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Amendment to Statement <br /> of Facts <br /> 1 During the August 2, 1983 inspection, several hundred drums of hazardous <br /> wastes were observed at an unauthorized point, and had been there for several <br /> years according to McCormick and Baxter employees. Removal of these wastes <br /> were to be accomplished in accordance with specific written instructions from <br /> the Department (See exhibits Q, R and S) . Prior to movement of these wastes to <br /> an approved location for subsequent disposal contents of all chemicals were to <br /> be analyzed. McCormick and Baxter failed to fully comply with these <br /> instructions. <br /> 2 As part of negotiations to reach a mutual settlement with McCormick and <br /> Baxter a two—phase site investigation plan was developed in early 1984. <br /> Settlement negotiations were extended pending completion of this investigation <br /> provided that the submitted schedule was met. The Phase I report, due April <br /> 13, 1984, has not been submitted. Preliminary results from groundwater samples <br /> taken by the Central Valley Water Quality Control Board staff show high levels <br /> of contamination from polynuclear aromatic compounds (PNA's) , pentachlorophenol <br /> (PCP), arsenic and chromium. <br /> 3 <br /> M. Laboratory Results — dated October 18, 1983 by HML. Further results of <br /> samples taken on August 5, 1983. <br /> N. Revised Site Mitigation Plan — dated January 13, 1984 by CHpM—Hill. <br /> 0. Plan Approval — dated January 25, 1984 by Brad Parsons. <br /> P. Site Investigation Schedule — dated February 16, 1984 by Brad Parsons. <br /> Q. Drum Removal Plan — dated August 10, 1983, by McCormick and Baxter. <br /> R. Drum Removal Approval — dated August 19, 1983, by Jim Stahler. <br /> S. Drum Disposition — dated September 9, 1983, by McCormick and Baxter. <br /> 4 <br /> 6. Pamela Schiro, Public Health Chemist, Dept of Health Services, *Hazardous <br /> Materials Laboratory, (415) 540-3003; will testify to contents of Exhibit <br /> K. -- <br /> 7. Jarnail Garsha, Public Health •Chemist, Dept of Health Services, <br /> Hazardous Materials Laboratory, (415) 540-3003; will testify to contents of <br /> Exhibit J. <br />