Compliance evaluation inspection rpt, w/marginalia · analysis plan; and 11) no accumulation start...

POOR LEGIBILITY

ONE OR MORE PAGES IN THIS DOCUMENT ARE DIFFICULT TO READ DUE TO THE QUALITY OF THE ORIGINAL

DEPARTMENT: OF TOXIC SUBSTANCES CONTROL 1011 N GRANDVIEW AVENUE

GLENDAIE. CA 91201

(818)551 2800

SFUND RECORDS CTR

5091-00002

; I' I r i>. • _•

f ^ROOOG

COMPLIANCE EVALUATION INSPECTION REPORT

. Enviropur West Corporation (formerly known as Petroleum Recycling Corporation)

1835 East 29thi Street Signal Hill, CA 90806 EPA ID # CATO80011059

Inspected by: Larry Stuck Dates Inspected: November,6, 7, 15, 21, 1995

Date of Report: December 21, 1995

Enviropur West Corp. Nov. 6, 7,15, 2 1 , 1995 Page 2

I. PURPOSE:

To conduct a Compliance Evaluation Inspection (CEI) of a facility performing oil recycling by blending oils into fuels. Enviropur West Corporation (EWC), formerly known as Petroleum Recycling Corporation (PRC), has an Interim Status Document (ISD) and has submitted Parts A and B of the permit application to the Department of Toxic Substances Control for a Treatment, Storage and/or Disposal (TSD) Facility Permit.

II. REPRESENTATIVES PRESENT:

Department of Toxic Substances Control (Department):

Larry Stuck, Hazardous Substances Scientist (HSS) Ann Iaali, HSS il/6,7,15/95

Enviropur West Corporation (EWC)%

Mike Petty, Compliance Manager., 11/6,7,15,21/95 Robert Rowden, REA, Compliance Manager 11/6,7,15/95 Phil Goodman, Vice President of Operations 11/21/95 Mario Quezada, Corporate.Safety Manager 11/6,7,21/95 Mike Fox, Drum Staging Area Manager 11/6/95

-Bob Jackson, Plant Manager 11/6,7,21/95

III. OWNER/OPERATOR:

This facility is owned and operated by Enviropur West Corporation.; Prior to February, 1994, the.facility was owned and operated by PRC.

IV. BACKGROUND: : .

EWC is located at 1835 East 29th Street, Signal Hill. The facility; occupies approximately 3 acres (Attachment 1). The facility employs about 15 to 20 employees, which includes maintenance workers, lab technicians and clerks.

From the 1950's until 1973, the facility was used for the refining of lubrication oil. Since 1973, the facility has

: been usedfas a waste oil'recycling facility servicing the petroleum refineries, military facilities, railroads, aerospace industries, auto repair shops and gasoline stations. Since December 1990, the facility has been treating other hazardous wastes, in addition to waste oil, as specified in their revised ISD. This activity includes oil/water separation, waste water treatment, fuel blending,

Enviropur West Corp. Nov. 6, 7 , 15, 21, 1995 I Page 3 ;

t

ana dewatering. The facility also acts as a broker in the •weste.-as-fuel business. , • .

Petroleum Recycling Inc. (formerly McAuley Oil) leased the facility from C.S. McAuley, the sole owner, until 1987. In 1987, PRC was purchased by the following stockholders: DMI, Del Parker, Jim Einess, and Rich McAuley. In February, 1994, PRC filed bankruptcy arid was. taken over by EWC.

A. Surveillance History ;

" ' ! ' On March 16, 1984, Mary Cooper, of the Department, conducted a visual site 'inspection as part;of the permitting process. She found the following violations: 1) illegal disposal of hazardous waste on-site; and 2) failure to install a continuous, impervious containment base. On April 19, 1984, a Notice of Violation (NOV) was issued to the facility

• for the above violations.

