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Inspection Report 22, section 66262.34(d) and Code of Federal Regulations 40, part 262.34(d)(5)(ii) as the applicable regulatory requirements for employee training. Actually, the reference provided in the SOV is incorrect, and it is California Code of Regulations, title 22, section 66265.16, as referenced in section 66262.34(a)(4) of title 22, that is the correct reference for the regulatory requirements regarding employee training. Failure to provide and document the required employee training is a Class I violation because it increases the potential that the employee will handle waste in an unsafe manner which may result in exposure of the employee to hazardous waste, release to the environment, or failure to adequately track the final destination of the waste due to failure to correctly complete transport manifests. Required Action: LC shall comply with the required action regarding this violation as documented in the SOV. However, since LC has requested additional time to respond to the SOV, LC shall complete the required action as specified in the SOV, and submit information as specified in the SOV to DTSC via certified mail, return receipt requested, within 60 days of the date of the transmittal letter accompanying this report. 2) Waste Determination: LC is required to perform a waste determination pursuant to California Code of Regulations, title 22, section 66262.11 for all wastes generated in manufacturing operations. LC failed to make a waste determination for chrome polishing dust. The failure to make a waste determination for chrome polishing dust is discussed in further detail in Section IV. of this report, and was documented as a violation in the SOV issued to LC on December 22, 2003. LC has requested an additional 30 days (i.e., until February 20, 2003) to respond to all violations documented in the SOV. This violation will be evaluated and classified based on the information LC submits in response to the SOV. Required Action: LC shall submit a detailed waste analysis for the chrome polishing dust to DTSC via certified mail, return receipt requested, postmarked no later than 60 days from the date of the transmittal letter accompanying this report. The analysis shall contain a detailed description of the composition of the polishing dust, and explanation of the procedure used to determine the composition of the dust. If LC determines that the dust is hazardous, LC shall also include a written statement describing how the dust will be managed in the future. 3) Inspection Records: LC manages hazardous waste in containers and must inspect containers and container storage areas weekly pursuant to California Code of Regulations, title 22, section 66265.174 as referenced in California Code of Regulations, title 22, section 66262.34(a). During the inspection, Mr. Mason stated that hazardous waste containers are inspected "every once in a while". I documented failure to inspect containers holding hazardous waste weekly as violation 3 in the SOV issued to LC on December 22, 2003. Failure to inspect containers was documented as a Class I violation. However, after further review, DTSC has determined that this violation is a Class II violation because the number of containers onsite (three) was low, and all containers appeared to be in relatively good condition, although one container was open. If in the future it is determined that LC is not inspecting containers weekly as required, this violation may be elevated to a Class I violation. Required Action: Comply with the required corrective action in the SOV. Implement a weekly inspection for all containers holding hazardous waste. At a minimum, document 11