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Renovation of buildings,involving asbestos removal,as well as the removal of electrical transformers <br /> containing PCB's contributed significantly to their waste stream. <br /> According to Mike Escotto,In 1990 the hazardous wastes manifested off site should be of considerably <br /> less volume,and of a different composition. Since the removal of the Mineral and Chemical Division <br /> and site improvements,most of the waste generated at the site will come from machinery degreasing, <br /> machinery lubrication and general site cleaning. <br /> Mr. Escotto said that there was very little waste generated from the materials used in the <br /> manufacturing of the fertilizer. Mr. Escotto stated if there was spillage,or contamination of the raw <br /> fertilizer materials, these materials could usually be recycled back into the manufacturing process at <br /> some point. <br /> After Mr. Escotto explained the general processes at Simplot, he led Ms. Foley and I through the <br /> machinery and maintenance area. There was a mobile aboveground waste oil tank at this location. <br /> At this point,Ms. Foley and I explained the appropriate storage and labeling requirements for waste <br /> oil tanks with Mr. Escotto. We then proceeded to the accounting and records office. <br /> At the records office Mr. Escotto showed us the hazardous waste manifests, and the emergency <br /> preparedness plan. All the hazardous waste manifests were in order and well organized, except for <br /> the waste oil (modified) manifests which were not on file. Mr. Escotto said that the waste oil was <br /> removed from site under manifests, and were on file at the business office. <br /> I received the contingency plan and found that many of the names and addresses and phone numbers <br /> of the responsible employees at the site responsible for emergency response were out of date. At this <br /> time Mr. Escotto was informed that his contingency plan required up dating. <br /> After reviewing the site records,Mr. Escotto led us on a site tour of the hazardous waste storage area, <br /> and the area where hazardous waste was transported in bulk form. All hazardous waste was stored <br /> in barrels, and fiber board containers in good condition, with sealed lids. All the containers were <br /> labeled with identification information, and the date the containers were filled. All containers were <br /> stored on pallets in a warehouse. The last area we inspected was the bulk transportation area where <br /> small but heavy duty Department of Transportation (DOT) steel trailers were stored. These <br /> containers were empty,and they had an expired hazardous waste DOT number on them. Mr.Escotto <br /> informed us that the container with the expired DOT number on it would not be used for hauling <br /> hazardous waste. The personnel training records related to the handling of hazardous waste were not <br /> available for review. The nurse responsible for the records was not present during the inspection, <br /> IX. DISCUSSION WITH THE MANAGEMENT <br /> After the site tour was completed, Mr. Escotto led us to the business office to obtain the waste oil <br /> manifests. The waste oil manifests could not be located. Escotto then led us to the front of the <br /> facility where the inspection was concluded. <br /> I informed Mr. Escotto of the violations which Ms.Foley and I had observed. Mr.Escotto stated that <br /> the contingency plan would be reviewed and updated to provide accurate information, and waste oil <br /> receipts would be mailed to PHS-EHD to verify appropriate disposal. I asked Mr. Escotto if he had <br /> any questions, and he stated that he did not. I informed that he would receiving a copy of the <br /> inspection report. At this time Ms. Foley and I left the facility. <br /> On December 27, 1989 a letter from Mr.Escotto was received with copies of all waste oil receipts for <br /> the year 1989. Mr. Escotto stated that waste oil receipts will now be maintained on site. <br /> 3 <br />