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marked with the word "Empty" and the date-which they became emptied. Empty <br /> hazardous waste containers shall be managed 1 year from the emptied date. Correct <br /> immediately. <br /> It is true that there were two empty drums in the waste oil storage area that was not <br /> labeled. This has been corrected. (They were crushed and put in the scrap metal container <br /> for recycling). As for the 14 poly drums in the diesel tank secondary containment area <br /> without labels,two items needs to be addressed here. First, as one can see in Attachment <br /> # 3,they do in fact have labels. The problem was from the distance we could observe the <br /> drums, (they were inside the secure area) it looked like there was no information on the <br /> labels. Attachment#4 is a copy of a label removed from one of the drums out of the <br /> direct sunlight and Attachment# 5 is a copy of a label removed from one of the drums in <br /> direct sunlight. Both labels show that they were in fact made out and that 1-year has not <br /> passed. Subsequent to the inspection, all drums have been destroyed and disposed of <br /> properly. Attachment# 6 will show that this is not a double containment for the present <br /> diesel tank. At one time,this was a double containment for a 10,000-gallon diesel tank <br /> that has been disposed of many years ago. The diesel tank that is shown in Attachment# <br /> 6 is in fact, a 500-gallon tank that is "self-double-contained" and is positioned inside of a <br /> "secure area". <br /> Permit by-Rule: Inspectors Observation: -Plant Manager stated that PBR Unit will no <br /> longer be used in the future, and facility in the process of closing the unit. Pursuant to <br /> California Code of Regulations Section 67450.3 (c) 11 (0, and 67450 (c) 11 (d), facility <br /> has 90 days for the completion of closure according to the closure plan. In addition, <br /> owner or operator shall notify this office and any other agencies having jurisdiction over <br /> the closure project at least(15) days prior to completion of closure. —A permit from this <br /> office is required prior to taking boring samples. <br /> The Plant Manager did say that we have considered the closure of the PBR unit and that <br /> we were in the process of taking quotations for the closure and removal of the equipment. <br /> However, he did not say that we were in the process of closing the unit. — Subsequent to <br /> the inspection, and under the advice of Phillips Environmental Services,it would be <br /> prudent to submit to your office a more formal closure plan for your approval. We have <br /> therefore, issued a Purchase Order#2007-0176 for their services to prepare and submit a <br /> PBR Closure Plan, Closure Report and Certification. Quotations for the decontaminations <br /> of the equipment and the removal etc. is still pending. Therefore,the completion of the <br /> closure cannot be 90 days from June 11, 2007. <br /> Sincer <br /> Wayne F. arm <br /> Site Consultant—for- <br /> Sumiden Wire Products Corp. <br /> 3 <br />