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Valley Industries, LLC. 1---' 4/29/2004 <br /> Certification of Return to Compliance <br /> For Valley Industries, LLC. <br /> Inspection date 2/26/04 & 3/1/04 <br /> Under the section of Class I Violations, these corrections are either complete or in <br /> process of being corrected. <br /> Point # Out of Compliance Description and actions to return to compliance <br /> 04. (ILLEGAL OPERA77ON.S)(H.SY:) 25189.5 <br /> a. Cooling fluid observed dripping on the ground. Two scrap bins on <br /> the South side seen dripping into pans one of which showed signs of <br /> heading towards a nearby storm drain. Same fluid seen in a rain <br /> puddle outside tent on the West side of the property <br /> THE TWO SCRAP BINS ALONG WITH SIX OTHER BINS ARE <br /> NOW COVERED TO PREVENT MATERIAL EXPOSURE TO <br /> RAINWATER. THE CONTAINER CLOSEST TO THE STORM <br /> DRAIN HAS BEEN RELOCATED. WE HAVE A LOCAL <br /> CONTAINER MANUFACTURER DESIGNING AND BUILDING <br /> RAIN TIGHT COVERS FOR OUR TWO CONTAINERS AND WE <br /> ARE WORKING WITH OUR SCRAP DEALER TO PROVIDE <br /> CONVERED CONTAINERS FOR OUR OTHER STEEL <br /> COMMODITIES. WE HAVE MODIFIED THE PROCESSES <br /> FROM WHICH PARTS AND TAILINGS LEAVE A COOLING <br /> FLUID EXPOSED OPERATION. ADDED RINSING, DRAINING <br /> AND.WASHING STEPS HAVE BEEN ADDED TO REMOVE <br /> FREE FLOWING OILS FROM TRAVELING WITH THE PARTS <br /> AND SCRAP. COOLING FLUID RINSED OR DRAINED FROM <br /> THE PARTS FLOWS BACK INTO THE MACHINE SUMP. <br /> b. The analytical test results on the dry sweep in the machine shop have <br /> identified it to be hazardous due to its high chrome content. <br /> WE HAVE HELD THIS WASTE STREAM UNTIL THE TEST <br /> RESULTS CAME BACK. WE ARE COLLECTING THIS <br /> MATERIAL IN A SATALITE CONTAINER AND WILL DISPOSE <br /> OF IT THROUGH PROPER HAZARD WASTE MANIFESTING. <br /> c. Two of the three materials sampled during the inspection, the <br /> polishing dry sweeps and the laser floor sweeps, were found to be <br /> hazardous. The third sample, paint ash, was restricted to disposal at a <br /> class 11 landfill dumpsite. WE HAVE COLLECTED THESE <br /> WASTE STREAMS IN SATELLITE CONTAINERS SINCE THE <br /> INSPECTION REPORT WAS ISSUED. <br /> d. Metals in scrap bins were contaminated with free flowing oil. <br /> METALS BINS HAVE BEEN SECURED WITH AN ANTI <br /> PICKUP LOCK AND HELD FOR MATERIAL TRANSFER INTO <br /> PROPER DOT CONTAINERS FOR DISPOSAL AS HAZARDOUS <br /> WASTE. PROCESSES THAT PRODUCE SCRAP EXPOSED TO <br /> COOLING OILS HAVE BEEN MODIFIED TO REMOVE THE <br /> PRESENCE OF FREE FLOWING OIL ON THE STEEL. <br /> 1 <br />