On August 20, 1987, Stevjen Layinger, of the Department, inspected the facility and found the following violations: 1) failure to label hazardous waste containers; 2) failure to install an impervious base under their waste pile; 3) no hazardous waste warning signs; 4) failure to record inspections in a written inspection log; 5) failure to maintain individual training records; 6) failure to submit the facility contingency plan to locajl authorities; 7) no evacuation plan in the contingency plan; and 8) failure to amend the list of emergency coordinators when the coordinators changed. ' ' •.,,

On August 28, 1987, Christopher-Marxen, of the Department's Financial Responsibility Unit (FRU), reviewed the financial responsibility documents submitted by the facility. He found that the facility did not have liability coverage for sudden and non-sudden accidental occurrences? and no financial assurance for closure costs. An NOV was issued on September 15, 1987 for these violations.

On February 10, 1989, Diana Thomas, of FRU, conducted a financial responsibility! review. A Corrective Action Order was issued on March 8, 1989 regarding liability coverage for sudden and non-sudderi accidental occurrences. The Order was settled on September 22, 1989, withithe facility agreeing to pay $3,500.00 in penalties. j

Enviropur West Corp. Nov. 6, 7, 15, 21, 1995 Page 4

On February 17, 1989, Romeo "Skip" Ricarte, conducted a CEI inspection of PRC. On April 6, 1989 a report of violation (ROV) and schedule of compliance was issued to address the following violations: 1) failure to submit a contingency plan to local and state agencies; 2) no evacuation plan in the contingency plan; 3) failure to amend the list of emergency coordinators; 4) no job description for each position in the training plan and records; 5) no adequate secondary containment for hazardous waste storage tank and container storage area; 6) no sign nor NFPA markers on the hazardous waste tank; 7) no emergency communication or alarm system; 8) no 24-hour surveillance system or barrier to secure the facility; 9) time of inspection was not included in the inspection logs; 10) inadequate waste analysis plan; and 11) no accumulation start date visible on each hazardous waste container. On April 28, 1989, an amended ROV was issued to include the financial responsibility violation found on February 10, 1989. On October 5, 1989, a follow-up inspection determined that the facility was in compliance. \

On February 28, 1990, Stephanie McEwing of the Department inspected the facility and found the following violations: 1) no land disposal restrictions (LDR) notification or certification attached to the manifest with LDR waste; 2) some manifests were missing EPA waste code; 3) no written job description in their training plan and records; 4) no training records for their hazardous waste truck driver; and 5) no hazardous waste warning sign posted on.the?back*barrier of the facility.

On March 12, 1990, two Fieldi Orders (Toxic Tickets), FO 89/90-356 and FO 89/90-320, were issued to PRC because the facility transported hazardous waste without carrying a valid registration. •

On March 12, 1990, a truckstop inspection indicated that facility had illegally disposed hazardous waste on the ground. The case was combined with a civil case pending at that time. Ar: -

On July 17, 1990, another Field Order, FO 90/91-4-400, was issued during the truck stop inspection for training and drum management violations, and settled on July 24, 1990 for $900 penalty.-

On November 5, 1990, the Department conducted an annual CEI, and numerous violations were discovered. A ROV


was issued on December 15, 1990 to address the following violations: accepting new waste streams without the Department's approval; inadequate waste analysis plan, training plan, contingency plan, and closure plan; lack of emergency equipment, barrier for security, and a waste as fuel notification form; plus there were operational management problems regarding drums, tanks and secondary containment.

On September 10, 1991, the Department conducted an enhanced surveillance inspection and numerous violations were discovered. An ROV was issued on December 20, 1991 to address the following violations: managing hazardous waste not specified in the Part A application; failure to retain copies of LDR notification; failure to develop a written inspection schedule for each tank; failure to include TCLP in the Waste Analysis Plan; and failure to maintain an operating record.

The.Department performed additional inspections in 1991 and 1992. Violations discovered during these inspections were included in a civil case pending at that time.

On January 29, 1993, the Department conducted ^n annual CEI, and numerous violations were discovered. An ROV was issued on March 12, 1993 to address the following violations; accepting new waste streams without Department's approval; certification of recycled oil

. perfprined by :an uncertified laboratory; employing processes.not specified in the Part A application; inadequate waste analysis;plan, inspection logs,

.training records, operating records, and contingency

..plan';* failure to adjust the closure cost estimate annually; lack of emergency equipment, and barriers for security; plus there were operational management problems regarding drums, tanks and accumulated water

-iri>the secondary containment.

