SFUND RECORDS CTR

2128532

Orange County Health Care Agency Project Chronology provided by Kevin Baitx 4/4/07

Impressions Polishing and Plating. Orange, CA

INSPECTION HISTORY/CHRONOLOGY

5/10/06 Routine Inspection (Mayo). The following violations were noted:(W052) Generator has not obtained proper identification number.(W222) Manifests are not properly completed by generator or copy not sent to DTSC within 30 days.(W302) Generator does not store waste within approved accumulation times.(W312) Each container and portable tank is not clearly marked with beginning accumulation date.(W322) Each container and portable tank is not marked "Hazardous Waste" including: Composition andPhysical State of Waste, Hazardous Properties, and Generators Name and Address.(W422) Containers are not stored closed during transfer and storage.(W442) Container storage areas are not inspected weekly for deterioration and leaks.(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(W952) Facility has not developed or submitted required SB-14 Plans and Reports.(WO 12) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

Observations: A joint inspection was conducted by Howard Mayo and Pearl Boelter.This facility is using multiple EPA ID numbers on manifests. Generator is not maintaining final'signed off copies of manifests from Designated Facility. No manifests for waste disposal offilter cake since January 2006. Accumulation start dates not written on sulfuric acid drums instorage area, and waste sludge bins outside. No hazardous waste labels on sludge transfer drams,waste sludge bins outside, wasted sulfuric acid near strip tank, drums for polishing debris, andwaste debris drams in storage area. Containers / drams with filter cake uncovered inside thefacility. Operator is not keeping log of visual inspections of haz waste storage. Training recordsnot available for review. Employee job descriptions not available for review. Provide ownershipchange and updates to existing SB 14 report to DTSC.

Please have analysis ran for all wastes being treated in the waste water treatment system.Please have analysis done by a California state approved lab. Obtain and maintain available forreview a written assessment/certification that has been reviewed and certified by an independent,qualified professional engineer, registered in California, that attests to the integrity of each onsitehaz waste storage tank and associated secondary containment system. Tiered Permitted facilitiesmust prepare closure plans for all fixed treatment units.

6/8/06 Follow up (Mayo) Spoke with Alex Granero regarding outstanding violations. He statedthe following by phone:

1. He would fax copies of manifests.2. He has not corrected the address on his Federal EPA ID3. He cannot afford to pay his employees let alone hire a PE

7/17/06 Follow up phone call (Mayo) Left message for Alex G. regarding outstandingviolations.

Show Cause Letter Request11/22/04

8/24/06 Follow up inspection (Mayo) Onsite for follow up inspection to check progresswith outstanding Hazardous Waste violations. The inspection was a joint inspection with BradGoodrich assisting from Orange Fire Dept. Pearl Boelter, Isaac Mendel, and I represented thisAgency. Alex Granero with Impressions Polishing was present. The following items were notedand observed:

1. All outstanding violations for this facility are still outstanding.(W052) Generator has not obtained proper identification number.(W222) Manifests are not properly completed by generator or copy not sent to DTSC within 30 days.(W302) Generator does not store waste within approved accumulation times.(W312) Each container and portable tank is not clearly marked with beginning accumulation date.(W322) Each container and portable tank is not marked "Hazardous Waste" including: Composition andPhysical State of Waste, Hazardous Properties, and Generators Name and Address.(W422) Containers are not stored closed during transfer and storage.(W442) Container storage areas are not inspected weekly for deterioration and leaks.(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(W952) Facility has not developed or submitted required SB-14 Plans and Reports.(W012) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

Inside the facility, several open, unlabeled 55 gallon drums of waste filter cake were observed.The secondary containment under the waste water treatment system had a large accumulation ofliquid. Mr. Granero explained the secondary containment is pumped daily (approximately 1000gallons). Severe etching of the secondary containment cement was observed. The area under theclarifier for the treatment system had an extreme accumulation of liquid. The secondarycontainment directly under the process is covered and could not be easily inspected. The processfloor (wood planks) was extremely wet. Debris was observed on the process floor, under tanks,and under the wood. Several tanks were partially covered with wood and had items stored on topof the wood. A zinc rinse tank was leaking heavily. An area of the tank also appeared to besplitting. The tank was red tagged by Mr. Goodrich. The ventilation system for the process areadid not appear to be working.

