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permissi n to proceed. With all necessary parties present <br /> we began the physical inspection of the facility in the <br /> "shop" a ea. <br /> The Safe y Kleen unit was pointed out to us, and it was <br /> stated t at as of July 1993 VFC maintained only one such <br /> unit. W were informed that this unit is serviced by Safety <br /> Kleen ap roximately every six weeks. <br /> Mr. Trev na and I noted the presence of absorbent used to <br /> clean up incidental spillage at the facility. We were <br /> informed hat although VFC had a large amount of this <br /> product, they had not yet generated any waste from this <br /> source. <br /> We then proceeded to the forklift "wash" area. Here it was <br /> explained to me by Mr. Cast that originally, a 3-compartment <br /> clarifier was located underground in this area. VFC did not <br /> use this larifier and so waste was never generated from <br /> this unit. The clarifier was removed and in its place a sump <br /> equipped ith a pumping system was installed. The waste <br /> water flo s into the sump and from there it is pumped to an <br /> abovegroupd sand-filter oil/water separator. After <br /> separatio the effluent flows back into the sump, and the <br /> cycle rep ats itself. From the sump they generate a <br /> sludge/wa er mixture that is pumped out periodically and <br /> hauled as hazardous waste. When the sand filter becomes <br /> clogged o is not efficiently filtering, they backwash the <br /> filter, i a similar manner to a pool filter. This is a <br /> completel closed system, and the only waste generated is <br /> from the umping of the sump. Some evaporation occurs at the <br /> sump surf ce, which helps to reduce the amount of water that <br /> is pumped out with the sludge. <br /> The last rea we inspected was the hazardous waste storage <br /> area. He a we observed that although all drums of hazardous <br /> waste had labels, the labels lacked the generator <br /> informati n on them. Both Mr. Cast and Mr. Kennedy were <br /> informed hat this information was necessary for the <br /> hazardous waste label to be complete. <br /> With the hysical inspection completed, Mr. Trevena and I <br /> accompanied Mr. Cast, Mr. Kennedy and Mr. Savage to the <br /> office where we reviewed the hazardous waste paperwork. Mr. <br /> Trevena fund the employee training documentation to be <br /> inadequat , as well as the facility contingency plan to <br /> contain al outdated emergency coordinator. I reviewed the <br /> manifestsland found that no waste had been manifested in <br /> 1990, probably due to the fact that the operations at this <br /> facility duly began in November of 1989 and all maintenance <br /> of forklifts performed at TVG resulted in the waste being <br /> stored at 'and shipped from the TVG facility. Only Safety <br /> 7 <br />