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FEB-27-94 SUN 9:05 P, 03 <br /> David J. Ir.ey, Esq. <br /> F'ebruar'y 18, 1994 <br /> Page - 2 -- <br /> for hydrocarbons. The test will provide us with the proportions <br /> of water and oil(?) which should definitively answer the question. <br /> Please note that Falconts field notes (provided earlier) <br /> accurately trace the origins of everything in the Report. Since <br /> I assume you and PHS do not want to have to continuously review the <br /> field notes, perhaps we should discuss whether or not you would <br /> like some sort of weekly report produced while work is being <br /> performed. <br /> 3. Whether or not waste oil is considered hazardous? <br /> Contrary to the statements of Mr. Cummings regarding the <br /> hazardousness or toxicity of the fluids he tested, Z-M and Falcon <br /> are handling all fluids containing diluted hydrocarbons as <br /> hazardous. Such fluids are/shall be manifested and hauled by a <br /> licensed carrier which takes the fluids to an incinerator. It is <br /> my understanding that such fluids are mixed (fuels blending) and <br /> then injected into the incinerators. <br /> Now that you have the Report, the January 31, 1994, Cummings <br /> report and the October 23, 1993, Cummings report, I believe you <br /> have all the current chain of custody and testing information. <br /> Similarly, the disposal methods are also contained in the Report <br /> with the above clarification of "fuels blending." Carriers of and <br /> destinations for the materials being disposed of are or will be as <br /> shown on the appropriate manifest. <br /> 5. Why is antifreeze being incinerated rather than recycled <br /> through the Z-M shop? Rather than treat antifreeze that was in the <br /> landfill as if it had simply come out of a vehicle in the shop, <br /> Z-M and Falcon decided to dispose of it as a waste from the <br /> landfill. I believe it is cheaper to add it to a drum destined for <br /> incineration then recycle it through the shop. <br /> 6. Use of paint found in the landfill. Contrary to the <br /> Report, Z-M shall treat the paint as all other hazardous Fluids <br /> discovered, by proper disposal. <br /> 7. The white granular material in DR6. Z_M has tentatively <br /> described this material as a fungicide used on the ranch. Tests <br /> will be conducted to confirm this. if confirmed, it will be <br /> disposed of according to the applicable laws or regulations, and <br /> not pursuant to information received from the County Ag. <br /> Department. <br /> 8. Disposal of oil rags, wood, and metal (item 10 on the <br /> Report) . These items were separated from the non-hazardous trash <br />