Outside the facility, several cubic yard sacks with waste filter cake were labeled by an employeeof the facility during the inspection. The accumulation dates on the labels did not appear to beaccurate. Two sacks had the same date on them. Mr. Granero advised the waste was refused bythe transporter because this facility does not have a Federal EPA ID number. Mr. Graneroadvised the facility has applied for a number and the waste will be transported when it is issued.The last disposal of waste filter cake was in May of this year (per a manifest reviewed on site).One drum of sulfuric acid had a labeled accumulation date of 5/10. The cubic yard sackcurrently being used for accumulation was not labeled and there appears to be run off under theaccumulation area. Filter cake was observed on a piece of cardboard near two shovels used totransfer filter cake to the sack. An unlabeled 55 gallon drum of waste oil was observed. An oildrain pan with waste oil and 2 used oil filters was observed. The air compress appears to havean oil leak and evidence of an oil spill was observed outside the secondary containment for the

Show Cause Letter Request11/22/04

compressor. Evidence of a wash down or release was observed leading from one of the doors ofthis facility to the parking lot. The drainage channel in the parking lot has been etched.

Photographs were taken on site.

9/6/2006 Follow up phone call (Mayo) Received phone call from Hector Garcia(consultant) regarding outstanding TP and Haz Waste violations for Impressions Polishing andPlating, 1223 Batavia, Orange, CA.

Mr. Garcia informed me that he and Alex Granero have drafted a letter that will be faxed latertoday. The letter will explain how Impressions has begun remedial action with regard to theoutstanding violations.

10/17/2006 Follow up phone call and inspection report (Mayo) Let this report reflect atelephone conversation with Alex Granero of Impressions Polishing and Plating.

Today I spoke with Mr. Granero and explained Impressions Polishing & Plating mustCOMPLETE a written assessment/certification by a professional engineer by January 2007. Theviolation for not having this certification has been outstanding since March 2005.

Outstanding Violations that still remain for Impressions Polishing and Plating are listed below:

(W052) Generator has not obtained proper identification number.(W222) Manifests are not properly completed by generator or copy not sent to DTSC within 30 days.(W302) Generator does not store waste within approved accumulation times.(W312) Each container and portable tank is not clearly marked with beginning accumulation date.(W322) Each container and portable tank is not marked "Hazardous Waste" including: Composition andPhysical State of Waste, Hazardous Properties, and Generators Name and Address.(W422) Containers are not stored closed during transfer and storage.(W442) Container storage areas are not inspected weekly for deterioration and leaks.(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(W952) Facility has not developed or submitted required SB-14 Plans and Reports.(WO 12) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

10/17/06 Onsite Follow up (Mayo) Onsite to follow up and check status of HazardousWaste and Tiered Permitting violations. Alex Granero was present.

The following items were noted and observed during this inspection:

1. The area underneath the process tanks was dry. Mr. Granero stated that the area iscontinuously being pumped out.2. The Hazardous Waste being stored onsite was all within 90 days storage time limit.3. The facility has assumed the EPA ID number CAD981983968 from the previous owner,PLATECORP. The number is currently listed as INACTIVE. Please ensure this number isactivated and begin using on all hazardous waste disposal manifests. EPA ID numberCAR00160556 has been terminated with DTSC.4. All containers storing Hazardous Waste were properly labeled and stored closed.

