Cal/EPA July 3, 1997 Pete Wilson Governor Department of Toxic Substances Control 1011 N. Grandview Avenue Glendale, CA 91201 James M. Strock Secretary for CERTIFIED MAIL Mr. James Marzolino GNB Industries 2700 South Indiana Avenue Vernon, CA 90023 Dear Mr. Marzolino: On April 30, May 1 and May 2, 1997, the California Environmental Protection Agency, Department of Toxic Substances Control (DTSC), conducted an inspection of GNB Industries located on 2700 South Indiana Avenue, Vernon, California. The enclosed report describes the findings of this inspection, including all violations and any actions that should be taken by the facility to correct the violations. You are required by section 25185(c) (3) of the Health and Safety Code to submit a written response to the Department within ~ days describing the corrective actions that you have taken or propose to take to bring your facility into compliance. If you dispute any of the violations, you should explain your disagreement in this written response. All pertinent information derived from the inspection, including documents, and photographs are included as attachments to the report. This report will become a public document; you may request that any trade secret or facility security information be withheld from public disclosure. If you have any questions regarding this letter, or if you wish to meet with the Department to discuss any questions or concerns you have with Environmental Protection Mr. James Marzolino July 3, 1997 Page 2 the inspection, the report, the violations, or the proposed corrective action, please call Ruth Williams-Morehead at (818) 551-2916. sincerely, ~ ______ ~~ ~ ,J{{--:-----,n~Q \. --- LJ~~UI AgarWa~--- --~---719z51 01-----J supervising Senior Hazaraous Substances Scientist Statewide compliance Division Enclosures certified Mail P 529 033 568 Return Receipt Requested INSPECTION REPORT I. GENERAL INFORMATION GNB company Name: Facility Address: 2700 South Indiana Avenue, Vernon, Ca. Telephone Number: (213) 262-1101 EPA ID Number: CAD 097 854 541 RCRA ISD Hazardous Waste Treatment Facility. Facility Type: facility is 90023 currently be evaluated by the The Facility permitting Branch for issuance of a Hazardous Waste Permit. Regulated Units: for The facility is currently operating under an lSD their wastewater retention pond, lead smelter, wastewater treatment unit and four spent lead-acid battery and lead waste storage areas. waste Streams: plastic case Polypropylene materials, waste, furnace wastewater, slag, filter rubber sludge, and lead contaminated wipes and rags. Inspected by: Ruth Williams-Morehead, HSS - 4/30/97, 5/1-2/97 Dave Stuck, HSS - 5/1/97 Date of Inspection: April 30 - May 2, 1997 Type of Inspection: CEl XX. CME. O&M. Focused XX Limited _ Transporter Facility Rep.: James Marzolino, Environmental Engineer Type of Business: GNB is a secondary lead smelter which produces pure lead and lead alloy form mainly lead acid batteries and other lead bearing waste. The lead is subsequently sold as a product. II. CONSENT consent to photographs, personnel conduct reviewing and inspection and inspecting Yes/No that copying hazardous involves: records, waste taking questioning handling areas. Yes. Consent given by (name and title): James Marzolino, Environmental Engineer III.DOCUMENTS REVIEWED (circle all reviewed) I and David stuck reviewed the following records and the following violations were found: a. Manifests, Bills of Lading, LOR's, Exception Reports: The facility did not keep copies of LDR notices that are attached to the manifest when shipping wastestreams for disposal (attachment 1). off LDR Although the facility does not keep copies of the LDR notification, Mr. Marzolino provided me with a blank copy of the notification which is used during shipment (attachment 2). b. contingency Plan The contingency plan does not list the addresses of the emergency coordinators (attachment 3). Also copies of the contingency plan have not been provided to all local police and fire departments, hospitals, state and local emergency response teams, etc. that may be called to provide emergency services. c. Training Plan and Records: No violations were found. d. Incident Report: Mr. Marzolino explained that on Monday 4/28 a mud tank overflowed in the storm channel (Attachment 4). The mud tank contains lead oxide used a blast feed for the furnace. Mr. Marzolino stated that initially the spill was contained on the site. He stated that a delivery truck(s) spill which caused drove through the splash over the retaining wall. it to Mr. Marzolino assumes that during the initial clean-up the pressure from the water hose the spill to over the containment berm. Mr. Marzolino stated that he notified DES, the City of Vernon Health and Safety and the Fire Department. Mr. Marzolino stated that the fire department sent a response team, and the city of Vernon notified the Los Angeles County Flood Control. The Los Angeles County Flood Control sent two inspectors, Roland Romaine and Daryl Taylor. Mr. Marzolino stated that storm drain will be sampled and witnessed by the city of Vernon and that he will submit a copy results to DTSC. e. waste Analysis Plan and Records: The waste parameters analysis plan does not for which waste will be describe analyzed for the the "acceptable plant scrap metal" and the sampling method used for" acceptable plant scrap metal "would not provide a representative sample of the waste to be analyzed (attachment 5). I spoke with Jeff Pierce of Lake Engineering, Inc., who is involved in preparing the facility's waste analysis plan. Mr. Pierce explained to me that because the plant acceptable scrap material is composed of several metallic lead plates, lead sludge and lead dross. In order to get a composite sample of each layer the plant scrap is placed on the floor lined with plastic. The scrap is inspected and a composite is taken based on what is in the drum. f. operation Log: The facility has an inadequate operating log (attachment 6). The current operating log is an inventory of the number of pallets in each battery storage area, but does not describe the date the batteries are received, the methods of its treatment , storage or disposal and does not cross reference any of the information to a hazardous waste manifest. g. Inspection Records The facility's inspection records were inadequate. It did not equipment, include inspections of monitoring, securi ty devices, safety operating and structural equipment and does not identify problems to be looked for during the inspection (attachment 7) . Mr. Marzolino stated that GNB is currently modifying its inspection schedule and logs and gave me draft copies (attachment 8) • h. Tiered Permitting Applications and Authorization Letters: N/A i. Annual/Biennial Reports: No violations were found. j. SB 14 Plans: The facility· has an adequate waste minimization plan. k. Closure Cost Estimates and updates: Facility permitting is currently and post-closure cost (attachment 9). revising closure 1. Part A: An application was filed in 1981 by Gould , Inc. former owner of GNB. subsequent to RSR Corporation purchasing GNB a revised Part A has been filed and the facility is currently operating under interim status. m. Part B: Part B is currently under review by Jamshid Ghazanshahi. n. POTW Compliance Data: The facility has a permit (11092R-1) to discharge in the Los Angeles County Sanitation District. o. Tank and/or containment certifications: Mr. Marzolino stated that under an Supplemental Environmenta·l Program negotiated as a result an Enforcement case several years certification program. ago, GNB will be implementing tank Mr. Marzolino said that this program was to begin this year but due to several delays in other segments of the Supplemental Environmental" Program, the tank certification program may be postponed. p. Air Board Permits The facility has numerous air permits for their smelting and processes. q. variances: Not currently operating under a variance. r. Recycling Records: N/A s. Other N/A IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR On April 30, 1997 at approximately 2:30 p.m. I began my inspection at GNB Technologies. I met with Mr. Jim Marzolino, Environmental Engineer. I explained to him the purpose of my visit was to conduct a compliance Evaluation to determine compliance with hazardous waste regulations and statutes. Mr. Marzolino stated that he understood the purpose of my visit and gave me, Ruth Williams-Morehead, permission to inspect the facility. We began our discussion with the background of the facility. Mr. Marzolino explained treatment and storage facility. that GNB is a GNB stores lead-acid batteries and lead bearing materials which is used as raw feed in the facility's lead to produce elemental lead. Mr. Marzolino explained that lead batteries and lead bearing materials are received from off-site. The batteries and lead bearing material are either placed in one of three storage areas are immediately placed into the reverberator furnace. can be smelted, they However before the batteries are crushed. The components resul ting from crushing the battery which consist of post, plates, paste mud and polyethylene casings are conveyed to a clarifier. The sulfuric acid is collected in the a tank and used in the process. The polyethylene is washed, placed in a trailer and eventually sent offsite as hazardous waste. The post and plates are placed in the reverberatory feed room prior to being fed into the reverberatory furnace. The paste mud, after being desulfurized, as well as filter cake generated from the wastewater treatment unit and desulfurization unit are also fed into the reverberator furnace. Lead dross and lead slag are produced in the reverberatory furnace. The lead dross and lead slag are placed into the blast furnace. The blast furnace generates a second slag which is sent to Kettlemen Hills for disposal. The dirty hard lead generated from the blast furnace is sent to refining. Mr. Marzolino also explained that GNB will be closing battery storage areas 101 and 102 to further expand the reverberatory feed room. Mr. Marzolino also stated that . GNB will possibly redesign the stormwater pond. Mr. Marzolino stated that currently the stormwater pond is being used as a secondary containment system to collect runoff generated from rain and on-site activities. He stated that the upper liner of the pond is torn and may be leaking between the upper and lower liners. He stated that currently the inlet pipe to the storm water pond is being blocked with a bladder blown up with air to seal off the opening to the pond and the water is being directed to the wastewater treatment unit. I ended the inspection at this time and continued the next day, May 1, 1997. On May 1, 1997, I and Dave stuck resume the inspection. I again received permission from Mr. Marzolino to conduct the inspection and we began the record review (see section III). After the record review we had lunch and resumed the inspection and began the walk-through of the following areas: Surface Impoundments As closed. mentioned earlier the However during surface impoundment the walk-through I is observed puddles of water in the surface impoundment and tears were noted in the upper I iner (photos 1, 2 and 3). Presently the surface impoundment is not being used and wastewater generated at the facility is being routed to the wastewater treatment