Oni May, 6,1993, the. Department conducted a complaint inspection and observed, 6,violations. An ROV was issued on August 10, 1993 for the 6 violations.

On October 27, 1993, Christopher Hendrix of the Department conducted a CEI inspection.

On December 10, 1993, an ROV was issued citing 10 violations observed during the October 27 inspection.

i i


On December 21, 1993, Chris Hendrix and Mark Fuentes of the Department investigated a fire and release of hazardous waste at the facility.

On February 14, 1994, an ROV was issued citing 3 violations: failure to use controls to prevent spills or overflows from tanks, failure to provide immediate access to emergency communication and/or alarm system and improper handling of ignitable wastes.

On August 2, 5, 12, 26 & 31, 1994, Larry Stuck of the Department conducted a CEI inspection.

i

On September 15, 1994, an ROV was issued citing 14 violations observed during the August 1994 inspection.

On December 20, 1994, an Amended ROV was issued deleting 1 violation and adding 3 violations.

On February 8, 1995, an Addendum to Amended ROV was issued citing 1 violation.

On October 16, 1995, a civil complaint was filed in Superior Court by the Attorney General's Office on behalf of the Department regarding violations found during the 1994 and 1995 inspections at EWC's Signal Hill and Patterson facilities.

B. Permitting History

On March 13, 1979,^McAuiby (Oil ; Company submitted an operating permit application to the Department.

On June 11, 1981, McAuley Oil Company submitted a revised Part A application to the Department.

On July 30, 1982, the Department issued an Interim Status Document (ISD) to McAuley Oil Company for treatment and storage of waste oil.

On May 4, 1983, the Department extended the deadline for Part B (hazardous waste facility operation plan) submittal. • >'

On September 6, 1985, Petroleum Recycling Inc. (formerly McAuley Oil Co.) submitted a revised Part A application, informing the Department of the change in owner/operator and.name of the facility located at 1835 E. 29th Street, Signal Hill, CA: The revised Part-A also included the following changes: 1) increased

Enviropur West Corp. Nov. 6, 7, 15, 21, 1995 ; . Page 7

storage capacity for tanks; 2): various RCRA "U" wastes had been deleted; and 3) off-site hazardous waste storage in containers was also deleted because the facility had never conducted this activity.

On June 24, 1987, PRC 'submitted a revised Part A application to increase its treatment and storage capacity, and to add various California only hazardous wastes to its waste acceptance list.

In April 1988, PRC submitted a Part B application (operation plan) for the Department's review.

On July 18, 1988, the Department issued a revised ISD identifying the above changes to the facility's operation and reflect the1change of ownership and name.

In April 1990, the facility submitted an amended Part A application according to the new EPA's TCLP rule. In addition to those organic,constituents identified in the TCLP rule, the facility, also included F-listed wastes, K wastes, and other wastes which were not previously identified.

On December 21, 1990, the" Department issued a letter to address the changes in PRC's ISD. Additional hazardous waste codes & maximum allowable; quantities were added to the facility's acceptance list.'

On March 3*, 1993, the Department issued a letter to address the changes to.PRC's;revised?Part A-application dated October 5, 1992Additional hazardous waste codes and maximum allowable quantities?of F003 and F005 waste streams were amended. : V

On March 2, 1994, Jose Kou of. the Department sent PRC a letter to clarify certain issues unresolved from the March 3, 1993 letter. This March 2 letter was ruled invalid by a Judge in bankruptcy court because the removal of the subject equipment/processes; could force PRC out of business and prevent PRC from paying their creditors. • ;?•?'. '

On October 25, 1995, EWC submittedaRevised PartB application. "" ;V

Department Region 3 permitting staff are currently reviewing (technical review) the facility's Pa^tB V application.


