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We completed the physical portion of our inspection in the wastewater treatment and hazardous waste storage areas in the rear of the facility. Mr. Neal described to us that two metal bearing and one non-metal bearing (defined as less than or equal to .8 ppm copper) wastewater streams flow into the treatment area via different pipes from the production areas. The non-metal stream undergoes a pH adjustment only, while the two metal streams go through the entire treatment process. Mr. Neal informed us that LIKA has reduced water consumption by 33%, and this should reflect positively on their hazardous waste quantities. In this area we also observed the bulk storage tanks; One used to contain the ammonia etchant and the other for the waste etchant. Mr. Neal explained that approximately every two weeks Entech Recovery delivers the ammonia product and, after unloading the product, in turn removes the waste etchant. Once we completed the walk-through of the facility, Mr. Neal directed us back to his office for the paperwork review. Mr.Trevena and I reviewed the facility's employee training records, hazardous waste manifests, waste minimization plan, and contingency plan. All paperwork except for the personnel training records were in order. Mr. Trevena indicated to Mr. Neal that it was necessary to keep documentation of all annual refresher training that the employees have received. Mr. Neal stated he would be implementing a system to correct this discrepancy. We discussed the upcoming tiered permitting steps that Mr. Neal would be fulfilling. The silver recovery and triple rinsing empty containers (the rinsate generated here would be fed into the wastewater treatment) would be categorized under Conditional Exemption. The filter press would fall under Conditional Authorization. Lastly, the metals removal and pH adjustment in the wastewater treatment would be eligible for Permit by Rule. Mr. Neal informed us that City of Stockton Fire Department had last made an inspection in September 1993. City of Stockton Municipal Utilities last inspected LIKA in Spring of 1993, however, an inspector from Municipal Utilities samples LIKA's wastewater discharge approximately once or twice per month. IX. DISCUSSION WITH MANAGEMENT: Mr. Trevena and I discussed the four violations we noted during our inspection. Mr. Neal stated he would correct the violations immediately and send written confirmation to PHS-EHD once they were corrected. With the inspection completed we left the facility at 3:30 p.m. X. ADDENDUM: October 20, 1993 PHS-'EHD received written confirmation from Mr. James Neal indicating all violations noted during the inspection had been corrected, and a new personnel refresher training is currently under development. November 10 1993 1 spoke with Mr. Neal on the telephone to clarify a couple points of confusion relative to the quantity of hazardous waste and production processes. Alan Ito, Cal EPA/DTSC 5