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2 . BPO generates a similar water/hydrocarbon hazardous <br /> waste from the above ground tank "bottoms" resulting <br /> from water intrusion from rain, etc. Approximately <br /> once a year roughly one inch is drawn off from each <br /> tank bottom. This waste is collected in a 6, 000 gallon <br /> underground tank, and is also hauled by Ericksen to <br /> Gibson for recycling. The tank is emptied as soon as <br /> the waste is collected. The amount of waste generated <br /> from this point source is included in the quantity <br /> stated in 11 above. <br /> 3 . Another potential source of hazardous waste, although <br /> none to date has been manifested, are the absorbent <br /> pads and booms used for spill clean up at the loading <br /> rack. <br /> VII. VIOLATIONS: <br /> #1 A Land Disposal Restriction (LDR) notification was not <br /> accompanying manifest #90900696. <br /> VIII.OBSERVATIONS: <br /> Mr. Trevena and I arrived at BPO at 10: 00 a.m. Upon <br /> arriving we met Mr. Jeff Withrow who identified himself as <br /> the Terminal Manager. Mr. Trevena and I explained the <br /> nature of our appointment, and requested permission to <br /> perform the inspection. Mr. Withrow indicated he would have <br /> no objection to our inspection. <br /> Mr. Withrow briefly explained the operations of the bulk <br /> facility and the hazardous waste they generate. At this <br /> point virtually all hazardous waste generated at the site <br /> consists of a water/fuel mixture. Mr. Withrow indicated <br /> that although there is a potential generation of hazardous <br /> waste with the use of absorbent pads and booms, the need has <br /> not yet arisen to utilize these materials. <br /> Mr. Trevena and I performed the first part of the inspection <br /> in the office reviewing paperwork. There was only one <br /> hazardous waste manifest for 1990, but there were several <br /> for 1991. Although the manifests appeared to be in good <br /> order, one LDR was missing from one of the manifests for a <br /> D018/D001 waste. Mr. Trevena informed Mr. Withrow that it <br /> is necessary to retain all LDR's with their appropriate <br /> manifests. Mr. Withrow was asked if the facility had ever <br /> utilized their contingency plan. Mr. Withrow indicated that <br /> they had not. While Mr. Trevena and I were reviewing BPO's <br /> personnel training records, Mr. Withrow indicated that <br /> hazardous waste training is given prior to a new employee <br /> beginning their duties, as well as an annual refresher. BPO <br /> had a copy of their Biennial Report on site. <br />