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a. Description of the stored material and its source; <br />b. Date material was initially placed in the drum or container; <br />C. If the material is known to be a hazardous waste, the type of <br />hazard and the waste code must also be documented on the <br />label. <br />All waste containers must be secured at all times. Secured includes: <br />a. Closed with a lid or bung when not in use; <br />b. Staged/stored to prevent a spill or release. <br />We have had a training session and reviewed the above procedures <br />with our supervisory staff. (See attached management meeting <br />minutes) <br />NOV #25 & #28: CCR Section 66262: Manifests not sent to DTSC and failure to <br />determine status of manifest not received back from TSDF. <br />All manifests identified without site disposal confirmation have been <br />requested and received from the disposal facility. The documentation <br />has been received and is now on file. <br />NOV #34: CCR Section 66268.7(a) -Failure to make land disposal <br />determination <br />In reference to the brake pads and brass rivets being disposed of to <br />the local municipal landfill, it is SJC-EHD's contention that the brake <br />pads and brass rivets generated at the Knock -Out operation may be <br />hazardous. QBR, based on knowledge of its processes and incoming <br />materials, has determined that the brake shoe wastes and rivet wastes <br />generated at the Knock -off Machine are non -hazardous wastes since <br />these waste materials are not in a friable, powdered or finely divided <br />state (Reference Title 22, Section 66699). QBR requests that this <br />NOV be rescinded. <br />In the interim, QBR has adopted in it's hazardous waste management <br />program disposal procedures to satisfy SJC-EHD requests to manifest <br />the above referenced waste material until additional profiles can make <br />an absolute determination that the waste material shall be classified as <br />a hazardous waste. <br />NOV# 49: CCR Section 66265.16- Personnel training records not maintained <br />per regulation. <br />In reference to the training materials examined by the SJC-EHD <br />inspectors during the October, 1999 inspection. We are requesting <br />that this NOV be rescinded for the following reasons: <br />