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The following is an itemized list of our response to the hazardous waste violations for the Louise <br /> Avenue Water Treatment Facility: <br /> Violation#101 Managed a hazardous waste without an identification number. <br /> The City has an identification number, which is inactive. The City has submitted an application to <br /> reactivate identification#CA0000379085,which is attached. <br /> Violation#105 Failed to determine if a waste is a hazardous waste or retain waste analysis on site for <br /> 3 years. <br /> On May 25, 2016 a waste analysis was performed by BSK Laboratories for both the filter cake and the <br /> liquid from the filter press (see attached analysis). <br /> The summary of violation indicated the liquid from filter press was discharging into the storm drain. <br /> However,this is incorrect and is actually being discharged into the sanitary sewer drain. <br /> When used,the herbicide barrels are triple rinsed and the water used to triple rinse the barrels is <br /> emptied into the spray rig. The unused barrels are then returned to the supplier. However,some <br /> unused barrels where cut in half after they were rinsed to be used for other purposes not related to <br /> hazardous waste. These half cut barrels had accumulated standing water from recent rain events. The <br /> rain water was emptied from barrels and discarded in the normal trash. <br /> The hazardous waste,which was sprayed onto the rocks was picked up and disposed into the 20-yard <br /> sludge storage bin. Ferric Chloride caused excessive staining to the rocks and the rocks remain in place. <br /> The City will be replacing the stained rocks in the future. <br /> Violation#106 Failed to prepare and implement a contingency plan. <br /> The City is in the process of developing a contingency plan to meet this requirement. It is anticipated <br /> the contingency plan will be completed and submitted by October 31st, 2016. <br /> Violation#107 Contingency plan is incomplete. <br /> The City is in the process of developing a contingency plan to meet this requirement. It is anticipated <br /> the contingency plan will be completed and submitted by October 31st, 2016. <br /> Violation#111 Failed to maintain complete personnel training records. <br /> The City does have training records and is kept on site with the Operations Superintendent. Additional <br /> training that will be provided as required by CCR 66265.16(a-c)will also be included once obtained. <br /> Attached are employee job descriptions and current training records. <br /> Violation#115 Failed to keep signed copy of manifests from the designated facility for three years. <br /> Attached is a copy of manifest 004836601FLE. <br /> Violation#116 Failed to comply with uniform hazardous waste manifest exception requirements. <br /> Attached is a copy of manifest 004836601FLE. <br />