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Statement of Facts, McCormick & Baxter -4- 16. Groundwater contamination and monitoring data were not available (Section IV.4.(b) . , ISD) . 17. Groundwater monitoring was not implemented as of 19 November 1981, as required by the ISD (Section VIII, ISD) . 18. The oily waste tanks are not inspected by the operator (Section VIII.3. , ISD). 19. The surface impoundments (hazardous waste storage ponds) are not inspected by the operator (Section IX.4. , ISD) . 20. Hazardous waste container storage areas are not inspected by the operator (Section X.4. , ISD) . 21. Waste containers are not closed (Section X.3.(a) . , ISD) . 22. Empty and full drums containing or previously containing a hazardous waste or material were stored in an unapproved location (Section Il.(4). (d) . , ISD) . 23. Hazardous waste is stored over one year, and no fees are paid to the Depart- ment (Section II.(I) .(a&b) . , ISD) . 24. Hazardous waste containers (drums)were not in condition to safely transport, handle, or move (Section II.W .W . , ISD) . 25. Hazardous waste containers (drums) were not stored on an impervious base (section II. (l) . (d) . , ISD) . 26. No hazardous waste labels were applied to the containers stored over 90 days (Section II.W .(c). , ISD) . 27. Hazardous waste containers (drums) are not stored within a secure enclosure (Sections IIJO .(O . , II.W . , and III. W . , ISD) . 28. Hazardous waste containers (drums) are stored in an area without safety shower and eyewash (Section 11. 02 & 13. , ISD) . , 29 . Ignitable hazardous wastes are stored within 50 feet of property line (Section X.W . , ISD). 30. No double containment is provided for hazardous waste storage tank (Section II.M. W . , ISD) .-,, 31. Extremely hazardous wastes are stored in surface impoundments (Section II.. W. W. M. , ISD) . 32. No Closure Plan, Financial Assurance, or Contingency Plan is provided for hazardous waste surface impoundments (Section 111. (13) . , V. ,&VI. , ISD) . 33. Hazardous wastes have been disposed of to land on-site (Sections I.M . W. , 11. (8). , ISD).