pond. Next to the surface impoundment was three 20,000 gallon portable tanks. I asked Mr. Marzolino what the tanks contained and he stated water removed from the surface impoundment. He said that the wastewater had been sampled, and the results are pending, in order to dispose of the wastewater properly. I observed that the tanks were not marked with hazardous waste labels or accumulation finding. dates and informed Mr. Marzolino of my He stated that he would label the tanks before the end of the day. PAC Center PAC Center is where incoming batteries which are returned to GNB from the manufactures are sorted to determine if they will be placed in the smelter or sold as a secondary battery (photo 4). Mr. Marzolino stated that a battery is sold as a second if it can be recharged and if the battery is still under warranty. At the PAC Center sixteen pallets of batteries were not labelled with the date received (photo 5). However at the end of the facility walk-through we revisited PAC and I observed that each pallet was dated (photo 6). Battery storage Areas Area 7 (104 and 105) I observed that the facility was storing broken batteries in seven open drums (Photo 7). I told Mr. Marzolino broken batteries needed to be stored in closed drums. Mr. Marzolino said that usually broken batteries are placed into the battery crusher but labeled. spent ~hen they are placed into storage they are usually Also I observed that a drum containing casings from ammunition was not labeled I explained to Mr. Marzolino that this was a lead bearing waste and need to be marked with a hazardous waste label and accumulation date, and not only the date the ammunition was received. Area 16 (101 and 102) Batteries and lead bearing material are not being stored in this area. As mentioned earlier the facility is expanding the reverberator feed room into this area. Area 14 (103) No violations were noticed during the inspection in this area. Area 6 (106, 107, and 108) No violations were noticed during the inspection in this area. We concluded the inspection at this time. had to leave early and requested that I Mr. Marzolino conduct the exit interview the following day. VI. CONCLUSIONS: On May 2, 1997, I conducted the exit interview with Mr. Marzolino. We discussed the Summary of Violation (attachment 10), and schedule for compliance. Hazardous Substances Scientist Date ATTACHMENT 1 ZiLile ,-,I Ccili(Jrnio--Environmenful Protection Agenr.y Form Approved OMB No, 2050--0039 (Expires 9·30·96) Please print or type. Form designed for use on eli/e (12"pi/ch) See Instructions on back of page 6. No. UNIFORM HAZARDOUS! WASTE MANIFEST iii 3. I Address GNII 2100 !..0l:1 4. G E N E R A T <. '0 R w '"0 '" '" Z AW ~ « z 0 ;:: « z w :r .... ~ 16. GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed, marked, and labeled, and are in aU respects in proper condition for transport by highway according to applicable international and notional governmenf regulations, ~ « u ~' If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically prccticable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment; OR, if I am C/ small . generator, I have made a good faith effort to minimize my waste generation and select the best I ~ 0:: '" 0'" ... >- U Z w C!J :::'"w w "- 0 W « '"U Z 19. Discrepancy Indication Space F A C I L I T Y DO NOT WRITE BELOW THIS LINE. DTse a022A (1/95) EPA 8700-22 Yellow: GENERATOR PLAN T " ,/ <--' ) 19 .} ~ WEIGHED ; ,(. G N;BiINCORPORATED C , / Lt~'G", 6,,--" C A..1....' ,7 ~. WEIGHED FOR (OR ACCOUNT OF) Cl 7 REMARKS: > ·-d 4> • /,} RECEIVED C':? to' . {/ / J 7 J WEIGHED BY'--------7,-:,------------ BY - PLANT COpy . \ <~ \ \\ \\ METALS DIVISION LOS ANGELES, CALIFORNIA (,...., //Y('v!-Z.--· MERCHANDISE DELIVERED TO ",}. .:/":' I; ~ .; ',':'-1. '!l'i =--------.::...-::..-- <21 MATER"L .. ~ ') LOtC' .tk/~ in ,l;/>Oi '-,;:i":..!t;('; ;i, }\\\ 74100 1b C:;F:: ~51940 Ib T?-! 422f::,O Ib f"H ", (' L· lby;7cl l/ '7/ , • ,,/J ( / ,:/ DATE , ~ 76336 -;'1' Z ? / TRANSFER * 'k \" <:. '4 'Ih~ -f..x-·'·~ ';,-' (, " -.:" l'* ,-<~-j>~~;:;..~~:;, <-~ 1 J Sl~nlo-Envlronmenlol Protection Agency Form A'p-proved OMB No, 2050--0039 (Expires 9-30-96) please print or type, Form c!e"igned for use 011 elite {!2.pifch; ,ypewritf!r ~U~JfQI!M .~ HAZARDOUS See Instructions on bock \, Department of Toxic SuhstclI1ces Conti Sanomenio, Coli/ornicr 1. Generator's us EPA ID No, 2, Page' Information in the shaded areas is not required by Federal law, WASTE MANIFEST a GNlI BA1.'TERY TrlCl:!N()J.,OGIES 2700 ~j. S1'. LOS JINGIlL.ES. CALIF. 90023 i Generator's Phone 7. Transporter w '" Z 0 0- Ifl '" ~ « z 0 ;::: « z 1,l1tAR llYll P:ilOTECTlON & RUBBER' GLOVES WASil THOROUGHLY ..WI)!,R HANl)LING. w J: EMERGENCY CONTACTS' 1. CtlEi'mmC (BOO) /,21,-9300 2. GNH (213) 262·,·1101 J-~ 16. ~ « u I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping nome and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and nationol government regulations. If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of wasfe generated to fhe degree I have determined to be economically procticable and tnat I have selecfed the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment; OR, if I am a small generator, I have mode 0 good faith effort to minimize my waste generation and select fhe best ""0 >- U Z w Cl '" w '...." w Printed/Typed Name 0 W V) « u ~ , 19. Discrepancy Space ,•• I l I T Y ih Printed/Typed Name DO NOT WRITE BELOW THIS LINE. DTSC·OS022A (1{9.5) EPA 8700-22 Yellow: GENERA TOR RETAINS, - See instructions on ba... ,.jf page 6. Depar~ment of Toxic Substances ( Sacramento, California -I l i area5 is not required by Federal law. 9. Designated facility Name and Site Address u.s. ECOLOGY !lIlY 95, 10 IIILES SOUTH BEATTY NEVADA 89003 16. GENERATOR'S CERTIFICA nON: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed, marked, and labeled, and ara in all respects in proper condition for transport by highway according to applicable international and national government regulations. If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment; OR, if I am a small generator, J have made a good faith effort to minimize my waste generation and select fhe best meff10d that is I '" 0 >U Z w Cl '";:;: w w o.L 0 W V) () £; F A , , C L T Y DO NOT WRITE BELOW THIS LINE.· DTSC 8022A (1/9.5) EPA 8700-22 Yellow; GENERATOR RETAINS Stata of California--Envitanmental Protection Agency Form Approved OMB No. 2050-0039 (E)(pire~ 9-30-96) form designed for use on elite Please See Instructions on back of page 6, Department of To)(ic Substan(es Conlrol Sacramento, California i areas is not required by Federal law, .• UnifORM H'IAZARllOlIS WASTE'MANIFEST GNB BATTERY TECHNOLOGIES 2700 S. INDIANA S'f.. "",,,ate,', Pho," (213) 262-1101 4. 5, Transporter 1 Company WILEY LOS ANGEL,j!S. CAl.Xl!'. 90023 ....... SANDFJl.S 9. 1&61 SUNNYSlDB CT. llAli:.ERSFlELD, CAl,IF. 11. ..... RECYCLABLE HAZARDOUS W&STE, SOLID, 'N.O.G.·'CI..ASS 9, NA 3071, PC 111 ," " ' w .. '"0Z "- VI W '" ~ « z 0 ;:: « z lll:Sl!1it..nOR REQUIRED, 1-IASH TllOROt1GHLY· AFTER ilANDLli\G. w >- :t: ~ ~ 16, GENERATOR'S CERTIFICATION: I hereby declare fhatthe contents of this consignment are fully and accurately described above by proper shipping name and ore classifjed, « u pocked, marked, and labeled, cnd are in all respects in proper condition for transport. by highway according to applicable international and national government regulations. ~. If I am a large quantity generator, I certify "that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economicolly practicable and that I have selected the practicable method of treatment, storage, or disposal currently avcilable to me which minimizes the present and future threat to human health and the environment; OR, if I am a smaU"quantity generator, I have mode a good faith effort to minimize my waste generation and select the best il to me and that I can afford. . . . Printed/Typed N9.!ne ~ ii: V) ~'.O:: 0 '~>- U Z w l? '" w ~ w u.. 0 w V) « u ~ • , A C L I T Y Month DO NOT WRITE BELOW THIS LINE. DTSC 8022A (1/95) EPA 8700-22 Yellow: GENERATOR RETAINS Slate 01 Colifornio--EnvironllHmlal Protection Agency Form Approved OMS No, 2050-0039 (Expires 9-30-96) Please print or Iype. Form designed for use on alit/! (12-pilch) typewrifer. UNIFORM HAZARDOUS WASTE MANIFEST See Instructions on back of page 6. 1. Generator's US EPA 10 No. No. Deportment of Toxic Substances COrllro! Sacramento, California 2. Page 1 Information In the areas is not required by Federal law. 3. GNB BA'£TF;RY. TECl:lNOLOGI ES ~L08 4. ANGELES jt CALlF ~ 90023 7. Transporter 2 Company Name o. RECYCl.Alll.E HAZAlillOUS WASTE, SOl.ID, N.O.S. CLASS 9, NA 3077, PC ill G ~~~--------------------------------------~~~~~+-~-F~~~-+----- N b. E R A <. T o R w VI Z 0 "- VI w '" ..: ~ z 0 ;:: ..: z w :c .... ~ ~ 16. GENERATOR'S CERTIFICATION: I hereby declare thot the contents of this consignment are fully Clnd accurately described above by proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulotions. ..: u ~' If I am a large quantify generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that J have selected the practicable method of treatment,' storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment; OR, if I am a small generator, I have- made a good faith effort to minimize my waste generation and seled the best I I ~ 0: VI '" 0 >u , Z LU "'"::!: w w Printed/Typed Nome u. 0 w 19. Discrepancy Indication Space VI ..: U ?; F A C I L I T Y Printed/Typed Signature DO NOT WRITE BELOW THIS LINE. DTSC 802210. (1/9.5) EPA 8'~22 Yellow: GENERATOR,!ETAINS ATTACHMENT 2 ,ction This Form Is submllled to In accordance with the requirements 01 CCR Title 22, Chapter 30, Article 40 which restrlelS the land disposal of certain hazardous wastes. I have marked the appropriale box (boxes A, through D.) below to Indicate how my waste must be managed to conform to the land disposal restrictions. A copy of all applicable treatment standards and waste analysis data, where available, Is maintained at the GNB Battery Technologies facility Identified on the manifest referenced above. If the waste Is not a RCRA regulated hazardous waste, I have also entered the appropriate California Waste Code and checked the appropriate box In the' table below to Indicate the applicable non-RCRA hazardous waste listing from 22 CCR Section 67702 I I Complete This table For Non-RCRA, California Regulated Hazardous wastes Only Line Check lIem Here Restricted waste Description Relerence CCR Title 22 Metal-containing aqueous waste that contains any of the metals or metal compounds Identified In 22 CCA 67702(bX1) 66699(b). 67702(bX2) , Wastes containing polychlorinated biphenyls (PCBs). [reserved) [reserved! [reserved! [reserved! Metal -containing solid waste that contains any of the metals or metal compounds identified in 22 CCA 67702(b)(7) 66699(b). [reserved! [reserved) Aqueous and liquid organic waste that contain any organic compound measured by EPA Test Methods 8080, 67702(bXl 0) 8140. 