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Lodi Chrome <br /> Mr. Reggie Mason <br /> March 15, 2004 <br /> Page 2 <br /> In your letter, you describe two distinct areas where polishing dust is generated: a <br /> "polishing room" and a "color buff" area. You state that the dusts produced in these <br /> areas comprise two different waste streams, but you only provide waste analysis for <br /> only one of the dust waste streams, and you have not provided any evidence to support <br /> the claim that different polishing dusts with different hazard characteristics (e.g., <br /> different chemical compositions) are generated by Lodi Chrome. I would like to point <br /> out that you did not mention two different polishing dust waste streams when I inquired <br /> as to the origin of the polishing dust that I observed all over the floor of the facility during <br /> the inspection. During the inspection, you stated that the polishing dust on the floor of <br /> the facility came from "chrome polishing", suggesting that all polishing dust came from <br /> one process. Regardless of whether or not Lodi Chrome generates two different <br /> polishing dust waste streams, your letter indicates that Lodi Chrome has made the <br /> determination that all polishing dust is hazardous (i.e., since you state that Lodi Chrome <br /> is now managing all polishing dust as hazardous waste). I would also like to point out <br /> that I did not observe any "satellite accumulation" container holding polishing dust in a <br /> polishing room on the date of the inspection, nor was I shown any satellite container <br /> holding polishing dust when I asked to be shown all containers holding hazardous waste <br /> at the facility, nor did I observe any evidence that polishing dust is accumulated in any <br /> kind of container. Rather, I observed large quantities of polishing dust on the facility <br /> floor. Therefore, violation 2 in section I of the SOV stands as a Class I violation as <br /> cited. <br /> During the inspection you stated that Lodi Chrome has been disposing of polishing <br /> dust to the regular trash (i.e., destined for sanitary landfill), but your letter of <br /> February 16, 2004 states that Lodi Chrome has been sending polishing dust waste <br /> offsite to a permitted facility for storage, treatment, or disposal. In reviewing hazardous <br /> waste transport manifests for Lodi Chrome dating back to 1996, 1 have not found any <br /> record that Lodi Chrome has ever sent hazardous waste containing chrome, or any <br /> other metals, to a permitted offsite facility for treatment, storage, or disposal. In <br /> addition, Lodi Chrome has not provided any evidence to show that hazardous waste <br /> polishing dust has been transferred to an offsite facility authorized to treat, store, or <br /> dispose of the dust. Therefore, based on your statements during the inspection, and <br /> since Lodi Chrome has determined that all polishing dust waste is indeed hazardous, <br /> DTSC has determined that on or about December 22, 2003 Lodi Chrome committed the <br /> following additional Class I violations: <br /> Lodi Chrome violated Health and Safety Code sections 25201 and 25189.2 by <br /> disposing of hazardous waste polishing dust as nonhazardous waste at county <br /> landfill. <br /> • Lodi Chrome violated Health and Safety Code sections 25162(c) and 25189.2 in <br /> by transferring hazardous waste polishing dust to a county landfill that does not <br /> hold a hazardous waste permit. <br />