V. Hazardous Waste Status

PRC was issued an Interim Status Document for storage in containers, and treatment- and storage in tanks (Attachments 6 & 7). EWC is a registered hazardous waste hauler. Besides accepting wastes as a TSD, EWC acts as a transfer station for some hazardous wastes. EWC generates hazardous waste on-site. EWC's laboratory was certified by the Department of Health Services' Environmental Laboratory Accreditation Program (ELAP) on April 7, 1995 (see A t t a c h m e n t 1 6 ) .

VI. Hazardous Waste Activities

EWC's tank storage capacity is 862,260 gallons according to the 1990 Part A. The allowable quantities for treatment in tanks (T01 - oil/water separator) is 862,260 gallons annually. The allowable quantity for thermal/chemical treatment (T04 -heat and chemically enhanced de-emulsification) is 240,000 gallons.

Facility Processes:

EWC processes the following hazardous wastes at the Signal Hill facility:

Waste Industrial Oil: The facility considers waste oil that has a water and solid (BS&W) content less than 20% to be a commodity (used oil). Waste oil with low BS&W, (which EWC considers clean fuel or dry oil) is pumped into the 600 series tanks. After gravity separation, the facility blends wet oil with dry oil to meet the market specification (such as metal content and BTU value).

Waste oil with high water and solid content (wet oil) is stored in other 600 series tanks, except tank 601 which is used for wastewater storage. After overnight gravity separation, the oil phase is heated to 180*F with one hour retention time to enhance separation. Chemicals like tretolite de-emulsifier, or other surfactants are injected (about 1500 to 2000 ppm) to break emulsions.. After a second gravity separation, the treated wet oil is combined with the dry oil in the used oil program. Oily water and sludge are further treated before final disposal.

Note: EWC no longer accepts used crankcase or motor oil except from local residents as a free service to the community. This small quantity of household oil is periodically pumped from a 500 gallon receiving tank into the 600 series tanks with industrial oil.

ts


Oily Water/Solids: The oily wastes with high water and solid content are unloaded into half-tanks HT-2 and HT-2A. Tank HT-2 is equipped with a metal screen to separate large debris. The solids settle out in HT-2 and the liquids flow over and into tank HT-2A. The half-tanks are cleaned out periodically and the waste solids are placed in roll-off bins and shipped off-site for land disposal. Except for the 400 series tanks, all tanks in,the facility can be used to store the oily water. Oily wastes are pumped to the centrifuge (used to be the MX units). In the centrifuge, the solid phase is ejected and : dropped into a roll-off bin, while the centrifuge liquid is.piped to the wastewater treatment system; Depending on the waste stream, some solids are further solidified before land disposal.

Wastewater: The wastewater isjpumped into a 3000 gallon surge tank (R3) before it is fed into the wastewater treatment system (WWl). The first stage of WW1 is a oil/water separation unit (weir design, without oliphilic coalescing coating or chemical adding). At the next stage, two agitating tanks are used to adjust the pH so" that .metals can precipitate. The wastewater is then gravity fed into dissolved air floatation (DAF) devices to remove volatile organic • compounds. Wastewater then flows through two mixing tanks (one flush and one slow mixing tank) where permanganate, ferrous sulfide or polymer are added to eliminate oxygenated hydrocarbons such as phenol. Next, the water flows into two clarifiers to separate any residual oily water and solids. The last stage is a sand filter (back-flushed once every eight hours) where more particulate debris is removed.

Wastewater passing through thejtreatment system is stored in tank1 #1001 or #301 for a quality check. Once verified to comply with sanitation discharge requirements, the wastewater is pumped into batch tanks VI anc* V2 before it is discharged to the sewer. If tanks #1001 and #301 do not meet the sanitation requirements, 75 ppm oil & grease and 5 ppm halides, the water is pumped back to tank R-3 and re-run through the system. The sediment in the wastewater treatment system is cleaned out periodically. The duration of clean-up depends upon the waste fed into the system. It Varies from once every four hours to every twelve hours. The sludge is then run through the centrifuge with other oily waste. ;

