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i <br /> I <br /> i <br /> The following is an itemized list of hazardous waste violations that have not been <br /> addressed for LATHROP WATER TREATMENT FACILITY/ CORP YARD as of <br /> September 22, 2016. <br /> Open violations from May 10, 2016 inspection <br /> Violation#118 -Failed to maintain complete personnel training records. {1 <br /> Employee training records for the management of hazardous waste were not available. Employee training records <br /> shall include: <br /> 1. the job title for each position at the facility related to hazardous waste management, and the name of each E <br /> employee filling each job; <br /> 2. written job description for each position listed above; <br /> 3. written description of the type and amount of both introductory and continuing training that will be given to <br /> each person filing positions listed above; <br /> 4. records that document that the training has been given to and completed by facility personnel. <br /> Training records on current employees shall be kept until closure of the facility. Training records on former <br /> employees shall be kept for at least three years from the date the employee last worked at the facility. Ensure that <br /> employee training is properly documented. <br /> Violation #202-Disposed or caused disposal of HW at an unauthorized point. <br /> Twenty yards of filter cake was dumped on the ground towards the south side of the property. The filter cake was <br /> dumped on the ground to allow for more storage in the hazardous waste container. Per Milton Daley, when they <br /> had generated enough hazardous waste to have a truck full, which is more cost effective, they would call their <br /> hazardous waste hauler and arrange for a pick-up. Hazardous wastes shall be disposed of only by transportation to <br /> a permitted hazardous waste treatment, storage, and disposal facility(TSDF). Immediately cease disposal of <br /> hazardous waste to ground, properly store hazardous waste and ensure that all future waste is hauled by a licensed <br /> hazardous waste transporter to a permitted TSDF. Submit a statement to the EHD, with supporting documentation, lI <br /> showing how this violation was corrected and how it will be prevented in the future. <br /> Violation #204- Failed to obtain a permit to treat hazardous waste. <br /> Filter sludge is being treated by compaction of the sludge without a permit to treat hazardous waste. Immediately <br /> obtain a permit to treat hazardous waste from the EHD. <br /> Violation #301 -Facility not maintained to minimize the release of a hazardous waste. <br /> At time of inspection: <br /> -it was seen where the batch tank had overflowed releasing hazardous waste, filter press sludge, to the ground. The <br /> hazardous waste appeared to flow North towards a storm drain. As we walked towards the spill area we, Robert <br /> Lopez and myself, were told the release was contained to that area and had not impacted the on site storm drain, <br /> which leads to the on site retention pond. Upon further investigation it was determined the hazardous waste had <br /> made it into the storm drain and into the on site retention pond. According to the contingency plan, "The <br /> LathroplManteca Fire District prepared a response plan which considers the chemicals stored on site. The specific <br /> chemicals considered are Diesel Fuel, Ferric Chloride, and Chlorine."The Lathrop/Manteca Fire District did not <br /> respond to this release. There was no clean-up done for this release because the facility was waiting until the water <br /> dried out, making it easier to clean-up. It is not known how much of the hazardous waste was released to the <br /> ground, into the storm drain and into the retention pond. <br /> -Filter cake, which appeared to have fallen out.from the storage bin, was seen on top of the off site storm drain. The <br /> filter press sits over the off site storm drain. <br /> -Several dark oily stains seen in the dirt and gravel near the heavy equipment storage area towards the back of the <br /> property. <br /> -One gallon container labeled as Graffiti buster V.O.0 was seen on a shelf severely rusted, actively leaking. <br /> Facilities shall be maintained and operated to minimize the possibility of a fire, explosion, or release of hazardous <br /> waste to air, soil, or surface water which could threaten human health or the environment. Immediately properly <br /> manage the above wastestreams according to Title 22 hazardous waste regulations. Submit a statement and <br /> supporting documentation explaining how this waste was managed and how this will be prevented in the future. <br /> i <br /> Page 4 of 6 <br />