8150.8240. and 8270 described in Test methods for Evaluating Solid wastes, Physical! Chemical Third Edition. Methods, SW-846, Solid hazardous wastes that contain any organic compound measured by EPA Test Methods 8080, 67702(bXl1 ) 8140,8150,8240. and 8270 described in Test methods for Evaluating Solid wastes, Physical! Chemical Third Edition. Methods, SW-846, 1 2 3 4 5 6 7 8 9 10 11 l i j A. RESTRICTEDy,'ASTE REQUIRES TREATMENT . I am the generator of the waste identified above which must be treated to meet the applicable treatment standards set forth in GGA Tille 22, Chapter 30, Article 41 prior to land disposal. I j B.1 N RESTRICTED WASTE TREATED TO PERFORMANCE STANDARDS I certify under penalty offaw that I have personally examined and am familiar WI!to the trealmenttechnology and operation olthe treatment process used to support this certification and thai. based upon my inquiT oft,\ose individuals immediatedly responsible for obtaining this information, I believe that the treatment process has been opera.'e:' and mainfained property so as to comply with the performance levels specified in CGR Title 22, Chapter 30, Article 41 withoC'! dilution of the prohibited waste. I am aware that there are significant penalties for submitting a false certification. inctuding the possibility 01 a line and imprisonment.' c:::J C. RESTRICTED WASTE SUBJECT TO A VARIANCE The waste identilied above is subject to a capacity variance which expires on c=J D. RESTRICTED WASTE CAN BE LAND DISPOSED WITHOUT FURTHER TREATMENT N I certify under penalty ollaw that I have personally examined and am familiar with the waste through anatysis and testing or through knowledge of the waste to support this certification thaI the waste complies with the treatment standards specified in GCR Title 22. Chapter 30, Article 41 without dilution of the prohibited waste. I am aware that there are Significant penalties for submitting a fatse certification. including the possibility of a line and imprisonment. N , t hereby certify that a/l intormation submitted in this and all associated documents Is complete and accurate to the best of my knowledge and information. ITitie Signature IDate K. W. PLASTICS CO. LAND DISPOSAL RESTRICTIONS CERTIFICATION Attach to Hazardous Waste Manifest Number,--:_ _ _ _ _ _ _ _-'I certifY that the material( s) described on the attached Hazardous Waste Manifest are sent to KW. Plastics, Bakersfield, California for RECYCLE ONLY. Should this material be disposed of in any other manner, it is subject to the following treatment standard as prescribed under CCR 66268 and 40 CFR 268 (check all that apply): I have checked the appropriate box in the following treatment standard as prescribed under CCR 66268 and 40 CFR 268: o D002 Corrosive Characteristic Waste o D004 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for arsenic. o D005 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for barium. o D006 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for cadmium. o D007 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for chromium. o DOOS Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for lead. The plastic materials of spend lead acid batteries. o D009 Nonwastewaters that exhibit, or are expected to exhibit, the characteristic of toxicity for mercury. Signature Name and Title Date ATTACHMENT 3 . Date: February 1997 Revision No.: 4 Page No.: 10-1 EMERGENCY CONTINGENCY PLAN AUTHORIZED EMERGENCY COORDINATORS Persons autborized to act as emergency response coordinators should be contacted by pager according to a weekly "ON CALL" rotation. Monthly roster is available in CPI, CP2, CP3 and at tbe guard gate. NAME TITLE PLANT # 213/363-1101 PAGER # PIN # HOME # Dave Wesley Regional Director EXT. 275 800/225'()256 5974572 909/949-9520 Jim Marzolina Reg. Env. Eng. EXT. 259 800/225'()256 6053573 714/538-8805 Sylvia Ross Reg. Human Resources (818)937-2545 800/225.()256 5974891 818/961-9644 Carlos Pena Process Engineer EXT. 260 8001225'()256 907152 213/300-2179 Ty Avendano Health and Safety EXT. 215 800/225'()256 5974573 8181752-1613 Bill McKusky Engineer EXT. 226 213/963-1499 8181796-8542 Jim Puller Maintenance Engineer EXT. 264 213/530-9113 N/A N/A 310/970-1818 THE PRIMARY COORDINATOR WILL BE LISTED ON A CALENDAR AS STATED ABOVE. IF YOU ARE UNABLE TO CONTACT THE PRIMARY COORDINATOR CONTINUE CALLING OTHERS ON THE LIST UNTIL ONE IS REACHED_ AUTHORIZED SHIFT SUPERVISOR Persons autborized to act as shift supervisors are: (alternate Emergency Coordinator or onsite Coordinator) NAME TITLE PLANT # 213/363-1101 PAGER # Rafael Perez Depanonent}lead EXT. 224 213/991-6970 Joe Gonzalez General Supervisor EXT. 286 Bob Emerson Department Head EXT. 287 Jack London Shift Supervisor EXT. 286 Joseph Davis Shift Supervisor EXT. 286 NA NA NA NA CELLULAR # NA NA NA NA NA HOME # 213/583-3836 213/566-7323 714/828-5389 3101788-9154 7141621-4405 Date: February 1997 Revision No. : 4 Page No.: lOA-8 \) TABLE 10.6 CONTINGENCY PLAN DISTRIBUTION AND RECORD OF UPDATES DISTRIBUTION & REVISIONS Environmental Engineer Plant Manager Plant Engineer Guardhouse Health and Safety Manager Wastewater Treatment Building Maintenance Shop RMPS Refmery Administrative Building Laboratory Smelting Building Scalehouse Employee Facilities Vernon Fire Department Vernon Police Department L.A. County Sheriff Telegraph Medical Clinic Spectrum Industrial Medical Clinic Beverly Hospital Rio Hondo Hospital \(' - ~ ATTACMEN 4 TECHNOLOGIES May 27,1997 Mr. David Sanchez Industrial Waste Inspector Los Angeles County Department of Public Works 1955 Workman Mill Road Whittier, California 90601 Re: April 28. 1997 Response to Mud Tank Release Dear Mr. Sanchez: In response to your site visit on April 29, 1997 concerning the release from the number one mud tank on April 28, 1997 at the GNB Vernon facility, the following information is being supplied to you: 207003.1 1. The release was discovered on Apri128, 1997 at approximately 3:30 in the afternoon. 2. The material released was lead oxide paste that was undergoing desulfurization by the addition of soda ash. 3. The quantity of the release to the storm channel was estimated to be approximately 20 gallons. The extent of the spill outside the containment structure is hard to determine as response activities began in the contained area immediately after the release. GNS Technologies Recycling Division PO. Box 23957 2700 South Indiana Street Los Angeles, CA 90023-0957 U. S. A. Telephone: 1.213.262.1101 Facsimile: 1.213.261.3584 Mr. David Sanchez May 27,1997 Page 2 4. The cause of the releases from the mud tank is still under investigation. The release to the storm channel is believed to be caused by trucks splashing the material into the channel when driving in to unload spent batteries. Another possible cause of the release to the channel is when cleanup of the area began, a hose was used to wash down the area and a scrubber truck was used to collect the liquid and mud. 5. The liquid recovered from the scrubber was pumped back into the mud tanks for treatment. The gravel and sand collected from the stormwater trench was collected into hoppers. Any liquid from the cleanup was also collected in the hoppers and was absorbed by the silica sand. 6. To prevent any further releases to the stormwater channel, the raising of the existing six inch berm to approximately three feet is being considered. The enclosing of mud tank area from the base to the top of the tanks is being developed. The release is still being investigated and, once the cause is known, measures will be taken to prevent any future releases. 7. The gravel from the storm channel was stockpiled and will be properly managed. Three samples were taken for verification of cleanup. The samples were taken in clean zones outside the release area. The samples were taken on May 5, 1997 and were witnessed by Leonard Grossberg, Environmental Health Specialist for the City of Vernon. Upon receiving the analytical results they will be forwarded to your department. Follow-up Site Visit On April 30, 1997 Hector Aguirre, L.A. County Department of Public Works visited the site for final inspection. He said the cleanup was satisfactory, gave us a key for the fence lock for any future incidents and gave us a list of DPW approved emergency responders. 207003.1 Mr. David Sanchez May 27, 1997 Page 3 If you should have any further questions or comments, I can be contacted at (213) 262-1101, extension 259. Sincerely, Environmental Manager cc: 207003.1 Dave Wesley Thomas McHenry Leonard Grossberg, City of Vernon Roland Romain, L.A. County Dept. of Public Works Gary Wiskus, City of Vernon Fire Department Ruth Morehead, DTSC Glendale ATTACHMENT 5 Date: March 1997 Revision No.: 4 Page No.: 5-18 TABLE 5.2 WASTE ANALYSIS SUMMARY Spent Battery "Acceptable" Plant Scrap Material Sulfuric acid (D002) Lead (DOOS) Arsenic (D004) Cadmium (D006) I Arsenic (D004) Cadmium (D006) Lead (D008) "Conditionally Acceptable" Plant Scrap Material Arsenic (D004) Cadmium (D006) Lead (D008) Not Applicable - will not I Non lead-acid batteries be placed in a land-based unit Not Applicable - will not be placed in a land-based unit Not Applicable - will not be placed in a land-based unit Not Applicable Visual Inspection Total Lead Total Mercury Total Aluminum Grab/composite Visna! Inspection; SW-846 Method 60 10 SW-846 Method 747017471 (for mercury) Total volatiles and semivolatiles - sweepings only Grab SW-846 Method 8240 and 8270 Total Lead Total Mercury Total Aluminum Composite Visual Inspection; SW-846 Method 60 10 SW-846 Method 747017471 (for mercury) Chlorinated bydrocarbons - sludges. dusts. and drosses only Grab SW-846 Method 8120 ~C!;w c4u/6 Polypropylene Lead (DOOS) Not Applicable - will not be placed in a land-based unit Total Lead Grab TV~ Blast Furnace Slag Lead (DOOS) Yes Total Lead Composite TCLP, STLC, TILC, SW-846 Method 6010 ~etention Lead (D008) Not Applicable - will not be placed in a land-based Total Lead Grab TCLP, STLC, TTLC, SW-846 Method 6010 Pond Sediment , I (}I.~ TCLP,STLC, TILC, SW-846 Method 6010 I ;1 Date: March 1997 Revision No.: 4 Page No.: 5-29 5.3.4.2 Blast Furnace Slag If GNB determines the slag may be defined as non-hazardous waste, it is sampled and analyzed for lead and other heavy metals listed in Table 5.4 to determine if the material meets the definition for a federal or California hazardous waste, If an analysis fails, then that material, when shipped, is manifested as a hazardous waste. However, if all analyses pass, then the next roll-off shipment may be shipped under a bill of lading as non-hazardous waste. Once the analyses determine that the slag is a non-hazardous waste, the material is sampled at the intervals specified in Table 5.5. 