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Inspection Report <br /> Code of Regulations, title 22, section 66265.16 as referenced in California Code <br /> of Regulations, title 22, section 66262.34(a)(4). Mr. Mason stated that LC had <br /> no records of employee training. Therefore, I documented failure to provide <br /> employee training as a violation in the SOV issued to LC on December 22, 2003 <br /> (see attachment 3). In the SOV I incorrectly referenced California Code of <br /> Regulations, title 22, section 66262.34(d) and Code of Federal Regulations 40, <br /> part 262.34(d)(5)(ii) as the applicable regulatory requirements for employee <br /> training. Actually, those references are incorrect, and it is California Code of <br /> Regulations, title 22, section 66265.16, as referenced in section 66262.34(a)(4), <br /> that is the correct reference for the regulatory requirements regarding employee <br /> training. Failure to train employees is discussed further in Section V. of this <br /> inspection report. <br /> d. Waste Analysis Plan and Records (Title 22, CCR, Section 66265.13): A waste <br /> analysis plan is not required for this facility since no waste is being treated <br /> onsite. However, facility is required to perform a waste determination pursuant <br /> to California Code of Regulations, title 22, section 66262.11 for all wastes <br /> generated in manufacturing operations. LC failed to make a waste determination <br /> for chrome polishing dust. The failure to make a waste determination for chrome <br /> polishing dust is discussed in further detail in Section IV. of this report, and was <br /> documented as a violation in the SOV issued to LC on December 22, 2003. <br /> e. Inspection Records: LC manages hazardous waste in containers and must <br /> inspect containers and container storage areas weekly pursuant to California <br /> Code of Regulations, title 22, section 66265.174 as referenced in California <br /> Code of Regulations, title 22, section 66262.34(a). During the inspection, Mr. <br /> Mason stated that hazardous waste containers are inspected "every once in a <br /> while". I documented failure to inspect containers holding hazardous waste <br /> weekly as violation 3 in the SOV issued to LC on December 22, 2003. 1 <br /> instructed Mr. Mason that LC should manage containers and container storage <br /> areas and look for things such as incomplete or incorrect container labels, open <br /> containers, leaking containers, etc., and that LC should maintain some sort of <br /> record indicating that weekly inspections are being done. <br /> f. POTW Compliance Data: No deficiencies observed. According to Mr. Dennis H. <br /> Catanyag, REHS, the San Joaquin County representative present during this <br /> inspection, Lodi Chrome has not had any recent discharge violations and is <br /> operating in compliance with the discharge requirements of the local sanitation <br /> district. <br /> IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR <br /> I arrived at the Lodi Chrome (LC) facility located at 316 North Main Street in Lodi, California at <br /> 0845 hours on December 22, 2003 and met Mr. Dennis Catanyag, Registered Environmental Health <br /> Specialist with the Environmental Health Department of San Joaquin County (the local CUPA), in the <br /> parking lot. Mr. Catanyag and I entered the facility at 0855 hours and I made contact with the <br /> owner/operateor, Mr. Reggie Mason. I introduced myself and Mr. Catanyag to Mr. Mason and <br /> explained to Mr. Mason that the LC facility had been selected at random by DTSC for a compliance <br /> evaluation inspection. At 0900 hours Mr. Mason gave Mr. Catanyag and me permission to inspect <br /> the LC facility for hazardous waste activities, and to take pictures to document the findings of the <br /> inspection. <br /> 3 <br />