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\r *40 VIII. OBSERVATIONS: Mr. Trevena and I arrived at TOC at approximately 12:OOpm. Upon arrival,we met Mr. Charles Kyle who informed us he was the terminal manager. Mr. Trevena and I explained the nature of our inspection. We then requested and received permission to perform the inspection. Mr.Trevena and I first reviewed the facility's hazardous waste manifests for 1990 and 1991 to determine if they still were a generator of more than 5 tons. Our review showed the facility generated only 450 pounds in 1990, however, in 1991 they produced 29.35 tons of hazardous waste. Mr. Kyle explained to us that the tank cleaning process produces a large amount of petroleum/water waste and 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. Without this waste TOC may not fall into the category of a generator of greater than 5 tons. Mr. Trevena and I explained to Mr. Kyle that PHS-EHD would continue to review and evaluate TOC's hazardous waste stream on an annual basis to determine their eligibility for PHS-EHD's hazardous waste generator program. Mr. Trevena and I then examined TOC's contingency plan, City of Stockton wastewater discharge permit, and lastly their personnel training documentation. Although TOC had their employees' certificates from their hazardous waste 40 hour training displayed to verify completion of the training program, they lacked specific documentation as outlined in Title 22 in terms of job title, job description, etc. Upon completion of the paperwork review, Mr. Kyle escorted Mr. Trevena and I out to the tank farm area. There, Mr. Kyle explained how the sump/separator/filter/discharge system operated. We observed the 4 55-gallon drums used to contain the carbon filters in the treatment process. Mr. Kyle explained that the waste stream flows through the drums (filters) and once the filtering capability is exhausted, the drums are hauled away as hazardous waste. On site were 2 additional drums containing product filters. These drums are maintained as back-ups. IX. DISCUSSION WITH MANAGEMENT: Mr. Kyle was asked about the status of TOC's Permit by Rule process. I stated that PHS-EHD records indicated the last communication from Cal EPA/DTSC was a request for additional forms (8462A and 8462B) to be submitted by April 1, 1992. Mr. Kyle was not familiar with this process, and telephoned TOC's headquarters in Seattle. Mr. Kyle had me speak with Mr. Don Butler regarding this matter. Mr. Butler faxed a letter he had received from Cal EPA/DTSC to Mr. Kyle stating the deadline for submittal of the additional forms was extended to January 1, 1993. Mr. Butler indicated TOC would have all applicable documentation submitted to the state by this new deadline.