COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

January 7,2003 Page 2 Inspection Report. Item 19 referred to two 55-gallon drums of unknown contents and one large bag of fuel filters. The manifest at Attachment C, dated April 24, 2002, was for disposal of three drums of"Gasoline and Water Mixture." Based on the description of the waste in the manifest, I believe that the April 24`h manifest showed disposal of the two drums of unknown contents, but not the fuel filters. I have not yet confirmed how the dealer managed disposal of the fuel filters. Used absorbent and fuel filter waste is generated by the lessee-dealer and it is the lessee-dealer who is responsible for the proper management and disposal of this material. Item 20 on August 26, 2002 Inspection Report As I explained in my November 20`h letter, in response to Item 20 from the August 26`x' Inspection Report, BP has taken steps to educate the dealer at ARCO Facility No. 2133 on proper hazardous waste labeling practices. In addition, although BP believes that its hazardous label is compliant, it is exploring revising the label to ensure that the EHD is satisfied with its form. Item 21 on August 26 2002 Inspection Report Item 21 on the August 26`s Inspection Report related to the requirement that hazardous waste containers be kept closed. Specifically, this item related to the 30 gallon carboy of antifreeze, which was the dealer's waste. In my November 20`h letter, I explained steps BP has taken to educate the dealer on proper hazardous waste management, including that "contractor will be requested to submit a copy of manifests for the transportation of hazardous waste to the facility." In hindsight, I realize that this statement could be read two ways. By this statement, I was referring to the fact that the contractor will be requested to submit the manifests to the facility(not that the hazardous waste would be transported to the facility). Item 45 on April 4. 2002 Inspection Report The April 4th Inspection Report indicated for this item that the facility had an"incomplete contingency plan"and that a form outlining the missing information was provided to the facility. In my November 20th letter, I responded that BP had completed the requested form and enclosed a copy of that Hazardous Waste Emergency Information form as Attachment E. In my November 20`s letter, I referred to that form as a"contingency plan," using the same terminology used in the Inspection Report. To clarify, the Hazardous Waste Emergency Information form is the informational form that a small quantity generator must keep by the phone under 40 CFR 262.34(d), and is not formally defined as a contingency plan in the applicable regulations. I understand that the ARCO Facility No. 2133 does not generate more than 1,000 kilograms of hazardous waste per month, and therefore is not required to have a large-quantity generator contingency plan under Section 66265.52.