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Called David Hannen and left voice mail for him to call me back. <br />Mr. Harmen returned my call. He informed me that he had the result. Asked to fax me a copy. MK <br />3/4/97 <br />Received message from Mr. Harmen regarding problem with faxing materials. <br />Received fax copy of analytical data. The pump sample is ND. The storm drain sample has 150 WL of <br />Chrysotfle Asbestos. Per Title 22 66261.24, the STLC is 1.0% <br />Per DW consultation, lab is to be consulted. <br />Called lab and spoke with Mark Bailey, Company President, regarding the result. Per Mr. Bailey, it is <br />impossible to maintain it in suspension to analyze for mg/L. The only other way is to redo analysis to <br />include counting fibers and measuring width and length of fibers. Per Mr. Bailey, the EPA Drinking water <br />std is 7 MFL. MK <br />4/24/97 <br />Called and left message for Mr. Bailey of Asbestos TEM to call me regarding the conversion from MFL to <br />percentage as reported in Title 22. MK <br />11/5/97 <br />Conducted routine inspection. Will return to facility tomorrow for record reviewing. MK <br />11/6/97 <br />Concluded the RI. There were several violations, most of which were repeated violations. <br />Per records and discussion with the safety manger and plant manager, I discovered that no one on the plant <br />ever had formal hazardous waste training or was fit -tested for APR. The manager, Mr Dufall, claimed that <br />his men could learn from reading, the formal training or HAZWOPR was not a legal requirement. He was <br />in business for 20 years. He also disagreed with the cradle to grave law when I explained it to him. He <br />claimed that the manufacturer of the chemicals should be partly responsible. Mr. Moreno, Human <br />Resource Manager and Safely Manager, conducted all the training, mostly safety training, he never had any <br />formal training himself, he did not know what APR was. <br />I explained to Mr. Dufall and Mr. Moreno that their staff did not know about hazardous waste management <br />and handling. The problem that they had last year still existed. They claimed that I did not give then time <br />to work on it, they disagreed with me on that. I also advised them to obtain the result of the lab report in % <br />not MFL. Mr. Dufall asked me what % I was looking for. I told him more than 1%, he informed me that <br />"don't worry, we're going to be a lot less than that." <br />Mr. Dufall and Mr. Moreno disagree with the law and regulation I explained to them. They also did not <br />know what a hazardous waste label looks like. I showed it to them in their catalog. <br />They also asked me a lot of questions on how to handle and manage their waste, I answered most of them, <br />then I advised them to take HAZWOPR training, I would not teach them all that. Apparently they did not <br />know the hazardous waste laws and regulations, although they claimed they did; and they did not want to <br />attend any formal training. They claimed they could learn through reading. Advised them to characterize <br />the waste water. <br />Also see OIR. <br />Spoke with Alex Bailey of COSMUD regarding the hazardous waste storage area, the hazardous <br />management and disposal of waste in storm drain and sewer lines. <br />