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lo <br /> Brad Parsons -2- February 29, 1984 <br /> Generator Inspection <br /> Triangle Pacific Corp. <br /> V. Discussion with Management <br /> The inspection of TPC facility was conducted on 14 February 1984. <br /> Various violations related to generators of hazardous waste were <br /> noted and are listed as follows: <br /> 1. Pre-Transport Requirements <br /> a. Containers are not being marked with start of accumulation <br /> date (262.34, 40 CFR) . <br /> b. Containers holding ignitable wastes are not located at least <br /> 15 meters (50 feet) from the facility's property line <br /> (265. 176, 40 CFR) . <br /> C. There were no records to show that periodic inspections of <br /> the container area is being done (265. 174, 40 CFR) . <br /> 2. Record Keeping and Reporting Requirements <br /> a. TPC has not submitted annual reports as required (262.41, 262.42 <br /> 40 CFR) . <br /> 3. Training, Emergency Procedures Requirements <br /> a. TPC has no personnel training records (265.16, 40 CFR) . <br /> b. TPC does not have a written contingency plan in the event of a <br /> fire, explosion, or any unplanned release of hazardous waste <br /> (CFR 265.51 ; 265.56, CFR) . <br /> 4. Emergency Coordinator <br /> a. The facility emergency coordinator has not been identified <br /> (265.55, 40 CFR). <br /> All violations and suggested corrective actions were discussed with Mr. <br /> Helton and Mr. Kirkpatrick. <br /> In the container area were approximately 100 drums of solid and liquid wastes <br /> and 75 empty drums. I advised Mr. Helton that the empty drums were considered <br /> hazardous, as they contained residual lacquer and thinner. Further, he was <br /> told that if TPC wished to maintain its generator status , the drums must be <br />