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where the bulk of BPO's hazardous waste is generated and collected in the <br /> underground sump. <br /> We completed both the UST and hazardous waste generator inspection back in <br /> the BPO office with the paperwork review. Mr. Trevena reviewed BPO's <br /> contingency plan and asked Mr. Krebsbach if the facility had utilized this plan <br /> since the last inspection. Mr. Krebsbach indicated that they had not. Mr. <br /> Trevena and I reviewed BPO's personnel training records, Biennial Report, and <br /> their waste *minimization plan. We were furnished with a copy of BPO's waste <br /> minimization plan. <br /> While reviewing the five manifests generated for 1992, Mr. Trevena and I noted <br /> that land disposal restriction notifications and/or certifications were not <br /> accompanying any of the manifests. The wastes were designated as D018 on <br /> three of the manifests, and as D018/D001 or just D001 on the other two. Mr. <br /> Trevena and I discussed this with Ms. Sue Norton of BPO headquarters on the <br /> telephone. She indicated it was her understanding that LDR <br /> notification/certification was not required for those wastes for which treatment <br /> standards are not available, i.e., D018 is for Benzene for which there is no <br /> current treatment standard. Mr. Trevena informed both Ms. Norton and Mr. <br /> Krebsbach that he would discuss this matter with Cal-EPA, DTSC and get back to <br /> them with a determination. <br /> DI. DISCUSSION WITH MANAGEMENT: <br /> Mr. Trevena and I discussed the findings from both the UST and the hazardous <br /> waste generator inspection with Mr. Krebsbach. We informed him of the <br /> potential for the LDR violations pending consultation with Cal-EPA, DTSC. Mr. <br /> Krebsbach was told that he would be contacted with the outcome. Mr. <br /> Krebsbach indicated he had no questions. With the inspection completed, Mr. <br /> Trevena and I left the premises at 2:45 p.m. <br /> 3L ADDENDUM: <br /> November 9, 1993: <br /> Mr. Trevena spoke with Mr. Alan Ito of Cal-EPA, DTSC who clarified the LDR <br /> requirements as follows: For wastes for which no treatment standard exists, a <br /> LDR notification is required, e.g., DO18. For wastes that have a treatment <br /> standard, both a LDR notification and certification are required to accompany the <br /> manifest to the treatment, storage, and disposal facility. <br /> I telephoned Mr. Krebsbach and informed him of this conclusion. As a result, all <br /> manifests are in violation since none possessed either a certification or <br /> notification. <br /> c: Tim Naprawa, Cal-EPA, Department of Toxic Substances Control <br /> 4 <br />