Laserfiche WebLink
0 0 <br /> hazardous wastes. Indeed, data gathered from toxicity testing of these types of wastes <br /> has led us to conclude that atypically high levels of oil and grease would need to be <br /> present for this waste stream to be a characteristic hazardous waste. Proper operation and <br /> maintenance of the associated oil water separator for this area indicates to us that these <br /> levels of petroleum products will not be present in our wastewater. <br /> Using our generator knowledge, we also know that listed hazardous wastes are not used <br /> in the truck wash area and therefore the wastewater/residue is not a listed hazardous <br /> waste. DTSC Regulation Guidance Document(RG DOC#11, REV #1, 8-19-93)[JLDII. <br /> Violation#25—66262.23(a)(4) CCR—Generator manifest copies not sent to the <br /> Department within 30 days. <br /> Waste Management believes this finding to be in error. The facility has been consistently <br /> sending manifest copies to the DTSC within the required 30-day timeframe. In our <br /> review of the referenced regulation Waste Management does not find any DTSC <br /> requirement to document the submittal of the manifest copies. However ensure our <br /> determination was correct, Waste Management contacted Mrs. Mary Misener of the <br /> DTSC on May 180''2009 for guidance. Mrs. Misner agreed with our determination and <br /> stated that the DTSC does not expect or require that manifests be sent via registered or <br /> certified mail. The DTSC currently has a dedicated PO BOX for generator copies and <br /> another dedicated for Destination Field Copies. <br /> Waste Management recognizes that we do not have documented evidence that manifest <br /> copies were submitted to the DTSC. In review, Waste Managementbelieves the <br /> documentation of the submittal of the manifests would be a reasonable best management <br /> practice. Additionally Waste Management currently provides regulatory required annual <br /> refresher training for our personnel that handle these documents which outlines the <br /> regulatory requirements for submitting the generator copy of these manifests within the <br /> 30-day time frame the best management practice for documentation of the manifest <br /> submittals will be incorporated into the annual training. <br /> Violation#27—66262.40 (a) CCR—Failed to keep signed copy of manifest for 3 <br /> years <br /> Waste Management believes this finding to be in error. The signed manifest copies for <br /> the past three years were on site on May 18`x, 2009, but only located after the inspection. <br /> Unfortunately the manifests were miss filed in the binder we provided at the time of <br /> inspection. The site has recently begun using a specified binder for manifest copies of <br /> generated wastes. Similarly to the BMP mentioned above, Waste Management believes <br /> annual training on these requirements is appropriate. Retraining has already been <br /> performed with the operations specialist to ensure that all copies received are placed into <br /> the appropriate binder. The signed manifest copies from 00709893 — 12/14/2006, <br /> 000797307—9/7/2006, 001941907—7/10/2007, and 002913276— 1/25/2008, are <br />