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4. The metal plating operation generates a hazardous wastewater treatment sludge. The hazardous waste water is fed into a series of tanks where sodium hydroxide is eventually added creating a metal hydroxide. This metal hydroxide is then fed through a clarifier causing the metal hydroxide solution to settle out. The "metal free" solution goes through a pH adjustment and is then fed to the sanitary sewer. (The discharge to the sewer is under a permit - by -rule process imposed by Department of Toxic Substance Control.) The metal OH particles are pumped into a storage tank where a filter press removes additional liquid. This liquid then returns to the beginning of the hazardous waste water treatment system. The remaining metal sludge is placed in a roll off bin and manifested to World Resources in Phoenix, Arizona, for metal reclamation. LIKA manifested 1154 tons of the metal sludge in 1990. S. The gold plating occurs in a separate bath which is filled with cyanide (used to plate out the gold). The entire contents of the bath is manifested by J and B Reclaimer and taken to their facility in the Bay Area for gold recovery. (This process became obsolete in February 1992.) VIL VIOLATIONS: #1 A drum containing hazardous waste did not have a lid. #2 A drum, referenced in #1 above, also did not have a label. #3 Copies of Land Disposal Restriction (LDR) Notification forms were not being kept on site. VIIL OBSERVATIONS: Eric Trevena and I arrived at LILA Corporation at approximately 9:30 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 waste storage area. Mr. Neal then led Mr. Trevena and I through the manufacturing process describing each area we encountered and the waste it generates. Once we completed the walk-through of the facility, Mr. Neal directed us back to his office for the paperwork review. Mr. Trevena and I reviewed the facility's employee training records, hazardous waste manifests, contingency plan, and permit -by -rule notification. Mr. Trevena indicated to Mr. Neal that it was necessary to keep copies onsite of all Land Ban Notification forms. Mr. Neal stated he would begin this practice immediately.