Show Cause Letter Request11/22/04

VIOLATIONS STILL OUTSTANDING

(W052) Generator has not obtained proper identification number.(W442) Container storage areas are not inspected weekly for deterioration and leaks.(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(W952) Facility has not developed or submitted required SB-14 Plans and Reports.(WO 12) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

VIOLATIONS ABATED

1. XI32 - Compactor is taken out of production.2. W302, W312, and W322 Accumulation times3. W422 - Storage violation4. W222 - Manifest violation. Please ensure you are keeping all copies, including the final'signed off copy sent when waste makes final destination.

10/18/06 In office follow up (Mayo) Received copies of Manifests for ImpressionsPolishing and Plating, 1223 N Batavia St., Orange, CA.

11/28/06 Onsite follow up inspection (Mayo) Onsite to meet with Alex Granero ofImpressions Polishing and Plating (IPP) to discuss outstanding Hazardous Waste and TieredPermitting violations.

The W952 violation for SB14 documentation has been abated. A copy of the IPP SB14 reportfrom 2002 was received for the Orange County file.

The following violations detailed in previous inspection reports remain outstanding:

(W442) Container storage areas are not inspected weekly for deterioration and leaks.(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(W012) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

Please abate the violations listed above immediately. If you have any questions please contactHoward Mayo 714 433-6245.

11/30/06 Emailed Alex Granero with Impressions Polishing and Plating the Title 22guidelines for PE assessment.

12/13/06 Onsite Follow up inspection (Mayo) Onsite with Alex Granero to discussoutstanding Hazardous Waste and Tiered Permitting violations.

Show Cause Letter Request 411/22/04

Violation W442 is abated.

A Hazardous Waste inspection log was available for review during this inspection. The logshows daily waste inspections beginning on November 28, 2006.

Employee haz waste and safety training records were available for review during this inspection.One employee, Juan Perez was listed as having been trained. Please continue to train allremaining staff that handle hazardous materials as detailed in previous reports.

Secondary containment underneath the water treatment area had approximately 10 gallons ofliquid during this inspection.

The following violations detailed in previous inspection reports remain outstanding:

(W822) Personnel are not trained within six months of employment or assignment and an annual review.(W832) Adequate training records are not maintained and kept on-site.(WO 12) Hazardous Waste determination not made for all wastes.(W502) Generator does not comply with Article 10(Tank Management standards) except sections66265.197 & 66265.200)(X222) Closure plan not prepared nor available for review.

Please abate the violations listed above immediately. If you have any questions please contactHoward Mayo 714 433-6245.

1/3/06 Follow up phone call(Mayo) Received phone call from Priscilla Cook fromCDMS. She stated that her company has been retained by Impressions Polishing and Plating. Shestated that it would be very difficult for her company to complete the PE Certification beforeFebruary.

1/4/07 NOV sent certified mail to facility.

1/8/07 Follow up Inspection (Mayo, Mendel) Onsite to follow up on outstandingHazardous Waste and Tiered Permit violations. Isaac Mendel from this Agency was alsopresent. Met with Alex Granero. During the inspection Mr. Granero was meeting with hisconsulting firm, CDMS, Inc. CDMS is working with Impressions on the existing HazardousWaste and Tiered Permit violations.

Mr. Granero stated that status has not changed and none of the outstanding violations have beencorrected at this time.

The secondary containment area beneath the water treatment area did have several gallons ofliquid. The liquid was removed during the inspection. The filter cake transfer area behind thebuilding was free and clear of debris.

3/29/07 Onsite follow up HW inspection (Mayo, Mendel) Onsite with Isaac Mendel for afollow up Hazardous Waste inspection. Alex Granero with Impressions Polishing and Platingwas present.

Show Cause Letter Request 511/22/04

The following items were noted and observed:

Mr Granero advised us that Impression Polishing and Plating is in the process of closing. Theprocess line and treatment unit were not in operation this date. Buffing was still being conducted.

All violations from Notice of Violation on January 4, 2007 remain outstanding.

OUTSIDE the facility.