Fuel Blending: Wastes with high halide or solvent content and RCRA F-listed solvents (F-series wastes) are pumped into the 400 series tanks, except tank 403 which is used for rinsate storage. The liquid phase from tank 403 is analyzed


to determine if it should be treated in the wastewater treatment system or sent out for incineration. The oil phase is blended and sold as marine diesel oil (MDO). The contents of tanks 401, 402, and 404 are blended to meet heat content requirements, about 10 to 15 thousand BTU/gallon. Agitators have been installed in the tanks to keep the waste fuel mixture homogeneous. The waste fuel is then shipped to a cement kiln to be used as an alternative fuel. Some companies accepting this waste include North Texas Cement Company (TXD007926496), River Cement Company (MOD050232560), National Cement Systech (CAT080031628) , and Systech Environmental (KSD980633259).

Drum Program: Wastes accepted in drums are tested by EWC's own laboratory before treatment or disposal options are determined. The waste oil, wastewater and waste solvents are combined with EWC's own bulk load wastes, and run through the treatment system or sent off-site for incineration. The solid wastes are checked for benzene before a decision is made to either combine the waste with the oily solids for land disposal-or send-it out for \ incineration. Some solid wastes which have been determined as non-hazardous by the facility, are still sent to hazardous waste landfill sites.

Antifreeze: Used antifreeze is stored at EWC in a tank truck trailer. The glycol/water is shipped to Sylco in Denver Colorado, or PRS in Salt Lake City for reclamation.

Oil Filters: EWC accepts used oil filters on occasion for • transfer. ,

Aerosol Cans: EWC accepts used aerosol cans under hazardous waste manifest and segregates the empty and non-empty cans. Empty cans are bulked and sent to a scrap metal recycler. Cans that are not empty and are pressurized are sent under hazardous waste manifest to another TSDF for treatment with EWC listed as the generator.

Transfer Station: EWC accepts wastes other than those listed on their ISD for storage up to 144 hours, without handling the wastes or signing the manifests, as a transfer station./ =

VII. OBSERVATIONS:

(November 6, 1995)

At approximately 0950 hours Department inspectors Iaali and I arrived at Enviropur West Corporation's main office. We met with

Enviropur West Corp. Nov. 6,. 7, 15, 21, 1995 Page 11

!

Petty and Rcwden for a brief introduction. I explained the purpose of our inspection as veil as what we needed to do and see. I asked for consent to conduct our inspection and Petty said he needed to consult his legal counsel. After approximately 20 minutes Petty granted consent, though EWC's counsel had apparently not returned his call.

We drove approximately one block to !the facility on 29th St. and met with Jackson and Quezada. Inside the gate, which was closed, I asked Jackson for a copy of that morning's daily tank inventory. I then asked him to explain where wastes are received and to which tanks they are pumped. ; There are 4 loading/unloading racks. Rack it 1 is used for the unloading of halogenated wastes including oily waiter with high solids. As the waste is off-loaded, it passes through a shaker screen and into a bin separating the solids, which are drummed for offsite disposal. The liquids are then pumped into the 400-series tanks. Rack # 2, located at the truck washout at the back of the facility, is used for the unloading ,of oil and wastewater with high solids and for truck washout water. Again as the waste is off-loaded, it passes through a shaker screen"and into one*of two half tanks (HT-2 & HT-2A). The liquid waste then goes to tank 5001 or 5002 for gravity separation. Rack #3 is used mainly for the loading of outgoing recycled oil; from tanks D1/D2 (plumbed together) and # 2501 (see Photo 1). !; Rack 4 4 is used for unloading oily water. According to.ireceiving tickets and .statements by EWC managers, non-hazardous wastewater and wastewater manifested as hazardous waste which is profiled or fingerprinted and appears clean is pumped directly into tank # 1001. According to EWC management the.contents; of, tank f. 1001 "can^ be; treated in this tank, sent back through the treatment .system or if it meets the sanitation limits can be .sent, to the ibaLtCh|clischarge tanks # VI & V2. EWC would not commit to an answer.whether or not all of the wastewater manifested to EWC was always.run through the wastewater treatment.system.

