COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

Inspection Report in the citation of additional violations regarding management and disposal of the waste. I documented failure to make a waste determination for chrome polishing dust, along with the required corrective action, in the SOV (see attachment 3). In the plating area I observed a 55-gallon container holding hazardous waste. The container is shown in hoto ra hs 8a and 8b: ';'^ HAZARDOUS WASTE x , a b Photographs 8a and 8b-Hazardous waste container holding hazardous"alkaline sludge"waste. Note that lid on container cannot be secured because: 1. It is not the original lid,and 2. The top of the container has been cut-off. Photograph 8b shows a close-up of the label on the container in photograph 8a. According to Mr. Mason, the hazardous waste in the container is "alkaline degreasing sludge" that accumulates in the bottom of the alkaline "degreaser tank". According to Mr. Mason, the sludge is removed from the bottom of the tank periodically and containerized for transfer to a permitted offsite facility. The container shown in photograph 8a and 8b was more than half-full. I informed Mr. Mason that, pursuant to California Code of Regulations, title 22, section 66262.34, sections (a), (b), and (d), a generator of less than 1000 kg of hazardous waste per month may accumulate hazardous waste onsite for up to 180 days without a storage permit, and the 180-day period for a CESQG (i.e., generator of <100 kg of hazardous waste per month) begins on the date the CESQG has accumulated 100 kg of waste. A 55-gallon container holds approximately 210 kg of hazardous aqueous waste, assuming the waste is aqueous and has approximately the same density as water. Therefore, a 55-gallon container that is half-full would hold approximately 100 kg of hazardous waste. According to Mr. Mason, all the waste in the container was generated from one cleaning of the alkaline degreaser tank (i.e., generated on the same date). Therefore, the accumulation start date was the date the sludge was first placed in the container. I observed that the accumulation start date labeled on the container was "March 11, 2001", which was more than 180 days before the date of the inspection. Therefore, I informed Mr. Mason that storage of the hazardous alkaline degreaser waste onsite for more than 180-days without a storage permit is a violation of Health and Safety Code, section 25201. 1 documented storage of hazardous waste onsite for more than 90 or 180 days as a violation of Health and Safety Code section 25201 in the SOV. However, Mr. Mason stated that the waste sludge had not been in the container since March 11, 2001. According to Mr. Mason, the sludge is "picked up" routinely by a hazardous waste transporter and removed from the container, and LC inadvertently failed to record the new accumulation start date on the container the last time the sludge was picked up by the transporter. This was supported by reviewing recent LC transport manifests in DTSC's HWTS after the inspection, which shows multiple shipments of alkaline 8