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Inspection Report and documentation or certification of return to compliance, as specified in each required corrective action in the SOV, must be submitted to DTSC via certified mail, return receipt requested, postmarked no later than 60 days from the date of the transmittal letter accompanying this report. VI. CONCLUSIONS LC is an electroplating facility, and electroplating facilities typically generate large quantities of RCRA waste. However, LC is a Conditionally Exempt Small Quantity Generator (CESQG). This appears to be due to LC's use of "continuous flow" rinsing, where rinse water (i.e., industrial water) enters the facility as fast as waste water is discharged from the facility. The continuous flow of rinse water assures that hazardous constituents (e.g., chrome VI, and other metals) never reach or exceed regulatory levels. Because waste rinse waters and waste residues from treatment of rinse waters typically represent the majority of hazardous wastes generated by electroplating facilities, LC appears to generate much less hazardous waste than other electroplating facilities. Even though the continuous flow rinse system may result in an excessively high -rate of water use by the LC facility, according to the local CUPA, LC is operating in compliance with city and county water -use requirements. While LC is a CESQG because LC does not generate any waste rinse waters or residues from waste water treatment, LC nonetheless generates other wastes characteristic of metal finishing operations, including sludges from process tanks, spilled plating bath chemicals including copper - cyanide plating solution, and waste chrome polishing dust. These wastes must be managed safely to protect human health and the environment. In general, the LC facility was not managing these wastes adequately on the date of this inspection. In particular, the LC facility was allowing significant quantities of spilled plating solutions and chrome polishing dust to accumulate on the concrete floor of the facility. The spilled plating solutions are being allowed to remain on the floor for extensive periods of time judging from the corrosion of the concrete floor. According to Mr. Mason, the floor of the facility is not lined with any sort of barrier or impermeable coating to prevent migration of the chemicals through the floor and into the surrounding soil. The circumstances significantly increase the risk for release of hazardous chemicals to the soil under the facility. The spilled chrome polishing dust may pose a threat to the safety of workers in the facility. In addition to the more serious issues related to spilled plating bath chemicals and chrome polishing dust, available documentation (i.e., this inspection report and the previous CUPA inspection report contained in attachment 2) suggests that LC is a chronic and recalcitrant violator of hazardous waste container management regulations. Specifically, LC has continuously failed to adequately label containers holding hazardous waste, LC has failed to keep hazardous waste containers closed except when adding or removing waste, and LC has failed to inspect containers holding hazardous waste weekly to ensure the containers are not leaking. In order to address the problems and issues raised during this inspection, it is suggested that LC implement the following: Although spilled hazardous chemicals should be cleaned -up immediately after they are spilled, LC should implement a routine maintenance schedule that includes cleaning spilled chemicals from the plating room floor. LC should provide training for all LC staff involved with hazardous waste management. Training should include facility -specific topics such as responding to spills, facility maintenance, container management and labeling, and documenting container inspections. It is also suggested that LC send staff involved with hazardous waste management to California Compliance School for hazardous waste generators. California Compliance School is provided at many locations throughout the State of California, and is an excellent source of general information regarding California's hazardous waste management requirements. California Compliance School can be reached by calling 1-800-337-1422. VII. ATTACHMENTS 13