COMPLIANCE INFO 2008-2010 - Laserfiche WebLink

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Violation#82:Failed to label universal waste to identify type of universal waste. The noted containers were properly labeled as universal waste and remain properly labeled,see attached picture. However an addition Universal Waste label will be affixed to UW containers for future accumulation. Item#83:Stored UW onsite for longer than 1 year....This is a new item that was listed on the Summary of Violations received on 4/14/2010. All universal waste has been dated and continues to be dated. Item#91:See attached"Continuation-Official Inspection Report"for violation(s)not listed above. Hand written item stating "Aerosol puncture". The required written notification (HSC 25201.16)was submitted via FEDEX on July 2,2009, addressed to Michelle Henry,SJCEHD.This notification was deemed incomplete by the EHD agency. The process of puncturing aerosol cans will be stopped and instead aerosol cans will now be managed as Universal Waste pursuant to HSC 25201.16. This update covers all of the items listed on the Summary of Violations received on 4/14/2010. While we do not necessarily agree that the items are violations,we have taken all reasonable efforts to correct the observations noted in the report.Training has been conducted with all employees that have contact with waste and these items have been reviewed during that training. If you have any questions regarding these items please feel free to contact me at 209-858-6429 or at Ryan.Mock@Simplot.com. Simplot would also like to clarify what is a reportable spill. Several items noted in the inspection appear to be categorized as releases requiring reporting,which appears to be incorrect. Secondary Containment California Health &Safety Code§ 25501(s)explains that a release "means any spilling, leaking, pumping, pouring,emitting,emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, unless permitted or authorized by a regulatory agency." CERCLA§101 (22)offers substantially the same definition. Interestingly the term "environment" is not defined in the California Health &Safety Code. However, CERCLA section 101(8) defines"environment"as "(A)the navigable waters,the waters of the contiguous zone, and the ocean waters of which the natural resources are under the exclusive management authority of the United States under the Fishery Conservation and Management Act of 1976,and (B)any other surface water,ground water, drinking water supply, land surface or subsurface strata, or ambient air within the United States or under the jurisdiction of the United States." Secondary containment essentially prevents contact of the released material with the environment.