'Jackson then showed us the operation at Rack.# 1. Halogenated oil is unloaded and pumped through a shaker screen and into a •bin. Solids are filtered out as the waste passes through the shaker screen and are sent through a conveyer which dumps the sblidk:into a waste drum (see Photos 2-4). The liquids drain through the shaker screen into a receiving bin. From the bin, the^liquid;.is pumped into tank # 401, ; 402", or 404 for treatment

• ancl'.^S^qrage. EWC has installed covers on the shaker screen and •••.theycbnyeyor to control fugitive emissions (see Photos 2-4) . Jackson stated that they are still lisinb t^his equipment, even t^bugh"it is unauthorized and EWC was previously cited for using it./,


Next to shaker screen #1 is half-tank HT-1 which stores sump and rain water, sludge and oil drained from valves. Gravity separation occurs and the wastes are pumped to an appropriate tank. This tank has been covered.

We then started to walk through the tank farm. We inspected the six 600-series tanks. Concrete, constituting the secondary containment, had been poured up around the walls of each of these tanks indicating that they had not been lifted to pour a concrete foundation underneath (see Photos 5 & 11). A portion of the bottom edge of tank 606 was elevated above the concrete level (see Photos 7-8). There was an epoxy-like material under the exposed bottom of the tank. All of the valves associated with these tanks were tagged according to Air Emission Standard requirements. There was a pipe which Jackson stated was not in use that was left uncapped. Jackson told his staff to put a cap on the end. . These tanks were equipped with high level alarms and a vapor recovery system. There was no leak detection system and no seismic anchoring on these tanks.

We inspected tanks 5001 and 5002 which,appeared to be on a concrete foundation (see Photo 12). These tanks had high level alarms and vapor recovery^ systems. All valves were tagged for identification and there was no significant leakage. Jackson stated that these two tanks were being emptied for cleaning. They contained oil and water at the time of inspection.

The 400-series tanks appeared to be on a concrete foundation within secondary containment, though statements in the tank assessments claim that these tanks are on soil. They were equipped with high level alarms and a vapor recovery system'. Tank #402 was empty for cleaning and repairs. Jackson stated tank # 404 was in use for alternative fuel. Tank # 403 is used for Marine Diesel Oil (MDO). Gasoline-contaminated oil (D00i) was formerly added to this tank until the Attorney General filed a civil complaint against EWC in October 1995. EWC sends this MDO as recyclable material under bills of lading.

Tank: #2501 has been raised approximately 6M and sits on channel steel to provide leak detection, the observation pipes still need to be installed.

Tank.#301, used for storing treated water, is equipped with a leak detection system.

Tank #501, used for storing oil and oily water,, has been taken out of service for repairs. The entrance way was open and there was a light and ventilation system set up for the workers. The floor was rusty and appeared heavily pitted (see Photos 16-17). There were two steel patches recently welded on the floor. There

Enviropur. West Corp. j Nov. 6, 7, 15, 21, 1995 1

Page 13

were several other new welds on the:wall of the tank. This tank has leak detection.

Tanks #Rl-3 are above-ground horizontal tanks, all on a concrete foundation with secondary containment. None of these tanks are anchored. ~

Tanks # D1 & D2 have been plumbed together and are used as one final recycled oil "product" tank (see Photo 28). These tanks are filled, the oil is sampled/analyzed and then certified.

There was a pump just south of Tanks £D1/D2 that had oil in it's metal containment pan. I requested;that EWC remove the oil, which EWC did. A pipe from a nearby pump containment pan lead to a sump opening (see Photos 18-19). ;I explained that EWC could not drain this waste oil into their ;sump. Jackson agreed and told his employees to remove the pipe and plug the containment pah. There wais no oil in the pan at the time of inspection. Jackson stated that EWC has been replacing old pipes and removing unnecessary pipes and equipment.

There were no seismic anchors on most of the tanks (see Photos 5 & 11-15). All tanks had concrete poured around them and there was containment, walls around all tanks, however, there is evidence that several tanks do not sit on concrete but are directly on soil. -The volume of the secondary containment structures are currently being assessed by the Department's Permitting unit. All hazardous waste tanks were equipped with high level alarms and vapor, recovery systems.

