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LMT generated 5.25 tons of hazardous waste in 1991. VII. VIOLATIONS: At the time of the April 27, 1992 inspection, LMT had stored waste (air dry paint room sweepings) in an uncovered and unlabeled container. VIII. OBSERVATIONS: Mr. Snavely and I arrived at LMT at approximately 10:30 a.m. We identified ourselves and asked to speak to the appropriate hazardous waste management person. Mr. Snavely and I were escorted to the office of the plant supervisor, Dalton Beitz. Mr. Snavely and I introduced ourselves to Mr. Beitz and explained the nature of our inspection. Mr. Beitz identified himself by card and started to explain the operation of LMT. Mr. Beitz stated that he was very interested in hazardous waste minimization. Mr. Beitz told Mr. Snavely and I that LMT had evaluated it's paint waste stream. LMT changed to water based paint and had determined paint sludge was non- hazardous. Since the dewatered paint sludge made up the majority of LMT's hazardous waste, Mr. Beitz was hoping LMT would not be a large hazardous waste generator from now on. I told Mr. Beitz PHS-EHD might not regulate LMT after 1992, however, PHS- EHD needed to perform a generator and sampling inspection to confirm LMT's waste streams were in fact non-hazardous. Mr. Beitz gave me Material Safety Data Sheets for water based paints and solvents. 1 also received a copy of "certificate of recycling/reuse" from Summit Environmental Corporation for two drums of floor sweepings. Mr. Beitz agreed to the inspection and asked Mr. Lind to show Mr. Snavely and I around LMT. Mr. Snavely, Mr. Lind, and I crossed the street to the Plant. We followed Mr. Lind through the steel supports manufacturing operation including the welding shop, conveyorized paint spray operation, outside building sump, sludge treatment area, the machine shop, and finally to the air dry paint room. (In the air dry paint room, a 55 gal. drum used for floor sweep was uncovered and unlabeled.) 5