5.3.5 Sampling Procedures These sampling procedures provide the best means possible to obtain a representative sample of plant scrap raw material, polypropylene and Blast Furnace Slag wastes, and retention pond sediment. A representative sample is collected and handled in a manner that preserves its original physical form and composition, as well as prevents contamination or changes in concentration of the parameters to be analyzed. The sampling procedures are described below. Sample Collection Prior to sampling activities, the technician cleans and decontaminates all equipment. During the sampling process, the technician wears new, clean latex gloves, in addition to applicable personnel protective clothing and equipment outlined in the plant's health and safety plan. Conditionally Acceptable Plant Scrap \ A sample is collected from drums of CONDITIONAlLY ACCEPTABLE plant scrap to verify that the material is not a hazardous waste prior to the drum and its contents being processed into the Blast Furnace. The contents of the drum to be sampled are emptied onto the floor of the Blast Furnace Feed Room. The sampling technician collects one grab subsample of each type of material identified from the drum using a decontaminated, stainless steel trowel. The sub-samples are then placed in a Pyrex or stainless steel bowl and mixed to achieve maximum homogeneity. The composite sample is then transferred to appropriate sample containers. One sample per supplier is analyzed. Polypropylene To verify that the polypropylene chips do not meet the definition of a hazardous waste, the chips are sampled from each semi-trailer prior to shipment off-site. The process generating the polypropylene is relatively simple, and the resulting chips are a homogeneous material. Therefore, a single grab sample collected per trailer constitutes a representative sample. The sample is collected using a decontaminated, stainless steel trowel or small spade prior to being transferred to appropriate sample containers. Date: March 1997 Revision No.: 4 Page No.: 5-32 If the sample passes both the STLC and TTLC criteria, then the sampled material is classified as 'non-hazardous waste and is transported under a bill of lading via a licensed hauler to a permitted plastic reclamation facility for the polypropylene chips or a Class II Solid Waste (non-hazardous) landfill for Blast Furnace slag. Organic Analyses The samples of sweepings are sent off-site for analysis, The samples are analyzed for total volatile and semivolatile compounds (40 CFR Part 261, Appendix VIII) using SW-846 Methods 8240 and 8270, respectively. SW-846 Method 8120 is used for all chlorinated hydrocarbon analyses of sludges, dusts, and drosses. Hydrocarbon Vapor Analysis Each drum of sweepings is tested with a portable HNU Flame Ionization Hydrocarbon Detector. The instrument is calibrated against methane according to the Laboratory Analysis Procedures as developed by GNB's Quality Manager. The instrument is capable of detecting hydrocarbons at levels of 1 ppm in vapors. 5.3.7 Waste Analysis Parameters The waste analysis parameters are selected to provide sufficient information to ensure • Compliance with applicable regulatory requirements (e.g., LDR regulations, newly identified or listed hazardous waste) or waste identification • Conformance with permit conditions (Le., ensure that wastes accepted for management fall within the scope of the facility permit, and process performance standards can be met) or process and design considerations • Safe and effective waste management operations (Le., ensure that no wastes are accepted that are incompatible or inappropriate given the type of management practices used by the facility) or identification of incompatible/inappropriate wastes For the purposes of generating documentation for using acceptable knowledge, as allowed in the Guidance Manual, GNB runs an annual metals analysis on each type of ACCEPTABLE plant scrap material received from each battery and/or lead oxide manufacturer (sampling strategy is provided in Section 5.3.5). Based upon GNB's process knowledge concerning the generation of plant scrap from lead-acid battery manufacturing plants, the majority of the plant scrap does not have the potential to become contaminated with organics. However, one material, sweepings, is generated in a manner that allows for potential contamination. Therefore, the annual analyses also include a volatile and semi volatile analysis for sweepings. \ ,'\ , '\1 t---- {~J Date: March 1997 Revision No.: 4 Page No.: 5-34 BlF Regulations To comply with 22 CCR 266.IOO(c)(3)(D) and 66266.100(c)(3)(D), GNB is required to develop a waste analysis plan to show compliance with the following criteria: I) 2) 3) The waste contains recoverable levels of lead; The waste does not exhibit the TC of 22 CCR 261.24 for an organic constituent; and The waste is not a hazardous waste listed in Subpart D of part 261 because it is listed for an organic constituent as identifIed in Appendix VII of part 261. To determine that all waste contains a recoverable level of lead and meets the BIF requirement, a metals analysis is performed on all plant scrap. The analysis is run per the sampling strategy outlined in Section 5.3.6. Based upon GNB's process knowledge concerning the generation of plant scrap from lead-acid battery manufacturing plants, the majority of the plant scrap does not have the potential to become contaminated with organics. However, one type of material, sweepings, may be generated in a manner that allows for potential contamination. Therefore, the fingerprint analysis for sweepings also include the use of an HNU for hydrocarbon detection. 5.3.9 Incompatible/Inappropriate Waste Identification Incompatiblelinappropriate components that may contaminate the plant scrap received from off-site are mercury, aluminum, and organics. The Recycling Facility is not permitted to receive mercury toxicity characteristic wastes (D009) or the characteristic and/or listed wastes associated with organics and/or chlorinated hydrocarbons; the facility's air permit does not allow the emissions from the combustion of such compounds. Mercury and aluminum are considered incompatible with the process and are a potential hazard if inadvertently charged to the furnace. The acceptance/rejection procedures for materials contaminated with organics, chlorinated hydrocarbons, mercury, or aluminum are outlined in Section 5.3.3. 5.4 ANALYSIS PLAN UPDATE This waste analysis plan and other procedures associated with the receipt of off-site materials will be reviewed, and if necessary, updated whenever: I) Facility processes change in a way that might be threatened by currently defined indigenous battery plant scrap. 2) Materials included in the definition of acceptable indigenous battery plant scrap change in a way which threatens facility personnel, equipment or the environment. 3) Unacceptable materials are found to result in any sort of operational failure. \. ATTACHMENT 6 GNB TECHNOLOGIES INV. IN BINS INVENTORY 0F BATTERY GROSS Apr?97 GROSS WT. 101 102 103 104 105 107 103 SKIDS GROSS TRAILERS . 9.2 52-53 953;le 57% 00b ?ame Q5: 0 Ed? quir?rd$ f5 ifs/42 9g: if 500 ix; mm mg, 56?s) 773? {1 ?x?nfz 7 I 5% Jay .35 2/74, Am) Riga?) if Mr: is; 33:25:? 55:3 ?135" $54,002). [4&3 5 31: MA 2441mm 341?. [(13050 X?g?ad (EH, (3123; ?7?3Lem fe?g 2512mm 7% {?675 6.64490 our?! [(53 000 #9812995) (I: .3978? 555 if :5 7% we $434 if mg ELMO 7393? 22m sz? /5 dam: bob I??ii mm Z) 354: 4,94% $22 7 3,3 .0083. 1102'. 0&6 353?; M5: 735 5/5 51'? gig?) (A: @5383 25322053 Mg. Ma 57457 .135 5507300 5m 52:; .5955 352.. Md: #7325669 if?! 1 .. 25 Koolq 011:) 0250 A4 002) om 006 929% ?aw/?97 {725, Mb [mix (960 ?53. ?206 (320 .35? ?5 11 4906, m5 230.550 1% cat) 52;? we #93. {33% ?w ?0.53 7?3 (5&5 2; {a 23?: 53% as.an .414. 50:) 3.5% 357) g? 5553:?; 7534 9/35 79% M3 ?25; @051 was 200g 8; 4932} ?450 53/ ?ggam baggy: A12 mt: 3?95? EU. 372/ [05 352 Job 703:4m3 239 ?73? 7?/?wo 4&5, ma ffL??i: M31 33* 913'? amt.) if; 7 5. 4/ 5?7? L5 2/697 . {04/ 0A6 MM 14m; $05 .252 6436 mm Ma i? 9?43?, 3'3: ?0 32314325 3493f m2) 4% mg 25:2. (9321 M27, M5: (3095 ma .772 26? ??gaa f. 5% {5%.5551 ESEMKL D?W?nm an I) I) gig" Mi? ~ INVENTORY OF BATTERY GROSS WEIGHT GNB TECHNOLOGIES Feb-97 INV.IN BIIYS [DATE I 213197 1214197 1-215197 1276197 r 217197 2110197 21'17197 ! 21'18197 ~2124197 I 2125197 r- I;) /;{(,/" 7 ~/~'7/~ 101 144,,000 144,000 0 0 0 0 0 0 0 0 74,1000 37 8,000 4 () 0 154"O()O 154,000 468,000 392,000 <{£Ox. {)06:3'il.. 000 GROSSVIIT. At,,, 102 0 0 0 0 0 0 0 0 0 0 0 103 104 0 0 t---O--t-- 0 0 0 0 0 0 0 0 0 0 0 0 0 -- 0 0 71i,000 0 74..000. 0 71.. M~ 0 ~9d_b6lJ () .qt"'l'.bob3Sj?,il6o I :::/,3/97 1<'5.s~ ~()O D D 0 D n 7: 0 0 ! () Q i"J / 0 l D /) i; () i SKIDS 72 0 0 0 0 37 4 0 77 234 -2.3'1' .:23«' 19<{ ~£l 'j <'/{' .:2<12) ] '7/777g,;:; iS7"% &78" 1'6 ') //9'<{7 7' 17'7?.2() 12"5, 5103 1/5.0.. 7_~ IS'?", '5(3' =::::c; I -<.; I I , -S :;i '-I- -4 /3:>.. /f0 ~ 1/ f'l.. 't'" .i:o I DAILY YARD FUGITIVE INSPECTION REPORT Inspector 1<0 b~Vit Ts~ l.West Yard If/( Time!"2:: -)0 Date {J,t;, 2. SouthWest Monitor Area 0,1;. 3. Trailer Wash Area (2 4. Balloon Flue Area 5. "A" Pipes J:::- oJ::, {),!<2, 6. Baghouse Area O.t, 7. Feed Room Aisleway (JIG 8. North Yard 9. Wastewater Treatment Area 10. South East Monitor Area 11. Others 12. Air Flow Monitors 13. Triblowflows 4/;! If. 7 !J.f;. 't) \/:::' (5J, /::. .-.; c~! " .~ .. DAILY YARD FUGITIVE INSPECTION REPORT Inspector~ ~~ r$"~ . Time"] ::O\l&f#lDate 4A0/97 V'\ft} l.West Yard 2. South West Monitor Area 3. Trailer Wash Area O.,K, 4. Balloon Flue Area 5. "A" Pipes 6. Baghouse Area ·· C "D}f*~ . <:'-" '. 7. Feed Room Aisleway 8. North Yard 9. Wastewater Treatment Area 0,1:, 10. South East Monitor Area 0,1< . 11. Others 12. Air Flow Monitors 13. Triblowflows -+-[ , ( Signature: (\) I Inspector: 3--D \f?~V ~ [h..--.. D..q7 Reviewer~:.:=p...-'-I--"f_/~(_ _ _ _ _~ DAILY YARD FUGITIVE INSPECTION REPORT Inspector b~b.Qvt ]5'0(;\ Timel-'~oA~ate 4&/77 I West Yard 2. South West Monitor Area o·K:. 3. Trailer Wash Area 4. Balloon Flue Area 5. "A" Pipes 0 . Ie:: . 6. Baghouse Area D~vi: $ 7. Feed Room AisIeway ..L. 8. North Yard D\'f~~ C .JI(YY~ a..vou'rtJ. 9. Wastewater Treatment Area 0 ' b, L.) C!jv -j--lt/-f; ~J OX(djjjOVl 7\.q(,1P, . 10. South East Monitor Area 1l. Others 12. Air Flow Monitors 13. TribIowf1ows o \ lc . Signature: ¢\;:::::=-._",In"'IsIl>e",ct""o,,-,r:--'l:=-L.:.:.JI-~I-~~.Reviewet.;,·~1lit,&4==l--/!.~::::S~----2>~ . DAILY YARD FUGITIVE INSPECTION REPORT Inspector 1:o\pvK: 1s-~ I.West Yard -1 ~ 0" fl1 Dat4/t; (? 7 Time D'G- 2. South West Monitor Area 3. Trailer Wash Area 4. Balloon Flue Area 5. "A'" Pipes 6. Baghouse Area .. .;: " 7. Feed Room Aisleway 8. North Yard ", 9. Wastewater Treatment Area 10. South East Monitor Area 11. Others 12. Air Flow Monitors 13. Triblowflows 14. Wind monitors D . t:2 . [DAILY AND WEEKLY INSPCTION FORM . I -j. DAIL Y INSPECTION 47t/q'1 ;;7/~ \ (Or1 Date o .\;to . RMPS. Tanks Y7~/11 if,4 /q-l Ae ;of TMI \<:.. <.{.,.".A:;.,+H ,..,/A l <.,....+,41"""",",, .f.: V<-' 4./\ w.> '11'-L~; /; 1,1 i>I~ fileJ,. ",+-~' I"'fL-QA' OTSC (3/951 ,).L(.(J (;t,& ii /0",,107, /0'< -y,h sre J, '<1)1 h-i- /{'W ~ , S, \~h,...f,JkA- I. . !.Alft/V L .&-/v<'- ?if /4< -J#.< f.a.lk.." <:S:i i- lAJI",e) • Page P-9 • _" -, ••••• ~........-- _T _ _ _ ' __ _ - of - State of , , CaIH~mill ~ Californlll Environment.' Protection Agency ·1 Oepartment of Toxic Substancos Control SUMMARY OF VIOLATIONS SECTION II: OTHER VIOLA TlONS 0 OR MINOR VIOLA TlONS CORRECTED DURING INSPECTION rn""- (CHECK APPROPRIATE BOX) List of violations and compliance actions not included in Section I: Minor ViolationslNotice to Comply OTSC 13/95) 1'-9 Page_of_ Cal/EPA June 6, 1997 Pete Wilson Governor Department oj Toxic Substances Control 1011 N. Grandview Avenue Glendale, CA 91201 CERTIFIED MAIL Mr. James Marzo1ino Environmental Engineer GNB Technologies 2700 South Indiana Avenue Vernon, CA 90023 Dear Mr. Marzolino: On April 30, May 1, and May 2, 1997, the California Environmental Protection Agency, Department of Toxic Substances Control (DTSC), conducted an inspection of GNB Technologies, located at 2700 South Indiana Avenue, Vernon, California. The enclosed report describes the findings of this inspection. The following violations which are described in this inspection report, were found subsequent to the inspection. 