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The last area inspected was the northem-most part of the facility, near the fence line. Here we examined their hazardous waste storage area, as well as the trailer- type unit that holds all of the facility's spill containment equipment and supplies. This was the last area photographed. With the physical inspection completed, we proceeded to the office to perform the paperwork review. Mr. Trevena examined the personnel training records, and although they appeared more complete than in the last inspection, they still lacked necessary components. Mr. Trevena reviewed the applicable section in Title 22 with Mr. Wilkinson and Mr. Kyle, and they both indicated they understood the deficiencies and what was needed to correct them. Mr. Trevena also examined the facility contingency plan and their City of Stockton wastewater discharge permit, showing an expiration date of 12-31-93. Mr. Kyle indicated they retrieve a sample for analysis each time they discharge into the sewer, and they had not been recently inspected by City of Stockton Municipal Utilities. I reviewed the manifests for all hazardous waste shipped off-site in 1992. I noticed a significant increase in the amount of waste generated for 1992 from the previous two years. Mr. Kyle explained to me that the aboveground tank cleaning process produces a large amount of petroleum/water waste. This operation will occur at least once per tank every five years, but may arise more frequently if the product being stored in the tank has to be modified. For this particular year, tank #6 was cleaned, as well as maintenance performed on the oil/water separator, thus correlating to the substantial increase in this wastestream for 1992. Due to the high variability in the quantity produced from this wastestream, it will be necessary to closely scrutinize, on an annual basis, the amount produced as to accurately classify TOC in the PHS/EHD generator program. IX DISCUSSION WITH MANAGEMENT: Mr. Trevena and I informed Mr. Wilkinson and Mr. Kyle that the only violation noted was the inadequate training records. Mr. Wilkinson stated he would be working on correcting this violation immediately and would forward to PHS/EHD the completed documentation for our review. I asked Mr. Kyle about the status of TOC's Permit by Rule, now known as Tiered Permitting application process. He indicated that I would need to contact Mr. Don Butler, Environmental Specialist for TOC in the Seattle office, to acquire that information. With the inspection completed, Mr. Trevena and I left the premises at 2:30 p.m. X. ADDENDUM: On August 9, 1993, I received documentation from Mr. Wilkinson demonstrating that the personnel training records had been revised to comply with Title 22 requirements. 5