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known that the drum residues had been deposited on the ground since QBR <br />was unaware that the drum with the residues existed. <br />NOV #10: Section 66262.11 (CCR) -Failure to determine if a waste is hazardous: <br />In reference to the accumulated washwaters, oily wastes, oily sludges and <br />brake shoe waste, QBR requests that the NOV be rescinded for the following <br />reasons: <br />a. QBR profiled its waste water in September, 1999. Based on the <br />analysis and determination of a third party specialist, the wash waters <br />were determined to be non -hazardous. This determination was <br />confirmed by QBR's analysis of the sample splits collected by SJC- <br />EHD during the October 1999 inspection. It was only at the <br />recommendation of SJC-EHD that the wash waters were manifested <br />as a regulated hazardous waste (Refer to Manifest No. 99099774). <br />b. The waste oils have been determined to be regulated waste based on <br />the shipment of the accumulated non-RCRA waste oils that were <br />manifested on 12/31/98, Manifest No. 98454133. <br />C. The oily sludges were in the process of being consolidated and profiled <br />at the time of SJC-EHD's October 1999 inspection. The profile has <br />been completed (see attached analysis) and approximately 50% of the <br />generated waste stream is a RCRA hazardous waste due to Cadmium. <br />Those drums of sludge wastes that contain hazardous levels of <br />Cadmium will be manifested as a RCRA hazardous waste. The <br />remaining oily sludges will be manifested as oily wastes, a non-RCRA <br />regulated waste. <br />d. Based on our knowledge of our processes and incoming materials, we <br />determined that the brake shoe wastes generated at the Knock -off <br />Machine are a non -hazardous waste since the waste material is not in <br />a friable, powdered or finely divided state (Reference Title 22, Section <br />66699). <br />NOV #12: Section 66265.31 (CCR)- Facility not maintained to minimize the release <br />of a hazardous waste <br />In reference to the dried material discovered on the ground near the pond and <br />patio area and "oily" fluid inside the Caliper Department's Degreasing Area <br />observed by the SJC-EHD inspectors during the October, 1999 inspection, <br />we are requesting that this NOV be rescinded for the following reasons: <br />a. The "oily" fluid observed by the county's inspectors was in fact soap <br />residues as a normal consequence of operation of the Caliper's Parts <br />Washer. Moreover, this de minimis release was contained inside the <br />Caliper's manufacturing building. A release inside a contained <br />structure does not constitute a release into the environment, and <br />