1. Title 22, California Code of Regulations, section 66265.193 (c) (4) GNB Technologies failed to drain and remove liquids resulting from leaks , spills or precipitation from their secondary containment system, within 24 hours, or in as timely a manner as possible to prevent harm to human health or the environment. 2. Title 22, California Code of Regulations, section 66265.193 GNB failed to meet minimum requirements for secondary containment in that the upper liner in the secondary containment system has cracks. James M. Strock Secretary jar Environmental Protection Mr. James Marzolino June 6, 1997 Page 2 You are required by section 25185(c) (3) of the Health and Safety Code to submit a written response to the Department within ~ days describing the corrective actions that you have taken or propose to take to bring your facility into compliance. If you dispute any of the violations, you should explain your disagreement in this written response. All pertinent information derived from the inspection, including documents, and photographs are included as attachments to the report. This report will become a public document; you may request that any trade secret or facility security information be withheld from public disclosure. If you have any questions regarding this letter, or if you wish to meet with the Department to discuss any questions or concerns you have with the inspection, the report, the violations, or the proposed corrective action, please call Ruth Williams-Morehead at (818) 551-2916. cikJ~v~/-"~ &fb jcrrMUKUI Agarwal supervising Hazardous Substances Scientist statewide Compliance Division Enclosures certified Mail Z 066 443 736 Return Receipt Requested SUMMARY OF VIOLATIONS On April 30, May 1, and May 2, 1997, the Department of Toxic Substances Control, California Environmental Protection Agency, conducted an inspection at: facility name: GNB Technologies facility address: 2700 South Indiana Avenue Vernon, California 90023 EPA ID Number: CAD097854541 county name: Los Angeles As a result of that inspection, the violations of hazardous waste laws, regulations, and requirements listed on the attached pages were discovered. All violations must be corrected; the actions you must take to correct the violations are listed with each violation. If you disagree with any of the violations or proposed corrective actions listed in this summary of Violations, you should inform the Department. If you disagree with any of the violations listed in Section I, you must give the inspector who issued this Summary of Violations a written notice of disagreement. You must correct the violations listed in section I, Minor Violations, within 60 days. Within five working days of achieving compliance, you must sign the statement certifying compliance at the bottom of section I and return it DTSC at the address provided by. A false statement that compliance has been achieved is a violation of the law and punishable by a fine of not less than $2,000 or more than $25,000 for each violation. The Department may reinspect this facility at any time. The Department will provide you a complete inspection report within 65 days of the date of this inspection. You may request a meeting with the Department to discuss the inspection or the findings of the report. The issuance of this Summary of Violations does not preclude the Department from taking administrative, civil, or criminal action as a result of the violations noted in the Summary of Violations or that have not been corrected wi thin the time provided in section I. Authorized company Representative* Authorized State Agent Name Violations cited after Name Ruth A.Williams-Morehead Title the inspection. Title Haz. Sub. Scientist Signature Signature SUMMARY OF VIOLATIONS Facility Name: GNB Technologies, Inc. Date: April 30, May 1 and May 2, 1997 section II: OTHER VIOLATIONS OR MINOR VIOLATIONS CORRECTED DURING INSPECTION (CHECK APPROPRIATE HEADING) List of violations and compliance actions not included in section I, Minor Violations/Notice to Comply Class I Violations: Title 22, California Code of Regulations, section 66265.193 (c) (4) GNB failed to drain and remove liquids resulting from leaks spills or precipitation from their secondary containment system, within 24 hours, or in as timely a manner as possible to prevent harm to human health or the environment. Title 22, California Code of Regulations, section 66265.193 (e) (1) (c) GNB failed to meet minimum requirements for secondary containment in that the upper liner in the secondary containment system has cracks. INSPECTION REPORT I. GENERAL INFORMATION company Name: GNB Facility Address: 2700 South Indiana Avenue, Vernon, Ca. Telephone Number: (213) 262-1101 EPA ID Number: CAD 097 854 541 RCRA ISD Hazardous Waste Treatment Facility. Facility Type: facility 90023 is currently be evaluated by the The Facility Permitting Branch for issuance of a Hazardous Waste Permit. Regulated units: for The facility is currently operating under an ISD their wastewater retention pond, lead smelter, wastewater treatment unit and four spent lead-acid battery and lead waste storage areas. waste Streams: plastic case Polypropylene materials, waste, furnace wastewater, slag, filter rubber sludge, and lead contaminated wipes and rags. Inspected by: Ruth Williams-Morehead, HSS - 4/30/97, 5/1-2/97 Dave stuck, HSS - 5/1/97 Date of Inspection: April 30 - May 2, 1997 Type of Inspection: CEI XX o . CME. O&M. Focused XX Limited. Transporter Facility Rep.: James Marzolino, Environmental Engineer GNB is a secondary lead smelter which produces Type of Business: pure lead and lead alloy form mainly lead acid batteries and other lead bearing wast~. The lead is subsequently sold as a product. II.CONSENT consent to photographs, personnel conduct reviewing and inspection and inspecting Yes/No that copying hazardous involves: records, waste taking questioning handl ing areas. Yes. Consent given by (name and title): James Marzolino, Environmental Engineer tII.DOCUMENTS REVIEWED (circle all reviewed) I and David stuck reviewed the following records and the following violations were found: a. Manifests, Bills of Lading, LOR's, Exception Reports: The facility did not keep copies of LDR notices that are attached to the manifest when shipping wastestreams for disposal (attachment 1). off LDR Although the facility does not keep copies of the LDR notification, Mr. MarzoliI:l0? provided me with a blank copy of the notification which is used during shipment (attachment 2). b. Contingency Plan The contingency plan does not list the addresses of the emergency coordinators (attachment 3). Also copies of the contingency plan have not been provided to all local police and fire departments, hospitals, state and local emergency response teams, etc. that may be called to provide emergency services. c. Training Plan and Records: No violations were found. d. Incident Report: Mr. Marzolino explained that on Monday 4/28 a mud tank overflowed in the storm channel (Attachment 4). The mud tank contains lead oxide used a blast feed for the furnace. Mr. Marzolino stated that initially the spill was contained on the site. truck (s) drove through He stated that a delivery the spill which caused splash over the retaining wall. it to Mr. Marzolino assumes that during the initial clean-up the pressure from the water hose the spill to over the containment berm. Mr. Marzolino stated that he notified OES, the city of Vernon Health and Safety and the Fire Department. Mr. Marzolino stated that the fire department sent a response team, and the City of Vernon notified the Los Angeles County Flood Control. The Los Angeles county Flood Control sent two inspectors, Roland Romaine and Daryl Taylor. Mr. Marzolino stated that storm drain will be sampled and witnessed by the City of Vernon and that he will submit a copy results to DTSC. e. waste Analysis Plan and Records: The waste parameters analysis plan does not for which waste will be describe analyzed for the the "acceptable plant scrap metal" and the sampling method used for" acceptable plant scrap metal "would not provide a representative sample of the waste to be analyzed (attachment 5). I spoke with Jeff Pierce of Lake Engineering, Inc., who is involved analysis plan. the acceptable in preparing the facility's waste Mr. Pierce explained to me that because plant scrap material is composed of several metallic lead plates, lead sludge and lead dross. In order to get a composite sample of each layer the plant scrap is placed on the floor lined with plastic. The scrap is inspected and a composite is taken based on what is in the drum. f. operation Log: The facility has an inadequate operating log (attachment 6). The current operating log is an inventory of the number of pallets in each battery storage area, but does not describe the date the batteries are received, the methods of its treatment , storage or disposal and does not cross reference any of the information to a hazardous waste manifest. q. Inspection Records The facility's inspection records were inadequate. It did not equipment, include inspections of monitoring, security devices, safety operating and structural equipment and does not identify problems to be looked for during the inspection (attachment 7) o Mr. Marzolino stated that GNB is currently modifying its inspection schedule and logs and gave me draft copies (attachment 8) o h. Tiered Permitting Applications and Authorization Letters: N/A i. Annual/Biennial Reports: No violations were found. j. BB 14 Plans: The facility has an adequate waste minimization plan. k. Closure Cost Estimates and Updates: Facility permitting is currently and post-closure cost (attachment 9). revising closure 1. Part A: An application was filed in 1981 by Gould , Inc. former owner of GNB. Subsequent to RSR Corporation purchasing GNB a facilit~ revised Part A has been filed and the is currently operating under interim status. m. Part B: Part B is currently under review by Jamshid Ghazanshahi. n. POTW Compliance Data: The facility has a permit (11092R-l) to discharge in the Los Angeles County Sanitation District. o. Tank and/or containment certifications: Mr. Marzolino stated that under an Supplemental Environmenta?l Program negotiated as a result an Enforcement case several years certification program. ago, GNB will be implementing tank Mr. Marzolino said that this program was to begin this year but due to several delays in other segments of the supplemental Environmental Program, the tank certification program may be postponed. p. Air Board Permits The facility has numerous air permits for their smelting and processes. q. variances: Not currently operating under a variance. r. Recycling Records: N/A s. Other N/A IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR On April 30, 1997 at approximately 2:30 p.m. I began my inspection at GNB Technologies. I met with Mr. Jim Marzolino, Environmental Engineer. I explained to him the purpose of my visit was to conduct a Compliance Evaluation to determine compliance with hazardous waste regulations and statutes. Mr. Marzolino stated that he understood the purpose of my visit and gave me, Ruth Williams-Morehead, permission to inspect the facility. We began our discussion with the background of the facility. Mr. Marzolino explained treatment and storage facility. that GNB is a GNB stores lead-acid batteries and lead bearing materials which is used as raw feed in the facility's lead to produce elemental lead. Mr. Marzolino explained that lead batteries