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POTENTIAL VIOLATIONS <br />of <br />California Title 22 CCR and RCRA 40 CFR <br />Hazardous Waste Management Regulations <br />1. Failure to Make a Hazardous Waste Determination <br />22 CCR § 66262.11 (40 CFR § 262.11) states that a person who generates a waste, as <br />defined in section 66261.2, shall determine if that waste is a hazardous waste. <br />Findings: The inspectors observed a mostly empty aerosol can of brake parts cleaner in a <br />garbage can inside the heavy equipment maintenance area. The MSDS for the item <br />specifies that the dispensed liquid product is a RCRA hazardous waste for the <br />characteristic of ignitability and that aerosol containers should be empty and <br />depressurized before disposal. Unless aerosol containers can be completely emptied of <br />hazardous substances they are considered hazardous waste and should be managed <br />accordingly. The inspectors were told that Site 300 uses a ChemTrack bar code system to <br />ensure proper management of chemicals and that in this case the system was not <br />followed. <br />Facility Response: During the inspection a facility representative removed the aerosol <br />can from the garbage and placed the container in a nearby flammable storage locker. Site <br />300 committed to ensuring that facility personnel properly utilize their internal <br />ChemTrack system so that hazardous substances are correctly identified and managed <br />appropriately. <br />11 <br />