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Inspection Report I„e VIW Pilkington The first area inspected was the fork lift maintenance area. In this area (photo # 7) routine maintenance is conducted on fork lifts. The hazardous wastes generated include used oil, oily solids, and antifreeze. The containers were stored in accordance with satellite accumulation requirements. Just to the north of the lift maintenance area is a battery recharging station. At the time of inspection there was also a pile of battery debris (photo # 6 and SOV) on the floor. Also in the battery recharging area was a 55-gallon drum of aerosol cans. In the drum were approximately 12 waste aerosol cans. Some were empty and others were not. We then walked through the main building to the hazardous waste storage area. Prior to arriving at the hazardous waste storage area there were four (4) industrial batteries stored on a concrete pad (photo #9). At this time I asked Mr. Wang if the batteries were a waste. He indicated that they were (see SOV). We then continued east and stopped at the sanitary waste water treatment system that Pilkington continues to use. Sanitary waste generated onsite is treated and sent to a reservoir where the water is reused at the plant including watering the grounds. No hazardous wastes are treated in this waste water treatment unit or sent to the reservoir. Pilkington's National Pollutant Discharge Elimination System Permit (Permit # CA0004839) status has not been verified in this report. We then moved over to the oil water separator (photos 11 and 12) which is west of the 90-day Hazardous Waste Storage building. Oily water generated from minor leaks from air compressors and compressor cooling water is piped to the oil water separator. Also drums that once held oily wastes are sometimes rinsed in the containment area and the waste generated from this operation is also treated (photo #14). The used oil is separated from the water by phase separation and the use of a skimmer. The used oil is then stored in a 1000 gallon tank (photos 11 and 15). As of January 12, 2004 a tank assessment for this tank has not been provided by Pilkington and the issue remains unresolved. The water once separated from the oil is sent to the reservoir. Between the oil water separator and the 90-day Hazardous Waste Storage Building entrance were three pallets (approximately 27 lead acid batteries) of spent lead-acid batteries (photo 17) that were not covered (see SOV). We then moved into the Hazardous Waste Storage Building (photo #18). This building is on a concrete floor that is bermed on all four sides. On the west side of the entrance were eight (8) Cathode Ray Tubes (CRTs), that were not labeled with the words "CRT's"," CRT devises", "CRT Glass", or "Contains Leaded glass" (see photo 19 and SOV). This violation has been reduced from a Class II violation to Minor violation. The following containers were correctly labeled with no other violations: • Seven (7) 5-gallon containers of cutting oil (photo 22) • Parts washing solvents • Two (2) super sacks of solvent-contaminated textiles (photo 20) • Waste lithium bromide (photo 24) • Containers of waste Tetra Potassium Pyrophosphate (photo 2) • Oily waste containers (photo 27) • Other off spec wastes • Empty containers (photo25) We then moved back into the main building and headed towards the float glass line (photo 23) through the compressor building. In the compressor building, there were four (4) satellite accumulation containers of oily solid waste which consisted mostly of used absorbent granules and pads located at various locations. No violations were found in this building. We continued through the main building to the glass float line the line is estimated to be 1/3 to Y2 of a mile in length. Throughout this line (approximately every 75 yards) was a satellite accumulation container of oily solid waste which consisted of absorbent granules and pads. These oily solids are the result of oil that drips along the line (photo 23).