and lead bearing materials are received from off-site. The batteries and lead bearing material are either placed in one of three storage areas are immediately placed into the reverber'ator furnace. can be smel ted, they However before the batteries are crushed. The components resul ting from crushing the battery which consist of post, plates, paste mud and polyethylene casings are conveyed to a clarifier. The sulfuric acid is collected in the a tank and used in the process. The polyethylene is washed, placed in a trailer and eventually sent offsite as hazardous waste. The post and plates are placed in the reverberatory feed room prior to being fed into the reverberatory furnace. The paste mud, after being desulfurized, as well as filter cake generated from the wastewater treatment unit and desulfurization unit are also fed into the reverberator furnace. Lead dross and lead slag are produced in the reverberatory furnace. The lead dross and lead slag are placed into the blast furnace. The blast furnace generates a second slag which is sent to Kettlemen Hills for disposal. The dirty hard lead generated from the blast furnace is sent to refining. Mr. Marzolino also explained that GNB will be closing battery storage areas 101 and 102 to further expand the reverberatory feed room. Mr. Marzolino also stated that.GNB will possibly redesign the stormwater pond. Mr. Marzolino stated that currently the stormwater pond is being used as a secondary containment system to collect runoff generated from rain and on-site activities. He stated that the upper liner of the pond is torn and may be leaking between the upper and lower liners. He stated that currently the inlet pipe to the storm water pond is being blocked with a bladder blown up with air to seal off the opening to the pond and the water is being directed to the wastewater treatment unit. I ended the inspection at this time and continued the next day, May 1, 1997. On May 1, 1997, I and Dave stuck resume the inspection. I again received permission from Mr. Marzolino to conduct the inspection and we began the record review (see section III). After the record review we had lunch and resumed the inspection and began the walk-through of the following areas: Surfaoe Impoundments As mentioned earlier the closed. However surface impoundment during the walk-through I is observed puddles of water in the surface impoundment and tears were noted in the upper liner (photos 1, 2 and 3). Presently the surface impoundment is not being used and wastewater generated at the facility is being routed to the wastewater treatment pond. Next to the surface impoundment was three 20, 000 gallon portable tanks. I asked Mr. Marzolino what the tanks contained and he stated water removed from the surface impoundment. He said that the wastewater had been sampled, and the results are pending, dispose of the wastewater properly. in order to I observed that the tanks were not marked with hazardous waste labels or accumulation finding. dates and informed Mr. Marzolino of my He stated that he would label the tanks before the end of the day. PAC Center PAC Center is where incoming batteries which are returned to GNB from the manufactures are sorted to determine if they will be placed in the smelter or sold as a secondary battery (photo 4). Mr. Marzolino stated that a battery is sold as a second if it can be recharged and if the battery is still under warranty. At the PAC Center sixteen pallets of batteries were not labelled with the date received (photo 5). However at the end of the facility walk-through we revisited PAC and I observed that each pallet was dated (photo 6) .. Battery storage Areas Area 7 (104 and lOS) I observed that the facility was storing broken batteries in seven open drums (Photo 7). I told Mr. Marzolino broken batteries needed to be stored in closed drums. Mr. Marzolino said that usually broken batteries are placed into the battery crusher but labeled. ~hen they are placed into storage they are usually Also I observed that a drum containing casings from spent ammunition was not labeled I explained to Mr. Marzolino that this was a lead bearing waste and need to be marked with a hazardous waste label and accumulation date, and not only the date the ammunition was received. Area 16 (101 and 102) Batteries and lead bearing material are not being stored in this area. As mentioned earlier the facility is expanding the reverberator feed room into this area. Area 14 (103) No violations were noticed during the inspection in this area. Area 6 (106, 107, and 108) No violations were noticed during the inspection in this area. We concluded the inspection at this time. Mr. Marzolino had to leave early and requested that I conduct the exit interview the following day. VI. CONCLUSIONS: On May 2, 1997, I conducted the exit interview with Mr. Marzolino. We discussed the Summary of Violation (attachment 10), and schedule for compliance. Hazardous Substances Scientist Date ATTACHMENT 1 ::;;~i" uf (Co: '.:"']jo--~.".'''onmer1la: hole(IIOIl Agcllc.y Form Approved OMB No. 20S()....{1039 (Expire, 9?3()"96) Please prill! or type. See Instructions on back ot page 6. [)epo-tmen! of 1"" SlJb,to,,",,", l(. Socromento', Coli/ernlo Form designed for use en ""ite (12'Pitch) typewriter. Document No. 2. Page 1 Information areo~ not required by Federal law, j~ GNO TECHNOLOGI 2700 S. HWIAN LO''> ANGrU:S 4, Generator'l Phone ( CA 21:1 5, Transporter ENVIRO!fHENTAL 7, Transporter Company Name CHEMICAL ilASTE IIANAG8I'!E!!T 35251 OLDSKYLINE ROAD KETTLE/IA!{ CITY. CA. 93239 11. US DOT Description (including Prap&r Shipping Name, Hazard Class, and JD Number) G E N E R A T " o R w V'J Z ...0 V'J w '" g ~ << z << z w :I: I~ ~ 16. GENERATOR'S CERTIFICATION: I hereby declore that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, pocked, marked, ond labeled, and are in all resped$ in proper conditian for transport by highway according to applicable international and national government regulations. << u ~. If I am a large quantify generator, I certify that f have a program in place to reduce the yolume and to}(icity of waste generated to the degree I hove determined to be economically procticable and that I have selected the practicable method of treatment, storage, or disposal currently ovailable to me which minimizes the present and future threat to humon health and the envIronment; OR, if I om a small generator, I have made a good faith effort to minimize my waste generetion and select the best iI I Printed/Typed Nome ~ c:: V'J '" 0 >U Z w t:l ;/ - Printed/Typed Name J, '" ::; w I w u. '-. . j .. ___ . Printed/Typed Name 0 w 19. Discreponcy Indication Space V'J << U ~ F A C I L I T ,i Day Printed/Typed Nome Y DO NOT WRITE BELOW THIS UNE. DTse 8022A (1/9.5) EPA 87~22 V,IIow, GENERATOR R8AIJ. PlA.NT , 76336 TRANSFER / / DATE ----------- '7//-:>/ (_) .. j_) /)" C' ('J ' . {. 19 l'bV;;;(/ ')/ LOt!;-' g-.:J) .t ((. f:. j i:'; -;1 , ....> 74200 1 b !~,i~' ~n940 It Ti-! 422t,1) 1b f'~1 <2 '1 MATERIAL WEIO:;HED " .) - ,.r~/ MERCHANDISE DELIVERED TO ( t: / ( -t. ,-;' ,./ WEIGHED BY PLANT COPY \ \ " .. ': \ \ " METALS DIVISION RECEIVED BY _ _ _ _ _ _ _ _""---;,_ _ _ _ _ _ _ _ _ _ __ ,9(1 'V f.J' 7' J REMARK., I; ~ iL ! 'Vi &. . JU?l t~-... ,7 (OR ACCOUNT OF) '.""/ n.! LOS ANGELES. CALIFORNIA r:J......../;. WEIGHED FOR -"j" G N- B,INCORPORATED /") (--., ;/).Z_, .-:. )1, ,~.,-. \ \ "~/ f?-'??, l"* . />." .----- .J SI'" qI Cah~nio--EnvirOrlmentol Prole No 2050-0039 (E)'p:re~ 9-30-96) Please prin1 or type. Form deligned lor use on elile (12-pitch) t'j-'ewriter. .,:.u~lfa~M HAZARDOUS WASTE MANIFEST .. Name .'ge 6. 1. Generator's US EPA ID No. D,,;,"Jrl - 2. Page 1 ,-", Sw"~, ,", So,romenla. ColjJo'ruo Information in the areas is not required by federal law. of Mailing Address 0 '"'"':- N 4. '" ~"1 GNB BATTERY TECHNOLOGIES 2700 S. ST. LOS ANGELES, CALIF. 90023 Generator's Phone ( ~ ~ ~ 'f"'ti'5 0 9. Facility Name and Site Address U') I.l) 0') KINSBURSKY BROTHERS 1311> N. LEMON ST. ~ 11. US DOT D&5cription (including Proper Shipping Nome, Hazard Class, and 10 Number) (,O?; j')1: a. ~ <'0< BATTElu , I I ;;~ .. " ~ Z w C> w '" ~ u.. 0 w II) < u ?; , 19. D1s.crepaney Indication Space o C I l I ; I T Moootlo Y Day v.," DO NOT WRITE BELOW THIS UNE. DTSC 8022 ... (1,'9') EPA 8700-22 Yellow: GENERATOR RETAINS "n...... ? , 01 l.clllC'l'nrtl--trtVlronmentol Prot&ction AGency Fo~rr_ Appro\led OMB No. 20.50-0039 (Expires 9-30-96) Pleuse print or type Form designed for Vle on elile (12"p".n) fypewriler. i See Instructions on bee i page 6. Depof1ment of Tox" SubltonCe\ Socromento. Colofornia 1, Generator's US EPA JD No. j No.2. area' is nol required by ~erat low. 9, Designated Facility Name and Site Addreu u..S. ECOLOGY HWY 95, 10 MILES SOUTH BEATTY NEVADA 89003 n.o .. 8? t Dua vastE', ), (0008) 15. Special I ENVIRONMENTAL RECOY?J?Y SERY1CES 16. GENERATOR'S CERTIFICA liON: I hereby declare that the contents of this consignment ore fully ond accurately described above by proper shipping nome and ore classified, pocked, marked, al'ld labeled, Clnd are in all re~pects in proper condition for transport by highway according to applkable international and notional government regulations. If I am a Jarge quantity generator, I certify thot I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage. or disposal currently available to me which minimizes the present and flJlvre threat to human health end the environment; OR, if I am a small generator, I have made a good faith effort to minimize my waste generation and select the best I I F A C I L I T Y DO NOT WRITE BElOW THIS LINE. ;OT:SC 8022A (l/9!5) IfPA 8700-22 ,. Y.UoW: GENERATOR RETAINS Stole of Calilo"lio-Environmental Protection Agency Form OMB No. 2050-0039 (Expire\ 9?30-96) Form desi(}ned lor use on elife (!21'ilc~) fypewriter. . 'uNIFORM HAZARDOUS WASTE MANIFEST See Instructions on back of ~age 6. Deportment o[ T01l( ;,ubltOrlCel Cont" Sacramento, Coli/o'N" 1. Generator's US EPA 10 No. No. 2. PClQe 1 in tne a...as is not required by Federal law. 3. GN}) BATTERY TECHNOLOGIES 2700 S. INDIANA ST. LOS ANGELES, CALIF. 90023 Go..,.",,', Phone (2131 2 6 Z-11 a1 o. 1 Company WILEY 7. Transporter ~. SANDERS Name 11;61 Sm--[nvHoIHner,:al Protection Agency Form Approved OMB No. 2050-0039 (Expires 9?30-96) PIII'CI-e Form dtlli~ned See Instructions on back of page 6. for vse on elite Deporlmen' "I ~O~I( 5ublloncel Sacramento, California ; is not required by areas I law. m;g BATTERY TECl:lNOLOGmS 27uO s. "'. Generator', PhOfMl ( INDI~iA ST. LOS ANGELES, CALIF. 90023 6. US EPA 5. Transporter 1 Company Name WILEY SANVhRS .... .... X)6 ::t .::> :\I ", 0 C) 11. n o. RECYCLAbLE HAZAl\J)OUS WASTE, SOLID, S '" ..J : oj " " ''9" 0 - IX G f N E R A T 0 R N.O.S. CLAS~ 9, NA 3077, I'G ill b. <. zI!:! tl d. III 5"V) w IX .... < z Q I< Z 16, GENERATOR'S CERTIFICATION: I hereby dedore that the contents of this consignment are fully and accurately de~ribed above by proper shipping name and are douified, packed, marked, and labeled, and are in all resped5. in proper condition for tran$port by highway according to applicable internotional and national government regulations. If I am a large quantity generator, I certify that economically practicable and that I have selected threat to hum on health and the environment; OR, waste that is iI to me Printed/Typed Name IX 0 I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be the practicable method of treatment,' storage, or disposal currently available to me which minimize! the present and future if I am a small quantity generator, I ho~ made a good faith effort to minimize my waste generation and select the best and that I affard. 