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• • 8. Because of #7 above, a soldermask contaminated debris waste stream was also added in 1992. This consists of such wastes as fitters, tape, etc., generated from the soldermask spraying operation. LIKA generated .5 tons of this waste which was hauled to Chemical Waste Management. 9. Lastly in 1992, LIKA began reclaiming the silver from their photographic process. LIKA generated .029 tons of this waste which was reclaimed by Drew Resources Corp., 1717 Fourth Street, Berkeley, California, 94710. 10. A one-time generation of waste 1,1,1 Trichloroethane was disposed of in January of 1991. This product was purchased to utilize in the cleaning of circuit boards. A small amount was used, and .39 tons of remaining product were manifested to Baron -Blakeslee, Inc., 8333 Enterprise Drive, Newark, California, 94560, the manufacturer, to be refined for reuse. VII. VIOLATIONS: #1 A 5 gallon bucket in the screening area (soldermask) containing hazardous waste did not have a lid. #2 A 5 gallon bucket, referenced in #1 above, also did not have a label. #3 A container of hazardous waste in the production area (solder dross) did not have a lid. #4 The personnel training records lacked documentation to verify annual refresher training. VIII. OBSERVATION Mr. Trevena and I arrived at LIKA at approximately 10:15 a.m. We identified ourselves to the receptionist and asked to speak with James Neal. Mr. Neal greeted us and escorted us to his office. There we described the nature of our inspection and requested permission to inspect the facility. After granting permission for the inspection, Mr. Neal provided us with appropriate safety equipment and we started the inspection in the hazardous materials and other product storage area. Mr. Neal then led Mr. Trevena and I through the production process describing each area we encountered and the waste generated therein. In the screening area we observed the new equipment being utilized to apply the soldermask. This machinery was under construction during our last inspection. Mr. Neal described the method previously used to apply the soldermask as a manual silk screening process. It was here that Mr. Trevena and I observed a 5 gallon bucket containing a waste oil/water mixture resulting from filtering the associated compressor. This bucket had no lid or label. Mr. Neal indicated he would speak to the employees of this area to determine the best way to comply the lid and label requirements. Mr. Neal explained that approximately 3-4 drums of solvent contaminated debris are generated from this process every 90 days. On the production floor, we viewed the area where the solder dross waste from the molten solder is skimmed -off and placed in a containment pan. This receptacle did not have a lid on it. We discussed this with Mr. Neal who stated it may be more practical to have the employees place the waste directly in the 55 gallon storage drum (which did have a lid and label) rather than using the transitional containment.