Laserfiche WebLink
Inspection Report <br /> degreaser sludge since March 11, 2001. 1 informed Mr. Mason that failure to label a container with <br /> an accurate accumulation start date is a violation of California Code of Regulations, title 22, section <br /> 66262.34. I questioned Mr. Mason further about the circumstances under which the waste alkaline <br /> degreaser sludge is generated. <br /> According to Mr. Mason, the operator of the degreasing tank generates the sludge during tank <br /> maintenance, and the LC facility never accumulates more than 55-gallons of the degreaser waste <br /> before it is shipped to a permitted facility for treatment and disposal. I observed that the container <br /> holding the waste was located next to the degreasing tank where the waste is generated. I informed <br /> Mr. Mason that, so long as the container holding the degreasing sludge remains under the control of <br /> the operator of the process where the waste is generated, and so long as LC does not accumulate <br /> more than 55-gallons of the waste at any one time, and so long as LC complies with California Code <br /> of Regulations, title 22, section 66262.34(e), that LC could accumulate the alkaline degreasing <br /> sludge onsite for up to one year (i.e., "satellite accumulation"). The circumstances suggest that LC <br /> may accumulate the alkaline degreasing sludge for up to one year, and available HWTS records <br /> suggest LC has shipped alkaline degreasing sludge offsite in 2003 and has not been storing waste <br /> without a permit, and the volume and hazardous characteristics of the waste are low. However, I <br /> observed that in March of 2003 the local CUPA also documented that LC had failed to adequately <br /> label hazardous waste containers with an accumulation start date (see attachment 2). Therefore, the <br /> violation is hereby classified as a Class 11 violation because of the chronic or recalcitrant nature of the <br /> violation. Failure to prevent a similar violation in the future may result in classification of the violation <br /> to a Class I violation, which may be subject to an enforcement action and the assessment of <br /> monetary penalties. I documented the violation in the SOV issued to LC on December 22, 2003. <br /> We walked through a door at the East side of the facility and into an alley shared with a neighboring <br /> business (a door company). Access to the alley is restricted by a fence. I observed two 55-gallon <br /> hazardous waste containers in the alley, as shown in photographs 9a and 9b: <br /> � n <br /> A. <br /> \ 5i* <br /> fi <br /> w v-k l <br /> X !Y �I �� l?r►'! <br /> Y, <br /> a b <br /> Photographs 9a and 9b-Two 55-gallon containers(blue)holding hazardous"nickel-strip"waste. Also note open and <br /> unlabeled container holding recyclable copper scrap. Photograph 9b shows a close-up view of the hazard labels. <br /> I observed that the containers were not labeled with the hazardous characteristics and physical state <br /> of the waste in the containers, as required pursuant to California Code of Regulations, title 22, <br /> section 66262.34(f). I also observed that in March, 2003, the local CUPA documented that LC had <br /> failed to label hazardous waste containers with the hazardous characteristics and physical state of <br /> the waste. Therefore, although failure to label containers with hazardous characteristics and physical <br /> state of the waste in the containers might normally be considered a minor violation depending on the <br /> 9 <br />