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of waste oil was located which was unlabeled and uncovered (photo 16). In this <br />immediate area was found a barrel which was used for trash disposal, inside the barrel I <br />observed that floor sweepings had been disposed of and contained spilled hydrocarbons <br />(photo 17,18). We enter a shed and I observed what appeared to be a water treatment <br />system for the wash area immediately to the exterior of this building. An inspection of <br />the unit revealed oil waste was being removed from the system for disposal (photos <br />19,20). We proceeded thought the shop area and inspected the storage rooms to the <br />north side of the building. In one room I observed a container of aluminum brightener, <br />the label indicated that it contained hydrofluoric acid (photo 21). In an area on the <br />northeast corner of the building I observed a sandblasting machine (photo 22). We <br />proceeded outside the building and I observed a green 55 gallon barrel labeled as waste <br />antifreeze, no start date was observed on the label (photo 23). Immediately to the north <br />side of the green barrel many unlabeled 55 gallon barrels were observed (photo 24). We <br />proceeded to the driveway area and observed an above ground diesel tank, spillage was <br />observed around the pump station (photo 25). This concluded our walk though <br />inspection and we proceeded to the office area to speak to the owner/operator. <br />I made contact with a Mr. Rod Lawley, who identified himself as the owner. Mr. Lawley <br />stated that he and his father, Donald Lawley, operate business on the site. Mr. Lawley <br />was asked if he had any permits from PHS-EHD for the water treatment unit for recycling <br />the water from the oil sand separator. Mr. Lawley replied that all the work had been <br />done 2 years ago and all the permits were taken out then. Mr. Lawley was asked about <br />the antifreeze barrel, marked waste antifreeze. Mr. Lawley stated that "Snap-On" had <br />provided a recycling unit and this antifreeze was to be reused. Mr. Lawley was asked if <br />he had a permit from PHS-EHD to do on-site recycling. Mr. Lawley stated that he did <br />not get a permit, but that the unit was on a demonstration unit and they did not keep it. <br />Mr. Lawley called to get Mr. Steve Hernadez, the shop operator to talk to us so that he <br />could give us better information about the handling of hazardous waste at the site. Mr. <br />Hernadez arrived and we continued our discussions. I asked about the "Aluminum <br />Bright" which contains hydrofluoric acid, and how did they protect their workers. Mr. <br />Hernadez stated that they wore gloves. I asked if they had a safety plan and training for <br />employees. Mr. Hernadez stated that they had a HMMP, (hazardous materials <br />management plan) which had a safety plan. I informed Mr. Lawley and Mr. Hernadez <br />on the concerns for using hydrofluoric acid for cleaning and the possible influence it <br />may have on the oil/sand separator located at the site. I asked if the oil sand separator <br />had been cleaned out, (pumped). Mr. Lawley stated that they had only been on the site <br />2 years and they hadn't needed to clean in out yet. I asked what was done with the <br />sediment in the water recycling system found on site. Mr. Lawley stated that it had <br />never needed to be pumped out. I asked what was done with the oil which is generated <br />from the unit. Mr. Hernadez they put it back in the unit and the unit degrades it. I <br />asked about the sand blaster on site and what had been done with the used sand from <br />the unit. Mr. Hernadez stated that it went to the dumpster. I informed Mr. Lawley and <br />2 <br />