8 bags of filter cake. A large quantity of empty drums(20 +). One roll off bin with debris(wood,plastic, polishing debris). One drum of paint strip. 15 waste acid drums. 4 totes 250 gal each ofsulfuric acid. 1 tote of new nickel solution. The shed behind the facility contained 10 five galloncontainers with calcium Hydroxide, chem strip, and paint. One drain pan with used oil.

INSIDE the facility.

Sludge dryer has been returned to the company that was leasing the unit to Impressions. 1 drumof filter cake. 4 drums of copper, nickel, and chrome waste. Approximately 30 + process tanksremain. Many still with liquid remaining. Each tank being approx 500 to 1000 gallons.

The following items will be further review by this Agency:

Empty containers previously holding hazardous materials or hazardous waste larger than 5gallons must be properly managed.

All debris, all process floor wood, and all hazardous materials onsite is presumed to behazardous by this Agency and must be properly managed.

Please ensure all hazardous waste manifests are available for review. Please contact this Agencywhen all wastes have been properly transported for disposal. A follow up inspection will berequired.

Photographs of the entire facility were taken during this inspection.

3/29/07 Follow up TP inspection (Mayo, Mendel) Onsite with Isaac Mendel for a follow upTiered Permit PBR inspection. Alex Granero with Impressions Polishing and Plating waspresent.

The following items were noted and observed:

Mr Granero advised us that Impression Polishing and Plating is in the process of closing. Theprocess line and treatment unit were not in operation this date. Buffing was still being conducted.

All violations from Notice of Violation on January 4, 2007 remain outstanding.

The sludge dryer has been removed and returned to the leasing company. No notification ofclosure for the sludge unit was submitted to this Agency.

Show Cause Letter Request11/22/04

Please advise this Agency when a Closure Plan is available onsite. This Agency must be notifiedin writing at least 15 days prior to the completion of the closure plan. A California CertifiedProfession Engineer must certify the treatment units were shut down properly and according tothe Closure Plan.

Pictures were taken. A follow up inspection will be required by this Agency.

4/3/07 Follow up TP Inspection (Mayo, Mendel, Baitx)

Onsite to follow up with outstanding Tiered Permitting violations. Alex Granero was present.

Mr. Granero notified me that the TP Unit (sludge Dryer) has been decommissioned and removedfrom facility. This is in violation of the Tiered Permit closure procedure requirements.Immediately discontinue closure of the TP Unit unless prior notification has been made to thisAgency. Immediately notify this Agency where the sludge dryer was taken. Any further closureof the TP Unit without notification to this Agency may result in additional enforcement action.

4/3/07 Follow up HW Inspection (Mayo, Mendel, Baitx)

Onsite today in response to a referral from the City of Orange Fire Dept that the facility may beillegally disposing of hazardous waste(cutting up haz waste tanks and disposing to trash).

Alex Granero was present and discussed the following items:

I determined there was no illegal disposal of hazardous waste on the property rather he wasinvolved in sale of scrap metal / parts(meter, boiler).

Discussed with Mr Granero proper management and disposal of remaining hazardous waste.Discussed that all remaining chemicals, waste, floor boards, polishing debris, oil, contaminatedbuilding interior, tanks/containers, are presumed regulated hazardous waste and must bemanaged/manifested as hazardous waste.

Inventoried hazardous waste onsite; Exterior south side of building, 3 - 5 5 gallon drums ofpolishing dust. 1 - 270 gallon Chrome tote. 1 - 270 gallon Nitric Acid tote. Rear ExteriorHazardous Waste storage area, 6 - 270 gallon totes, 44 - 55 gallon drums. Haz waste shed rearME., 2 - 270 gallon totes, 30 - 55 gallon empty drums., 30 - 5 gallon full containers. 1 roll off fullbin., 9 Cubic Yard totes full of filter cake. 3 - 5 5 gallon drums next to water treatment. Unknown15 gallon drum near plating area. Plating area has 6 - 55 gallon drums. 15 approximately 1500gallon plating tanks. 10 -55 gallon drums near SE corner of plating area.

Show Cause Letter Request11/22/04