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According to Maureen Daggett, the waste water from Core Washing Area is drummed, then placed in the <br />treatment unit, where it is filtered and reused on site. The accumulation on site was from the period when <br />the water treatment unit was down. Filter media has never been removed, it was backflashed and reused. <br />The system was installed approximately in June 1998. Prior to that, the oven was used to incinerate it. Mr. <br />Moreno also confirmed the above info. <br />When I asked about the waste in the drums in 1997, Ms. Daggett interjected and advised Mr. Moreno not to <br />answer that question. <br />When I asked Mr. Moreno about the waste stream, Ms. Daggett answered it for him. Per Ms. Daggett, <br />there are 3 waste streams, the brake fluid, waste water and sludge; QBR is in the process of obtaining <br />POTW permit; the sludge is manifested as asbestos. Prior to the water treatment plan, waste water was <br />incinerated and sludge was placed with asbestos for disposal. <br />According to Mr. Moreno, the mop water is taken to the treatment plant; the blast bead, after being used, is <br />collected in the dust filter and placed in the asbestos bin. The copper ring and brass rivets go as scrap metal <br />by an scrap hauler. <br />When I asked Mr. Moreno about the incinerator, Ms. Daggett answered "there was no incinerator, they <br />used oven to burn it, it was not an incinerator." At this point, I informed Ms. Daggett that she had been <br />answering the question for Mr. Moreno; she was interfering with my inspection. She responded, "I am his <br />representative, am I not?"; Mr. Moreno knotted his head confirming it. The inspection was then <br />suspending pending the advice from my supervisor regarding the interfering from Ms. Daggett. <br />After several phone calls, DW, supervising REHS, came to site to assist in completing this inspection. <br />The inspection was resumed. Except where provided by others, Mr. Moreno informed us the following: <br />1. Ms. Daggett informed us that only the drum that sample came back hazardous would be hauled off as <br />hazardous waste 121, oily water with heavy metals. DW advised Ms. Daggett and Mr. Moreno that the <br />samples were the representative samples, if they came back hazardous all drums would be considered <br />hazardous. DW then asked how the waste would be hauled. Ms. Daggett replied that the waste would <br />be transferred into hazardous waste tanker with individual manifest, and Prime Environmental, out of <br />southern California would pick it up; she did not know the destination. DW asked for a copy of the <br />manifests. <br />2. Sludge from part washers was removed every 3 weeks, it was doubled -bagged and managed as <br />asbestos. Sludge from caliper washer and brake washer was managed the same as asbestos. <br />3. The whitish grayish water might be from mop water. It would be separated. <br />4. The sediment form black tank in the water treatment area was removed once. It was bagged and <br />managed as asbestos. <br />5. The bead blasting steel shot was recirculated till it became powder. The powder was collected in dust <br />collector, bagged and managed as asbestos. <br />6. The backwash from the filter in the water treatment plant stayed in the system. <br />7. The floor scrubber was handled as mop water. <br />8. Per Ms. Daggett, the wash water was placed in the water treatment system. It was reused. The water <br />in the drums was from the ups and downs of the pump. <br />9. The brake shoes from the debonding area was bagged and handled as non -hazardous waste. No <br />sampling or testing was done. Some of the rivets were not steel, they were either brass or copper. <br />They were also handled as non -hazardous waste without sampling or testing. Per Peter, the brake shoe <br />might contain 20-25% asbestos. <br />The inspection would be concluded tomorrow on 10/7/99. MK <br />10/7/99 <br />Returned to site to conclude the inspection and reviewed records. Provided Unified Hazardous Waste <br />Inspection Report to Mr. Moreno, who signed receiving it under protest. <br />See inspection report for details. MK <br />10/18/99 <br />Received a copy of manifest, dated 10/15/99, for 5000 gallons of non-RCRA hazardous waste. MK <br />