We walked through the. wastewaterKtr4atment*4system.: Water separated from the 600 series >tanksyjand: tanks # 5001 & 5002 is piped to weir box T-lOT and .chemical::addition tank 102, where the pH is raised, and then piped' to-ytheVcentrifuge. Sludge is removed at the centrifuge and is;conveyed and dropped into a bin. The conveyor and bin. have been enclosed to reduce fugitive air emissions. The water is then piped to centrifuge clarifier T-103, to clarifier surge tank T-105 and then to surge tank T-R3, which regulates the speed and volume: of water going through the rest of the treatment system. From R-3 the water goes to pre-treatment clarifier T-113, to chemical addition tank T-114, to chemical addition/flpcculation tank/T-115,;to disso1ved air flotation unit D-J01, to chemical^addftipn^tanks T-117 (permanganate) & T^T18, DAF clarifiersT-119 & T-120, carbon treatment/surge tanks T-121, T-l23;^*TTi247& ;T-125, then to finished water tanks T-1001 or 301, vfiniishfed water batch tanks T-VI & T-V2, sewer discharge clarifier'T-i;26 and finally to sewer discharge weir box T-127. > v ./


We nextwalked to the truck washout area which was on a concrete foundation with secondary containment. Unloading Rack £2 is located here. Waste loads as well as truck wash water is pumped through shaker screens and into two halftanks HT-2 & HT-2A. The shaker screens separate the larger solids which are then drummed for off-site disposal. The oily water is then pumped to the appropriate tank for treatment. The shaker screens and half tanks, which are still in use, are covered to control emissions.

Next to the truck wash area is the roll-off bin storage area. This area has a concrete pad but no containment berms. Several roll-off bins labeled as containing hazardous waste did not have the hazardous property marked on the label. Petty stated that these bins contained non-RCRA wastes and therefore, were not characteristically hazardous. I recommended that EWC choose the most appropriate characteristic and that used oil could be considered flammable or toxic and petroleum sludge could be considered toxic due to metals. There was a tanker trailer used to accept antifreeze. EWC marked the appropriate boxes. There were a couple of bins that had the incorrect CA waste code listed and EWC immediately corrected theses.errors.

EWC's management stated that prior to shipping the rolloff bins offsite absorbant is added and mixed to solidify any free liquids using a rented backhoe.

Iaali asked Jackson what they did with the spent activated carbon from their wastewater treatment plant. He told her that it is sent as non-hazardous waste on a bill of lading to the company that provides it for regeneration and recycling. There were large bags labelled as non-hazardous waste activated carbon near the roll-off bins. ; '

The flat bed trailer previously used to store wastes up to 144 hours as a transfer station had been removed. Drums to be transferred now remain in the staging area.

At approximately 1400 hours we walked to the drum staging/storage area in front of the tank farm and started to examine the drums and labels. Jackson explained the drum tracking numbers. I requested a copy of the logs from Jackson for the last two weeks in October and the first week in November (see Attachment 18). Wastes that EWC cannot treat are either emptied into.segregated roll-off bins for bulking purposes or manifested out in the same drums depending on the waste. Iaali and I observed one drum labelled as PCBs (see Attachments 8 & 18). Petty stated that this drum was one of seven drums containing used oil filters. EWC found oil at the bottom of this drum and had it tested (after the drums had been received) and discovered it had llppm PCBs.

Enviropur West Corp. Nov. 6,7,15, 21, 1995 j .• Page 15 i

EWC is working with the generator to properly dispose cf the

waste. :

Immediately southeast of tank. HT-1 is EWC's drum storage area noted in their ISD. This is a very small area. EWC is only allowed to store up to 90 days at this location. This area is near the facility's flare which is a potential source of ignition. EWC recently installed a fire wall between the flare and staging area. There were many drums here containing offsite D001 wastes that EWC had accepted prior to the civil complaint against EWC being filed on October 16, 1995. Rowden stated that EWC continued to accept D001 wastes up to this date (though EWCV was cited for this in an ROV dated December 20, 1994). There were several large boxes labeled as| hazardous waste - aerosol cans (D001/331). Rowden stated that when they receive aerosol cans in drums, several cans still contain material. EWC bulks the empty cans and sends them to a scrap metal recycler. EWC bulks the cans.with contents into cardboard boxes and sends them as hazardous waste to another TSDF'.l EWC becomes the generator of this hazardous waste. I

EWC stated' that" they still receive jused aerosol cans for transfer but stopped puncturing them until they receive confirmation from the Department that they can punctube empty cans without a permit.

