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informed us that these were satellite containers for ether and alcohol waste and that the waste was transferred to a <br /> 55 gallon drum in the waste storage area when the containers were filled. We informed Mr. Price that the <br /> containers needed to be labeled according to regulation and noted the violation and the corrective action required <br /> in the attached Summary of Violations (SOV). <br /> We continued down the main corridor toward the west. The following rooms were kept locked and no employees <br /> were present: MQUAD Seal, MR Sensor, Solder Dip, Boiler room, and Chiller room. Mr. Price informed us that <br /> these rooms had not been used for some time and there was not evidence of hazardous waste generation or <br /> storage in these rooms. There was some work being done in the Mold Room and Shear Form Room, but there <br /> was no evidence of hazardous waste generation. Apparently, very small amounts of waste oil (<55 gallons in a <br /> three month period)are generated when the oil is changed in equipment but that oil is immediately transferred into <br /> an accumulation container in the waste storage area. <br /> Having completed the walkthrough of the ISE building, I asked Mr. Price to show me the PBR-permitted <br /> wastewater treatment unit. The unit is not indicated on the attached facility map but I have attempted to note its <br /> approximate location. The unit is located outdoors to the Southeast of the building. The unit is enclosed in a <br /> locked cyclone fence and consists of a series of tanks where wastewater from the MECO Plating line is treated by <br /> pH adjustment and metal precipitation. The metal-sludge is collected and the treated water is discharged to the <br /> POTW. The treatment unit was well-maintained and daily inspection logs were present and up-to-date. I did <br /> observe several unlabeled empty containers and one unlabeled full container that Mr. Price said contained <br /> "Product". I noted the violations and corrective actions required in the attached SOV and informed Mr. Price <br /> verbally that he needed to properly label the containers. I asked Mr. Price to show me the waste accumulation <br /> area. <br /> The 90-day waste accumulation area is located in a locked wharehouse to the North and East of the ISE main <br /> building. Again, the accumulation area is not shown on some facility maps and I attempted to indicate its <br /> approximate location on the attached map. The accumulation area is secured under lock and key. Various <br /> container labeling violations were noted in the attached SOV. The violations included several unlabeled empty <br /> containers and two unlabeled containers that contained what appeared to be metallic strips coated with paint or <br /> ink. The material did emit a strong organic odor. Mr. Price was instructed to make a waste violation and to <br /> properly label and seal the containers, as noted in the attached SOV, <br /> Directly adjacent to the wharehouse where the 90-day accumulation area was located was a fenced-off area that <br /> contained several (approximately 20)unlabeled empty containers stacked on their sides. The area was outdoors <br /> and the containers were exposed to the elements. Mr. Price was instructed to label the containers and ship them <br /> offsite for disposal or recycling as specified in the regulations and the attached SOV. This completed the facility <br /> walk-through and we headed to Mr. Price's office to review various documents. <br /> Mr. Price was unable to produce written training plans or employee training records, a source reduction plan and <br /> annual plan review in accordance with SB14 requirements, annual notification for the PBR unit, a written waste <br /> analysis plan, an up-to-date and complete contingency plan, and manifests for any years prior to 2000. When <br /> asked for these documents, Mr. Price replied"we have most of that stuff, but I don't know where they are right <br /> now". Mr. Price explained that the previous facility manager, Mr. Gary Hubble, had left ISE rather abruptly. Mr. <br /> Hubble was in charge of hazardous waste management and apparently failed to transfer waste management <br /> documents to Mr. Price. As a result, Mr. Price was having a difficult time finding the requested documents and <br /> was unable to produce them during the inspection. I informed Mr. Price that it was the responsibility of ISE to <br /> maintain these documents onsit and that ISE had to locate the documents as soon as possible and then maintain <br /> the documents and make them available for inspection. The document-related violations are noted in the attached <br /> SOV. <br /> V. VIOLATIONS <br /> Yes No <br /> Summary of Violations attached? ❑ ❑ <br /> VI. CONCLUSIONS <br /> ISE Labs, Inc.(ISE) is engaged in the manufacture of various small electronic parts. The main hazardous-waste <br /> DTSC (3/95) Page 4 of 5 <br />