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10/1/99 Conducted routine inspection this date with Vedal Pedraza of EHD, Joseph Moreno, Human Resources Manager, and Pedro Warren, Plant Manager, of QBR. There were several violations, some of which were repeated. During the inspection of the water treatment area, I noticed the drums that were similar to those of waste water from 97 and 98. I asked Mr. Moreno about the waste water from 97 and 98, he informed me that it was reused in the part washer, it was heated and evaporated. There were several, unlabelled drums near gate and pond. Per Mr. Moreno, "it's non-RCRA and non -hazardous". The drums were as following: 1. Near gate: 34 x 55 gal. drums of waste oil and others. 2. Near pond: 5 x half -full 55gal. open drums, 55 x half to '/4 full 55 gal. drums, 5 x 5 quarts containers of what appeared to be waste oil. 3. Hazardous storage area: 48 drums of what Mr. Moreno claimed to be waste water. All drums were not labeled. At this point, Mr. Moreno asked me to make an appointment to come back later. He also gave me the analytical result that clearly showed the waste was hazardous. I then asked him for permission to sample. He informed that he needed to discuss it with Pedro. I spoke with Mr. Pedro Warren and asked him for permission to sample. He wanted to consult the top first. He then asked Vedal and me to leave the room. At 3:50PM, Micheal Hakeen, Counsel for QBR, informed me, via phone, that he wanted to look at the code and asked me to revisit on Monday. I informed him that I would like to sample it today. He informed me that "you are wasting time by hanging here." After consulting with DW, I asked Mr. Warren to call Mr. Hakeen for me. After I advised him that I would like to sample today, he told me that "I can't drop every thing to go there for you...". I informed him that I was not there for the argument, I would like to know if I had permission to sample. He answered in a raised voice "No permission. I'm not going to advise my client to give permission." Discussed the situation with DW. I was in the parking lot when Mr. Warren came to me with another guy and informed me "you can do what you want. Go ahead. Let us know what we need to do." Collected 2 sets of 9 samples each, labeling set A and B. Set B was given to Mr. Warren with chain of custody. Each sample evidence tape. The inspection was suspended due to lack of time and all other interruption. Inspection will be resumed on 10/5/99. MK 10/4/99 Ms. Maureen Daggett of Environmental Compliance Management Services (ECMS) called to inform that she was QBR Compliance Consultant, she was on board 2 weeks ago. She also advise me that she would be there (at QBR) for the inspection tomorrow and that the inspection needed to be done by 3:30; she had an appointment with legal counsel at 4:OOPM. MK 10/5/99 A representative from GeoAnalytical picked the samples. Arrived at site. Mr. Moreno asked me to wait for approximately 15 min. before he allowed me to proceed. He then introduced me to Ms. Maureen Daggett, QBR Consultant, of ECMS. She began by questioning me the following: type of inspection, when was last inspected, the sampling and names of my supervisor, director of EHD and director of PHS. Then she discussed the analytical result that QBR had; she claimed she had 25 years in chemist background. She then asked me to describe each violation in detail, including the color of the spill. I asked her if he was a lawyer; she responded "it doesn't matter if I'm a lawyer or not, you have my card; I represent my client." She asked me the same question, "is this a routine inspection?" several times. She claimed that it appeared to be beyond a normal routine inspection. I asked Mr. Moreno if Joe Chavez should be here, Ms. Daggett interposed, "NO". According to Mr. Moreno, approximately 4 drums of brake fluid is generated per quarter. It is collected and placed in the drum in the back where Rust Arrest is stored. Ramos Environmental manifested it out.