't.- ti zw C-' '"w :l: ...0w Printed/Typed Name W V) < U ~ o A. C I L , T Signotvre Y DO NOT WRITE BELOW THIS UNE. DTSC B022A (119-") EPA 87~22 Yellow: GENERATOR. ~ET AINS Co~'? ATTACI-DENT 2 C,alifornja Land Disposal Restriction Notice and Certification IManlf8$l Number Generator Name California hazardous waste Code(s) This Form Is submitted to,_ _ _ _ _ _ _ln accordance with the requirements of CCR Title 22, Chapter 30, Article 40 which restrlctl the land disposal of certain hazardous wastes. I have marked the appropriate box (boxes A, through D.) below to Indicate how my waste must be managed to conform to the land disposal restrictions. A copy of all applicable treatment standards and waste analysis data, where available, Is maintained at the GNB Battery Technologies lacllity Identified on the manifest referenced above. "the waste Is not a RCRA regulated hazardous waste, I have also entered the appropriate California Waste Code and checked the appropriate box in the' table below to Indicate the applicable non-RCRA hazardous waste listing from 22 CCR Section 6n02 I Line Check item Here Restricted waste Description Reference CCR ntis 22 Metal-containing aqueous waste that contains any of the metals or metal compounds Identified In 22 CCR m02(bXl) 66699(b). Wastes containing polychlorinatecfblphenyts (PCBs). m02(bX2) [reserved] [reserved[ [reserved] [reserved[ Metal-containing solid waste that contains any of the metals or metal compounds identified in 22 CCR 67702(b){7) 66699(b). [reserved] [reserved] Aqueous and liquid organiC waste that. contain any organic compound measured by EPA Test Methods 8080, 67702(bXl0) 8140,8150,8240, and 8270 described in Test methods lor Evaluating Solid wasles, PhysicalJ Chemical Third Edition. Methods, SW-846, Solid hazardous wastes that contain any organic compound measured by EPA Test Methods 8080, 6n02(bX11) 8140,8150, 8240, and 8270 described in Test me/hods lor Evaluating Solid wastes, PhysicalJ Chemical Third Edlt"'n. Methods, SW-846, 1 2 3 4 5 6 7 8 9 10 , I Complete This table For Non-RCRA, California Regulated Hazardous wastes Only ,, EJ A. RESTRICTED WASTE REQUIRES TREATMENT I am the generator olthe waste identified above which must be treated to meet the applicable treatment standards set forth in CCR Title 22, Chapter 30, Article 41 prior to land disposal. i : B.l IY RESTRICTED WASTE TREATED TO PERFORMANCE STANDARJS I certify under penalty of law that I have personally examined and am familiar WI.'" the trea,/men! technology and operation ofthe tteatmen! process usee' /0 support this certification and that, based upon my inqu'T cl f,'?cse individuals imme:ha!&o/y respo:-:s"ble for obtaining this information, I believe that the treatment process has been opera:2: ana' maintained property $0 as to comply wilh the performance levels sprxilied in CCR Title 22, Chapter 3D, Article 41 withe,: dilution of the prohibited waste. I am aware that there are significant penalties for submitting a fa/se certification, Including the p:-ssibllf1y of a fine and Imprisonment.' i 1 C. RESTRICTED WASTE SUBJECT TO A VARIAt\CE The waste identified above is subject to a capacity variance which expires on CJ D. RESTRICTED WASTE CAN BE LAND DISPOSED WITHOUT FURTHER TREATMENT 'I certily under penalty 01 law thai I have personally examined and am familiar wilh the waste through analysis and testing or through knowledge 01 the waste to support Ihis certification thai the waste complies wilh the treatment standards sprxified in CCR Title 22, Chapler 3D, Article 41 withoul dilution of the prohibited wasre. I am aware thai there are significant penalties lor submitting a lalse certification, including the possibility 01 a fine and imprisonment. ' It hereby certily that all in/ormation submitted in this and all associated documents Is complete and accurate to the best 01 my knowledge and information. : Signature .ITitte IDate K. W. PLASTICS CO. LAND DISPOSAL RESTRICTIONS CERTIFICATION Attach to Hazardous Waste Manifest Number,-:_ _ _ _ _ _ _ _-' I certifY that the material(s) described on the attached Hazardous Waste Manifest are sent to K.W. Plastics, Bakersfield, California for RECYCLE ONLY. Should this material be disposed of in any other manner, it is subject to the following treatment standard as prescribed under CCR 66268 and 40 CFR 268 (check all that apply): I have checked the appropriate box in the following treatment standard as prescribed under CCR 66268 and 40 CFR 268: o D002 Corrosive Characteristic Waste o D004 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for arseruc. o DOOS Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for barium. o D006 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for cadmium. o DOO? Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for chromium. o DOD8 Waste that exhibit, or are expected to exhibit, the characteristic of toxicity for lead. The plastic materials of spend lead acid batteries. o D009 Nonwastewaters that exhibit, or are expected to exhibit, the characteristic of toxicity for mercury. Signature Name and Title Date ATTACH-DENT 3 uate: February 1997 Revision No.: 4 Page No.: 10-1 EMERGENCY CONTINGENCY PLAN AUTHORIZED EMERGENCY COORDINATORS Persons authorized to act as emergency response coordinators should be contacted by pager according to a weekly "ON CALL" rotation. Monthly roster is available in CPl, CP2, CP3 and at the guard gate. NAME Dave Wesley TITLE Regional Director PLANT # 213/363-1101 PAGER # EXT,275 8oo/225.()256 PIN # HOME # 5974572 909/949-9520 Jim Marzolino Reg. Bnv. Eng. EXT,259 8oo/225-Q256 6053573 714/538-8805 Sylvia Ross Reg. Human Resources (818)937-2545 8oo/225-Q256 5974891 818/961-9644 Carlos Pena Process Engineer EXT. 260 8oo/225-Q256 907152 213/300-2179 Ty Avendano Health and Safety EXT,215 8oo/225-Q256 5974573 8181752-1613 Bill McKusky Engineer EXT,226 213/963-1499 N/A 8181796-8542 Maintenance Engineer EXT,264 213/530-9113 N/A 310/970-1818 Jim Puller THE PRIMARY COORDINATOR WILL BE LISTED ON A CALENDAR AS STATED ABOVE. IF YOU ARE UNABLE TO CONTACT THE PRIMARY COORDINATOR CONTINUE CALLING OTHERS ON THE LIST UNTIL ONE IS REACHED. AUTHORIZED SHIFT SUPERVISOR Persons authorized to act as shift supervisors are: (alternate Emergency Coordinator or onsite Coordinator) NAME TITLE PLANT # 213/363-1101 PAGER # Department Head EXT,224 213/991-6970 Joe Gonzalez General Supervisor EXT,286 Bob Emerson Department Head EXT,287 NA NA NA NA Rafael Perez Jack London Shift Supervisor EXT,286 Joseph Davis Shift Supervisor EXT,286 CELLULAR # NA NA NA NA NA HOME # 213/583-3836 213/566-7323 714/828-5389 3101788-9154 714/~21-4405 "dte: February 1997 Revision No.: 4 Page No.: lOA-S TABLE 10.6 CONTINGENCY PLAN DISTRIBUTION AND RECORD OF UPDATES DISTRIBUTION & REVISIONS Environmental Engineer Plant Manager Plant Engineer Guardhouse Health and Safety Manager Wastewater Treatment Building Maintenance Shop RMPS Refmery Administrative Building Laboratory Smelting Building Scalehouse Employee Facilities Vernon Fire Department Vernon Police Department L.A. County Sheriff Telegraph Medical Clinic Spectrum Industrial Medical Clinic Beverly Hospital Rio Hondo Hospital ATTACI-DIEN 4 i I l TECHNOLOGIES May 27,1997 Mr. David Sanchez Industrial Waste Inspector Los Angeles County Department of Public Works 1955 Workman Mill Road Whittier, California 9060 I Re: April 28. 1997 Response to Mud Tank Release Dear Mr. Sanchez: In response to your site visit on April 29, 1997 concerning the release from the number one mud tank on April 28, 1997 at the GNB Vernon facility, the following infonnation is being supplied to you: 1. The release was discovered on April 28, 1997 at approximately 3 :30 in the afternoon. 2. The material released was lead oxide paste that was undergoing desulfurization by the addition of soda ash. 3. The quantity of the release to the storm channel was estimated to be approximately 20 gallons. The extent of the spill outside the containment structure is hard to detennine as response activities began in the contained area immediately after the release. G:\,B 207003.1 TechnllloglL'~ Recycling Di"lsion PO. Box 23957 2700 South Indiana Street Los Angeles, CA 90023-0957 U.S.A Telephone: 1.213.262.1101 Facsimile: 1.213.261.3584 Mr. David Sanchez May 27,1997 Page 2 4. The cause of the releases from the mud tank is still under investigation. The release to the storm channel is believed to be caused by trucks splashing the material into the channel when driving in to unload spent batteries. Another possible cause of the release to the channel is when cleanup of the area began, a hose was used to wash down the area and a scrubber truck was used to collect the liquid and mud. 5. The liquid recovered from the scrubber was pumped back into the mud tanks for treatment. The gravel and sand collected from the stormwater trench was collected into hoppers. Any liquid from the cleanup was also collected in the hoppers and was absorbed by the silica sand. 6. To prevent any further releases to the stormwater channel, the raising of the existing six inch berm to approximately three feet is being considered. The enclosing of mud tank area from the base to the top of the tanks is being developed. The release is still being investigated and, once the cause is known, measures will be taken to prevent any future releases. 7. The gravel from the storm channel was stockpiled and will be properly managed. Three samples were taken for verification of cleanup. The samples were taken in clean zones outside the release area. The samples were taken on May 5, 1997 and were witnessed by Leonard Grossberg, Environmental Health Specialist for the City of Vernon. Upon receiving the analytical results they will be forwarded to your department. Follow-up Site Visit On April 30, 1997 Hector Aguirre, LA. County Department of Public Works visited the site for final inspection. He said the cleanup was satisfactory, gave us a key for the fence lock for any future incidents and gave us a list of DPW approved emergency responders. 207003.1 Mr. David Sanchez May 27,1997 Page 3 If you should have any further questions or comments, I can be contacted at (213) 262-1101, extension 259. Sincerely, James R. Marzolino Environmental Manager cc: 207003.1 Dave Wesley Thomas McHenry Leonard Grossberg, City of Vernon Roland Romain, L.A. County Dept. of Public Works Gary Wiskus, City of Vernon Fire Department Ruth Morehead, DTSC Glendale ATTACIQENT 5 Date: March 1997 Revision No.: 4 Page No.: 5-18 TABLE 5.2 WASTE ANALYSIS SUMMARY DESCRIPTION Spent Battery "Acceptable" Plant Scrap Material "Conditionally Acceptable" Plant Scrap Material I LDR APP~IC~~!LlT0 .' o. \> oo.......................oo...o. ????i rESTPARAMETER~ Sulfuric acid (D002) Lead (DOOS) Arsenic (DOO4) Cadmium (DOO6) Not Applicable - will not be placed in a land-based Non lead-acid batteries Not Applicable Visnal Inspection Arsenic (DOO4) Cadmium (DOO6) Lead (DOOS) Not Applicable - will not be placed in a land-based unit Total Lead Total Mercury Total Aluminum Grab/composite Visual Inspection; SW-846 Method 6010 SW-S46 Method 747017471 (for mercury) Total volatiles and semi volatiles - sweepings only Grab SW-846 Method 8240 and 8270 Total Lead Total Mercury Total Aluminum Composite Visual Inspection; SW-846 Method 60 10 SW-846 Method 747017471 (for mercury) Chlorinated hydrocarbons - sludges, dusts, and drosses only Grab SW-846 Method 8120 COMMON COMPONENTS Arsenic (D004) Cadmium (D006) Lead (DOO8) . . . .,,> i SAMPLE . ooo..o.o. !i'ANALYTICAL >\> .... I.PROCEDURE. unit Not Applicable - will not be placed in a land-based unit ~Ctw -t..