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APPLIED <br /> STRUCTURES <br /> CO RP. <br /> A black plastic bag of graphite prcpreg was observed being stored on top of a full 55 <br /> gallon drum of graphite prcpreg being moved from the Fiberglass Layup room, <br /> putting the area over the 55 gallon storage limit. <br /> The black plastic bag of graphite, along with the full 55 gallon drum of graphite pre-preg <br /> was set outside the area for compacting. We believe that the bag was still in process and <br /> did not put the area over the 55 gallon storage limit because after compacting the drum, <br /> the black plastic bag of graphite fit inside and filled the drum. The drum was hauled <br /> offsite on July 26, 2011 on Manifest No. 000037722DAT, Line item 12 (Fig. 2). If we <br /> didn't compact the graphite pre-preg, we would be generating more drums of waste <br /> instead of minimizing the number of drums generated. <br /> Two 55 gallon drums of liquid waste paint related materials were observed in the <br /> Paint Booth room, putting the area over the 55 gallon limit. <br /> One drum which was connected with a hose from the paint gun cleaner, contained paint <br /> and solvent waste. The other drum contained paint/catalyst waste. We had been <br /> considering this as 2 separate waste streams, but were informed by the Environmental <br /> Health inspectors that since the disposal company profiles them the same, it is one <br /> wastestream and not two. One of the drums was removed from the arca and was hauled <br /> offsite on July 26, 2011 on Manifest No. 000037722DAT, Line item 1 (Fig. 2). <br /> To prevent these alleged violations from occurring again, weekly inspections will be <br /> conducted in all satellite accumulation areas using a weekly accumulation area inspection <br /> log(Fig. 3). Employees will receive hazardous waste training on August 17, 2011. <br /> Class II violations <br /> #7 Metal fines generated from metal grinding, drilling, and cutting are being recycled <br /> as scrap metal without first determining particle size or hazardous properties. <br /> In the future, metal fines will be collected and handled as hazardous waste. <br /> An aerosol can of Quik Freeze that was not completely empty was observed in the <br /> trash in the fiberglass layup room in Building 5. <br /> In areas that use Quik Freeze, aerosol can drums will be placed in satellite accumulation <br /> areas. Employee training will be conducted on August 17, 2011. <br /> AASC Response to 7-11-11 Inspection Page 2 <br />