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therefore is not subject to the obligations of Title 22 (refer to HSC <br />Section 25501) <br />b. Our facility is indeed designed and maintained to "minimize" the <br />release of hazardous waste. The facility's manufacturing areas are <br />either completely enclosed inside a building, or take place on a <br />bermed/contained concrete pad. Drummed chemical materials or <br />wastes are stored inside, undercover, on a bermed concrete pad. <br />Our non -hazardous washwater that is accumulated on site is stored on <br />pallets on the bermed concrete pad until the washwater is either <br />recycled for re -use onsite or staged for shipment/disposal offsite. <br />Surface drainage that may result in a spill or leak is contained within <br />the facility's surface drainage conveyance system, which discharges to <br />a retention basin immediately adjacent to the site. <br />The spilled dried material discovered on the ground near the pond and <br />patio area is an isolated incident. Corrective action has been taken to <br />prevent a reoccurrence of spill or release in the future. (see NOV #4). <br />NOV # 19: Hazardous wastes stored for more then 90 days: <br />In reference to the onsite storage of the washwaters, oily sludges and waste <br />oils. We request that this NOV also be rescinded for the following reasons: <br />a. The wash waters were profiled, twice, and determined to be non- <br />hazardous. The washwater was only manifested as a NON-RCRA <br />regulated waste at the recommendation of the SJC-EHD inspectors. <br />b. As previously discussed, the oily sludges, generated at the facility's <br />two parts washers and recycling system were in the process of being <br />consolidated and profiled at the time of the county's inspection. In <br />accordance with Title 22's Generator requirements, QBR can <br />accumulate hazardous wastes onsite for 180 days, or 270 days if <br />offered for shipment to a TSDF 200 miles or more, away. The <br />consolidated and profiled oily sludge wastes will be shipped offsite for <br />disposal no later than January 31, 2000. <br />To insure that generated waste streams are tracked from the time of initial <br />generation, QBR has developed a waste drum tracking system <br />NOV #20, #21: CCR Sections 66262.34 &66265.173(a): Failure to label hazardous <br />waste drums and failure to keep hazardous waste containers <br />closed when not in use. <br />We have taken measures to ensure that all waste containers at QBR <br />are labeled with the following information at the time that the material is <br />initially placed in the drum: <br />