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3437 South WayADPLy D P.O.Box 6189AEMSPAC Stockton,CA 95206 STRUCTURES 209-982- 60 COlP. Fax:2D9-983-3375 HAZARDOUS WASTE INSPECTION JULY 11, 2011 Class 1 violation #19 A 5 gallon bucket of fluoride rinse was observed in the laboratory satellite accumulation area with an accumulation start date of May 11, 2009. The 5 gallon bucket actually contained fluoboric acid rinse water. It was hauled offsite on July 26, 2011 on Manifest No. 000037721 DAT, Line item 3 (Fig. 1). A 55 gallon drum of potassium cyanide was observed in the Bldg. IA satellite accumulation area with an accumulation start date of November 9, 2010. To clarify, it was a 30 gallon drum of potassium cyanide contaminated debris and not a liquid, that was hauled offsite on July 26, 2011 on Manifest No. 000037722DAT, Line item 3 (Fig. 2). A 55 gallon drum of perchloroethylene/debris was observed in the Vapor Degreaser area with an accumulation start date of February 15th, 2010, The 55 gallon drum of perchloroethylene/debris was hauled offsite on July 26th, 2011 on Manifest No.000037722DAT, Line item 6 (Fig.2). A full 55 gallon drum of chromium mop waste was observed in the Prime Line room without the date it became full. An additional container of chromium mop water was observed in the Prime Line room, putting the area over the 55 gallon storage limit. The full 55 gallon drum of chromium mop water was hauled offsite on July 26th, 2011 on Manifest No.000037722DAT, Line item 7 (Fig. 2). A new, labeled, 55 gallon drum with accumulation start date for the chromium mop water was placed in the area and the chromium mop water in the mop bucket (referred to as an additional container) was poured into the new 55 gallon drum. We believe that the mop bucket is part of the process (floor cleaning) and since the drum was full, we disagree with the assessment that the contents of the mop bucket constitute an exceedance of the 55 gallon storage limit. AASC Response to 7-11-11 Inspection Page 1