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Mr.Jeffrey Wong <br /> San Joaquin County Environmental Health Department <br /> 25 March 2011 Page 2 <br /> Item 20 alleges that the hazardous waste label on a 5-gallon bucket of oily wastewater,used to <br /> accumulate atmospheric condensates generated during the operation of an air compressor in the <br /> maintenance area, and a 30-gallon drum of waste oil in the forklift repair shop were missing the <br /> accumulation start dates. Image 2 contained in Attachment 3 documents the current status of the label <br /> on the 5-gallon bucket used to accumulate atmospheric condensates from the air compressor. The label <br /> contains the accumulation start date and demonstrates compliance with hazardous waste labeling <br /> requirements as they apply to hazardous waste accumulation containers. The 30-gallon drum of waste <br /> oil identified in the Report has been removed from the facility in accordance with local,State, and <br /> federal hazardous waste control requirements. A copy of the Uniform Hazardous Waste Manifest <br /> number 001386381GBF is included in Attachment S. <br /> Item 32 alleges that a tank assessment has not been completed for hazardous waste accumulation tanks <br /> at the facility. The facility is currently working with Argos Engineering to have updated tanks <br /> assessments prepared by a registered professional engineer. A site walk and physical evaluation of the <br /> tanks occurred on 14 and 15 March 2011. The final report is pending. <br /> Item 35 alleges that the facility failed to conduct daily inspections of aboveground hazardous waste <br /> accumulation tanks. The facility has established procedures to document daily inspections of hazardous <br /> waste accumulation tanks. A copy of the inspection procedures are contained in Attachment 4. <br /> Item 44 alleges that the facility failed to prepare a contingency plan including list of emergency <br /> equipment,and written training record. Pursuant to 22 CCR 66265.52,the owner or operator of a <br /> facility that has already prepared a Spill Prevention,Control,and Countermeasures plan (SPCC)or some <br /> other emergency or contingency plan may use such plan if it contains provisions sufficient to comply <br /> with hazardous waste management requirements. Attachment 5 contains a copy of the SPCC <br /> implemented at the facility. Attachment 6 contains the Emergency Evacuation Plan (EEP) implemented <br /> at the facility. The plans satisfy the requirements of 22 CCR 66265.52. <br /> Items 60,61,&62 allege that the facility had failed to maintain signed copies of manifest numbers <br /> 003502275JJK,000805158GBF,000805564GBF,000806070GBF,000806394GBF,000806549GBF, <br /> 000347275GBF,000354793GBF and 000804879GBF as signed by the destination facility. The facility <br /> maintains electronic copies of Uniform Hazardous Waste Manifests on its EHS On-Demand web-based <br /> portal. Copies of the scanned images for the manifests in question are contained in Attachment 7. <br /> Item 67 alleges that the facility failed to retain wastewater analysis. Please see response to Item 7. <br />