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January 4,2003 Page 2 the inspection tha he will begin using an empty hazardous waste drum found onsite to manage used gaso ' e absorbent and fuel filters. To assist the facili in understanding the requirements for proper management of hazardous waste, 3P is providing the fact sheet for the hazardous waste generator requirements pub ished by California Environmental Protection Agency (Cal-EPA) Department of T xic Substances Control(DTSC)to the facility(Attachment B). In addition, BP will provide the facility with contact information for Belshire Environmental Services, Inc. (Belshire), a hazardous waste transport and disposal company. • Item 11: 6262.12(a)(CCR)Managed a hazardous waste without an EPA number. The Inspection R ort states that the facility managed hazardous waste without an EPA number. In fact, 1he facility has the following EPA identification number: CAL000257265. To avoid future cc refusion on this issue, BP has notified the manager to post the EPA number at the fac' 'ty. • Item 45: 6 265.52(CCR) Contingency plan incomplete. The Inspection Re ort requested the facility to fill out the form provided by the inspector and to post it next to the telephone to be used in an emergency. A completed form has been provided to the manager to be posted near a telephone to be used in an emergency (Attachment C). Please note that afthough Item 45 states that the facility has an incomplete contingency plan, I understand that RCO Facility No. 2130 does not generate more than 1,000 kilograms (kg) of hazardous waste per month and therefore is not required to have a large-quantity generator contingency plan under Section 66265.52. BP requires all of its facilities that generate less than 1,000 kg of hazardous waste per month to maintain the small quantity generator informa 'oval form by the phone as required under Section 66262.34(d). • Request regarding hazardous waste manifests. Finally, the Inspection Report noted that nine hazardous waste drums were observed onsite from SB-989 testing. You noted that all containers were labeled correctly and you requested that BP rovide a copy of the manifests showing proper disposal of these drums to the facility for record-keeping purposes. The drums were manifested and transported by Belshire on November 6, 2002. A copy of the manifests is being provided to the facility per your request. BP maintains copies of manifests for hazardous waste it generates at an offsite depository.