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the barrel was manifested off site every two weeks. One barrel was next to the turned over barrel and did not possess a hazardous waste label. Mr. Smith was asked how he could identify this barrel as product or waste. Mr. Smith stated " the red plastic protective covers had not been removed and therefore it was an unopened product" . We then proceeded to inspect the south portion of the outside shed area. It was noted that large plastic bags were around the rear area with hazardous waste labels on them. Mr. Smith indicated that this material was the copper sludge and heavy metal waste. This material was placed in the bags in a dry state. Further inspection of the southeast corner of the shed area revealed a white, five gallon bucket and a black, 25 gallon barrel stored inside the cement berm. It was noted that neither of these containers had any labels on them. The 25 gallon black container had a damaged hazardous waste label on it which had been mostly scratched off. Mr. Smith was asked what this product was. Mr. Smith replied that he did not know. No accumulation date was evident on the portion of the label still remaining. Just to the east of the cement bermed area were several large barrels with small barrels stored in them. It was noted that wood impregnated with chemicals (blue green stains) was found stored in the barrels. Mr. Smith was asked about the wood and barrels. Mr. Smith stated the barrels were to be cleaned and then cut up. Several portions of plastic barrels were evident next to this area and appeared to be cleaned. Further investigation of the barrels revealed that one of the barrels was over half filled with liquid. Dennis Fields, OEs, tested the liquid and noted that the liquid had a low PH (approximately 1) . Mr. Smith was informed of the liquid in the barrel, and the contaminated wood. Mr. Smith stated that he was well aware that the wood impregnated with heavy metals and other chemicals would have to removed as hazardous waste. One of the 55 gallon barrels had its lid cut off. This unlabeled barrel was about 2/3 full of a waste liquid which was field tested by Dennis Fields and found to have a ph of 1.0. Mr Hunt asked Mr. Smith if this material was an acid waste. Mr. Smith replied "it must be" . After this barrel was discovered and tested for ph, Mr. Smith turned to Mr. Hunt and said " I 'm in deep shit, aren't I ? " . On top of the liquid, solid wastes were floating. Mr. Smith also was informed that the floating waste in the barrel would also have to be removed under a manifest as hazardous waste. After sampling this barrel, Mr. Smith had the liquid removed to the treatment plant. It was then noted that the barrel had approximately 3 inches of sludge in the bottom. Mr. Smith was informed that this material would also have to be removed as hazardous waste.