~, c4uJ6 Polypropylene Lead (DOO8) Not Applicable - will not be placed in a land-based unit Total Lead Grab -ft>.f1..I.-v TCLP, STLC, TTLC, SW-846 Method 6010 Blast Furnace Slag Lead (DOOS) Yes Total Lead Composite TCLP, STLC, TILC, SW-846 Method 6010 Retention Pond Sediment Lead (D008) Not Applicable - will not be placed in a land-based Total Lead Grab I I OI.~ I I J TCLP, STLC, TTLC, SW-846 Method 60 10 I Date: March 1997 Revision No.: 4 Page No.: 5-29 5.3.4.2 Blast Furnace Slag If GNB determines the slag may be defined as non-hazardous. waste, it is sampled and analyzed for lead and other heavy metals listed in Table 5.4 to determine if the material meets the definition for a federal or California hazardous waste. If an analysis fails, then that material, when shipped, is manifested as a hazardous waste. However, if all analyses pass, then the next roll-off shipment may be shipped under a bill of lading as non-hazardous waste. Once the analyses determine that the slag is a non-hazardous waste, the material is sampled at the intervals specified in Table 5.5. 5.3.5 Sampling Procedures These sampling procedures provide the best means possible to obtain a representative sample of plant scrap raw material, polypropylene and Blast Furnace Slag wastes, and retention pond sediment. A representative sample is collected and handled in a manner that preserves its original physical form and composition, as well as prevents contamination or changes in concentration of the parameters to be analyzed. The sampling procedures are described below. Sample Collection Prior to sampling activities, the technician cleans and decontaminates all equipment. During the sampling process, the technician wears new, clean latex gloves, in addition to applicable personnel protective Clothing and equipment outlined in the plant's health and safety plan. Conditionally Acceptable Plant Scrap A sample is collected from drums of CONDITIONAlLY ACCEPTABLE plant scrap to verify that the material is not a hazardous waste prior to the drum and its contents being processed into the Blast Furnace. The contents of the drum to be sampled are emptied onto the floor of the Blast Furnace Feed Room. The sampling technician collects one grab subsample of each type of material identified from the drum using a decontaminated, stainless steel trowel. The SUb-samples are then placed in a Pyrex or stainless steel bowl and mixed to \ achieve maximum homogeneity. The composite sample is then transferred to appropriate . sample containers. One sample per supplier is analyzed. Polypropylene To verify that the polypropylene chips do not meet the definition of a hazardous waste, the chips are sampled from each semi-trailer prior to shipment off-site. The process generating the polypropylene is relatively simple, and the reSUlting chips are a homogeneous material. Therefore, a single grab sample collected per trailer constitutes a representative sample. The sample is collected using a decontaminated, stainless steel trowel or small spade prior to being transferred to appropriate sample containers. Date: March 1997 Revision No.: 4 Page No.: 5-32 If the sample passes both the STLC and TTLC criteria, then the sampled material is classified as .non-hazardous waste and is transported under a bill oflading via a licensed hauler to a permitted plastic reclamation facility for the polypropylene chips or a Class II Solid Waste (non-hazardous) landfill for Blast Furnace slag. Organic Analyses The samples of sweepings are sent off-site for analysis. The samples are analyzed for total volatile and semivolatile compounds (40 CFR Part 261, Appendix VIII) using SW-846 Methods 8240 and 8270, respectively. SW-846 Method 8120 is used for all chlorinated hydrocarbon analyses of sludges, dusts, and drosses. Hydrocarbon Vapor Analysis Each drum of sweepings is tested with a portable HNU Flame Ionization Hydrocarbon Detector. The instrument is calibrated against methane according to the Laboratory Analysis Procedures as developed by GNB' s Quality Manager. The instrument is capable of detecting hydrocarbons at levels of 1 ppm in vapors. 5.3 .. 7 Waste Analysis Parameters " " ,....-:->."", ',' \-'' ~ 1---r' I . '-, ~- The waste analysis parameters are selected to provide sufficient information to ensure o Compliance with applicable regulatory requirements (e.g., LDR regulations, newly identified or listed hazardous waste) or waste identification o Conformance with permit conditions (i.e., ensure that wastes accepted for management fall within the scope of the facility permit, and process performance standards can be met) or process and design considerations o Safe and effective waste management operations (i.e., ensure that no wastes are accepted that are incompatible or inappropriate given the type of management practices used by the facility) or identification of incompatible/inappropriate wastes For the purposes of generating documentation for using acceptable knowledge, as allowed in the Guidance Manual, GNB runs an annual metals analysis on each type of ACCEPTABLE plant scrap material received from each battery and/or lead oxide manufacturer (sampling strategy is provided in Section 5.3.5). Based upon GNB's process knowledge concerning the generation of plant scrap from lead-acid battery manufacturing plants, the majority of the plant scrap does not have the potential to become contaminated with organics. However, one material, sweepings, is generated in a manner that allows for potential contamination. Therefore, the annual analyses also include a volatile and semi volatile analysis for sweepings. I Date: March 1997 Revision No.: 4 Page No.: 5-34 BIF Regulations To comply with 22 CCR 266.100(c)(3)(D) and 66266.100(c)(3)(D), GNB is required to develop a waste analysis plan to show compliance with the following criteria: 1) 2) 3) The waste contains recoverable levels of lead; The waste does not exhibit the TC of 22 CCR 261.24 for an organic constituent; and The waste is not a hazardous waste listed in Subpart D of part 261 because it is listed for an organic constituent as identified in Appendix VII of part 261. To determine that all waste contains a recoverable level of lead and meets the BIF requirement, a metals analysis is performed on all plant scrap. The analysis is run per the sampling strategy outlined in Section 5.3.6. Based upon GNB's process knowledge concerning the generation of plant scrap from lead-acid battery manufacturing plants, the majority of the plant scrap does not have the potential to become contaminated with organics. However, one type of material, sweepings, may be generated in a manner that allows for potential contamination. Therefore, the fingerprint analysis for sweepings also include the use of an HNU for hydrocarbon detection. 5.3.9 Incompatible/Inappropriate Waste Identification Incompatible/inappropriate components that may contaminate the plant scrap received from off-site are mercury, aluminum, and organics. The Recycling Facility is not permitted to receive mercury toxicity characteristic wastes (D009) or the characteristic and/or listed wastes associated with organics and/or chlorinated hydrocarbons; the facility's air permit does not allow the emissions from the combustion of such compounds. Mercury and aluminum are considered incompatible with the process and are a potential hazard if inadvertently charged to the furnace. The acceptanceirejection procedures for materials contaminated with organics, chlorinated hydrocarbons, mercury, or aluminum are outlined in Section 5.3.3. 5.4 ANALYSIS PLAN UPDATE This waste analysis plan and other procedures associated with the receipt of off-site materials will be reviewed, and if necessary, updated whenever: 1) Facility processes change in a way that might be threatened by currently defined indigenous battery plant scrap. 2) Materials included in the definition of acceptable indigenous battery plant scrap change in a way which threatens facility personnel, equipment or the enviromnent. 3) Unacceptable materials are found to result in any sort of operational failure. \ ATTACI-DIENT 6 1Q w g~I~I~I~~I~I~~~I~~~I~I~i~~lt~I~I~I( I- ::I: S2 W s:en? en o ~ C> ~ w ~ III u.. o ~ oIZ W ~ - en w g ..J oz :c (.) w I- m z <.!) INVENTORY OF BATTERY GROSS WEIGHT (iNS TECHNOLOGIES INV.IN BINS GROSSWT. 101 144,000 144,000 0 0 15197 0 0 216197 0 0 217197 0 0 2110197 74,000 _ ~ 37 2117197 I 8,000 I 4 2118197 0 f--J124197 154,000 2125197 I 468,000 I 392,000 r~, DATE 213/97 r- 214197 r 102 103 0 0 0 0 0 0 0 0 0 0 0 _ 0 0 0 0 0 0 0 I 0 I 76,000 ::lb"f~;r 4-t~.M6T;39.2.oaoT - 0 - ' -r7t.DOO ~ I 1 >>~;h'7IYtR:6<>]>1.372.b611 L_Q~~ L7.LI:>CJ~L 104 0 0 0 0 0 0 0 0 0 0 0 [) 105 0 0 0 0 0 0 0 0 0 0 D L _ 12 L Feb-97 106 107 108 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DOD [) ,- D SKIDS 72 0 0 0 0 37 4 0 77 234 :E!,

._]~k..Q-_-lu}l7i'ZLr / 7 JDAIL Y AND WEEKLY INSPCTION FORM " ""'AlLY INSPECTION : ti-/J)~ ~r <1/'7 P:; "7 Date 9-/1/1 7 4AOIQl I<1 0\ {c- D, b. 0.1:::. D? \C. o .!:::. o. \;z . C) ./::. . , ( Jtter'y Unloading Area .. , Remark o?k? o.t oVel[ f)L.o vJ' ~ kJ71 ? V{ MPL~ IJ~r11 ~V\t.:{t ~ 'I; <:' G01 fITji:xe. b'v lDt:tot't I\.e'r 'ew:oVe. AV\~ ~e.. fEURl.\..(oVe.. Drains & Pipin Storm Water Pond tor. \9 '*:oJ '=' it1:> $flAY.i:o ik~ If'l kt- ~ (~~n' e ~) OI.A h l ~ o?t. i I DAILY YARD FUGITIVE INSPECTION REPORT InspectorRo b{lVit Ts~ Time!2" ff/( -30 Date 4/;! /f.7 l.West Yard 2. South West Monitor Area 3. Trailer Wash Area 4. Balloon Flue Area 0, 5. "A" Pipes !(2, 6. Baghouse Area 7. Feed Room Aisleway t2 ,f;. 8. North Yard 9. Wastewater Treatment Area 10. South East Monitor Area 1l. Others 12. Air Flow Monitors 13. Triblowflows Signature: Ins ector: ro " ,q(q1 - "'7~ Reviewer""",:,..Lf--'--t---'-1_ _ _ _ _ _~ DAILY YARD FUGITIVE INSPECTION REPORT Inspector'?1. ~~ 1~~ Time1.: l')~Date4A0/9 7 \)'\ft} l.West Yard 2. South West Monitor Area 3. Trailer Wash Area 4. Balloon Flue Area 5. "A" Pipes 6. Baghouse Area vk*~ 7. Feed Room Aisleway 8. North Yard 9. Wastewater Treatment Area 10. South East Monitor Area o,lowt 1~ l.West Yard Timej 2 0" ff1 Dat4/~ Ii 7 D'G' 2. South West Monitor Area 3. Trailer Wash Area 4. Balloon Flue Area 0." . 5. "A" Pipes 6. Baghouse Area G?b- . 7. Feed Room Aisleway 8. North Yard 9. Wastewater Treatment Area d? r ' 10. South East Monitor Area 11. Others 12. Air Flow Monitors 13. Triblowflows 14. Wind monitors Signature: . /\ fJ rnli( ( VI '(2 I Jlln!.[sRSe~cttQO!Lr:---=~~'!!Jf.L+-~~.Reviewerl \fill \ JDAIL Y AND WEEKLY INSPCTION FORM DAIL YI NS PECTION Jf/t /'1'1 ~/~ \ (0,1 Date O?~ o .~. . RMPS, Tanks 'I/~/q/ . I O,~ :J k. ;to RL\'~<,l r~~~ Flue Dust Slurry Tanks O?~. O?lQ , O? RMPS, sumps O?~. o .~, O?K"'. O?t. V " . Battery Unloading Area d7/ ~ \/0 l WEEKL Y INSPECTION (Put inspection date) n.b. Refinery building O?~. RMPS building Feed room aisleway I Storm water trench ;torage area L 0- V\ ~ +!p o' \ O?J;:: . P'- v: Drains & Piping Storm Water Pond o .tt. . f;L. ?l< . o. t:. Remark