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C7 <br />3. The contingency plan did not include an evacuation plan for <br />personnel where there is a possibility that evacuation could be <br />necessary. <br />4. The generator had not complied with Division 4.5, Title 22, <br />California Code of Regulations, Chapter 15, Article 10 "Tank <br />Systems", requirements. <br />Pam Violett, Alan Ito, and I arrived at Interlake at approximately 10 a.m. We <br />identified ourselves at the front desk and asked to speak to the individual in <br />charge of the hazardous waste management. At approximately 10:15 a.m., we <br />were approached by Steve Mathias, Industrial Engineer and Peter Eggleton, <br />Human Resource Manager for Interlake. I explained the purpose of our <br />inspection to Mr. Mathias and Mr. Eggleton. Mr. Mathias gave us consent to <br />perform the inspection. <br />The inspection started at the coil storage area where the coiled steel is stored <br />prior to fabrication. Adjacent to the coil storage area is part of the facility <br />referred to as "Fabrication". In this area, the steel is fed through a series of <br />rollers that form the steel into the planned shape. While the steel is traveling <br />past the rollers, a coolant is used to cool the steel. This process generates a <br />wastestream referred to as "roll form coolant". In this area, I observed a five <br />gallon container adjacent to the rollers that appeared to contain an oily waste. <br />This container did not have a lid or a label. Adjacent to the rollers, I observed a <br />55 gallon drum, platinum in color, labeled as "Hazardous Waste Floor Sweep". <br />The label did not indicate the name and address of the person producing the <br />waste. <br />Next to the platinum drum, I observed a 55 gallon drum, green in color, labeled <br />as "Non Hazardous Waste Coolant Sludge". I asked Mr. Mathias how the <br />coolant sludge is managed. He replied, "Chemical Waste Management picks it <br />up". A phone conversation with Peter Eggleton on August 12, 1993, confirmed <br />the roll form coolant sludge is disposed of as a hazardous waste. This drum <br />was not labeled correctly. <br />In the vicinity where the coolant sludge and floor sweep waste was located, I <br />observed a chart entitled "Waste Drum Color Chart" and "Waste Handling <br />Procedures". This chart stated if color of the drum is green, and the waste <br />name is "Bake Paint Over Spray", "Absorbed Wash Tank Sludge", or "Absorbed <br />Coolant Sludge", then the corresponding "waste type" is non hazardous. <br />VA <br />