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Item 15: Decontamination equipment not provided. A hazardous waste container was not <br /> available for used absorbent at the time of inspection. Title 23 CCR section 66265.32 (c). <br /> Correct immediately. <br /> Response/Compliance Actions: The SJRTD notes that there was indeed a metal container <br /> available for accumulating used absorbent at the time of inspection. This container was, <br /> however, not readily visible to the SJRTD staff at the time of the inspection for pointing out to you. <br /> The SJRTD shall, however, ensure that the location of this container is at all times readily known <br /> to the SJRTD staff. This will be further reinforced during our one-stop environmental compliance <br /> workshop, which will take place in this month. Lastly, the SJRTD respectfully notes that the <br /> correct citation for the above regulations is Title 22 CCR, section 66265.32 (c), not Title 23. <br /> Item 19: This facility has stored hazardous waste on site longer than 90 days in large <br /> underground storage tank without a permit or authorization. HSC 25201 (a). Stop this practice <br /> immediately. <br /> Response/Compliance Actions: the SJRTD has stopped this practice and shall ensure that its <br /> hazardous waste accumulation time period is consistent with its hazardous waste generator <br /> status. As indicated above, TRE Consulting shall confirm our generator status and the SJRTD <br /> shall accordingly accumulate its hazardous waste. The SJRTD, however, respectfully notes that <br /> the correct citation for the above regulations is Title 22 CCR, section 66265.32 (c), not Title 23. <br /> Item 20: The facility did not label container of hazardous waste correctly. Title 23 CCR, <br /> 66262.34. Correct immediately <br /> Response/Compliance Actions: The SJRTD notes that all hazardous waste labels on its <br /> regulated containers are the yellow plastic type, which has the words"hazardous Waste"written <br /> on them. The rest of the required information such as: name and address of the facility <br /> generating the waste, the content and composition of the waste, the properties of the waste, the <br /> physical state of the waste, and the accumulation start date have been erased due to the weather <br /> elements and fading in the sun light. The SJRTD shall ensure the above erased information <br /> observed during your inspection is properly written with indelible markers. Furthermore, to <br /> ensure that the information on the hazardous waste labels are properly maintained, weekly <br /> inspections of hazardous waste containers and the SJRTD's one stop environmental compliance <br /> training workshop as required, under Title 22, shall be used as avenue of reinforcing this <br /> particular requirement to the SJRTD hazardous waste handlers. Again, The SJRTD respectfully <br /> notes that the correct citation for the above regulations is Title 22 CCR, section 66265.32 (c), not <br /> Title 23. <br /> Item 21: the containers of hazardous waste were not observed to be closed at the time of <br /> inspection except removing or adding waste. Title 23 CCR, section 66265.173 (a). Correct <br /> immediately <br /> Response/Compliance Actions: The SJRTD shall reinforce this important hazardous waste <br /> container management requirement during its one stop environmental compliance training <br /> workshop scheduled for this month. In addition, the SJRTD hazardous waste handlers shall be <br /> fully trained in understanding that the only time a container is left open is when hazardous waste <br /> is being added or taken away from that container. Again, The SJRTD respectfully notes that the <br /> correct citation for the above regulations is Title 22 CCR, section 66265.32 (c), not Title 23. <br /> 3 <br />