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-2 - <br />Inspection Report - GSA <br />Carrier damaged material is held for the carrier to inspect and return. <br />If this is not returned, it is managed with the retrograde materials. <br />The retrograde materials are placed in lots and put out to bid. Material <br />that is not sold or claimed after sale, and spill cleanup residues are <br />disposed of as hazardous waste. Material that is let out to bid is not <br />manifested, nor managed as a hazardous waste. <br />V. Observations <br />The facility was inspected on 15 March 1984. Weather was cool, overcast, <br />and there were intermittent showers. I met with Messrs. Corona, Hayes, <br />Brandt, and Cole and discussed the purpose of the inspection. The "Gener- <br />ator Inspection Checklist" (GIC) provided the structure for the discussion. <br />Violations noted will be discussed below. After reviewing the GIC, we <br />proceeded to Building 213, where records on material handling are maintained. <br />Betty New, Chief of the Production Control Section, provided assistance in <br />this area. A review of the manifests showed hazardous wastes were being <br />stored over ninety (90) days. No manifests were available for shipments <br />prior to 29 June 1983. Since then only one shipment was made (12 October <br />1983), and one was being prepared today. The hauler (I.T. Corporation) <br />refused to deliver the 12 October 1983 shipment (manifest numbers 83142076, <br />83154287, and 83154288) to the facility designated by GSA, saying they were <br />having problems with that facility. They instead took the shipment to <br />their transfer facility. The completed manifests confirming delivery and <br />acceptance by the transfer facility have not been returned to GSA, nor has <br />GSA filed an exception report. Also noted was that GSA has two EPA numbers; <br />one assigned by EPA (CA7 690 506 863) and one issued by the Department <br />(CAX 000 045 765) The State -issued number is currently being used on their <br />manifests. <br />An inspection of the hazardous waste storage area (Lot 212) was conducted. <br />No containment was observed, and hazardous wastes were not stored on an <br />impermeable base (i.e., solvents stored on asphalt, photographs 1 thru 6). <br />None of the hazardous waste containers had labels (photographs 7-12). Ms. <br />New stated the hauler did not want labels placed on the containers until <br />they came in to pick them up. Mr. Corona stated the bid lots could con- <br />tain any item up for sale, and the lots were assembled without regard to <br />compatability. No hazardous waste signs were posted. <br />The maintenance area in Building 510 was inspected. Jim New, MHE Shop <br />Section Chief, said that waste engine and hydraulic oils went into the <br />same containers. There has been no analysis done on these oils, including <br />PCB analysis. Solvent sludges, waste oils, and waste caustic cleaner <br />are stored in Lot 212. These were stored next to, and assumed to be part <br />of, several barrels identified as empty during the inspection. None of the <br />barrels in that lot, nor those in the shop, had hazardous waste labels on <br />them (photographs 13-15). Mr. New was unable to provide receipts for <br />waste oils picked up. He said that waste oils were last picked up by <br />