(November 7, 1995)

and I returned to EWC to At approximately 0950 hours, Iaali conduct a record review. We met with Petty, Rowden, Goodman, Jackson and Quezada. The records-;Reviewed and findings are as -follows: • '-'/j' • ••••; '

Part A - Iaali and I reviewed the Part A applications dated April 24, 1990 and October 5, 1992 (see. Attachment 5) . Both of these applications include D001 wastestreams, however, EWC's ISD does not grant authorization to accept D001.

Interim Status Document (ISD) - EWC's ISD dated July 30, 1982 and the "Changes During Interim Status" letters dated December 21, 1990 and March 3, 1993 were provided (see Attachments 6 & 7). None of these documents list or approve the acceptance of DO01

• wastestreams. . ' "

Plot Plan — Present (see Attachment 1).

Operation Plan - EWC provided the following sections of their operation plan for review: ;


a) Waste Analysis Plan: Iaali reviewed versions of EWC's waste analysis plan dated June 1991, August 1994 and September 1994. Rowden stated that EWC is currently operating according to the 1991 waste analysis plan since the revisions include operations that have not yet been approved. Iaali found that this plan did not include specific limits of constituents or characteristics of wastes as parameters for accepting or rejecting incoming wastes.

b) Contingency Plan: Iaali reviewed the contingency plan which had been revised on August 15, 1995 and found it to be adequate. It included the current emergency coordinators, evacuation routes, agency phone numbers and arrangement correspondence with the fire and police departments and the nearest hospital.

c) Closure Plan; Iaali reviewed the May 1991 version of PRC's closure plan which Rowden provided and stated that was their current document. It was found to be adequate.

Closure Cost Estimate - Due to under estimates; .of closure cost throughout the industry, the Department's Region 3 permit writers developed standards with which they calculated each oil recycler's closure cost estimate.

Iaali reviewed EWC's closure cost estimate and funding status provided, dated 19941 The total estimate listed was $ 762,553; the amount required in the trust was $ 686,297.70; the amount currently in the trust was $ 55,638.33; so the trust deficiency was $ 630,659.37. These numbers do not match and are below calculations'made by the Department's analyst Cecilia Rosana.

EWC-did not update its closure cost estimate for 1995 within 60 days prior to the anniversary date of the establishment of the financial instrument (EWC's trust fund).

Air Emission Standards - During the walkthrough of the facility I inspected the facility's pumps, connection flanges, valves and piping for leaks and for identification tags. I did not observe any notable leaks at the connections, valves or pumps and all equipment had been issued identification numbers and had tags. Iaali reviewed the Air Emission Standard plans, equipment list and plot plan and found them adequate. Iaali also reviewed the Air Emission Standard inspection log and found it to be adequate, except that the date and nature of repairs was missing on a few entries.

Waste Minimization Plan - Iaali reviewed EWC's waste minimization plan and determined it was adequate.

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Enviropur West Corp. j Nov. 6, 7, 15, 21, 1995 Page 17 i '

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Inspection Logs - Iaali reviewed EWC's daily inspection logs and found that they combine tank, container, process and general facility inspections in one checklist (see Attachment 25). While reviewing approximately 2 months of inspections Iaali found that the date and nature of repairs made were often not noted on the checklists (see Attachment 25, 9/26/95). Iaali then cross-referenced the checklists with theioperating logbook and did not find reference to the repairs. |

Personnel Training - Iaali reviewed the facility's training plan, training records and individual training files for three employees. New employees have been given an orientation, Proposition 65 training and a 40 hour hazardous materials management training within 6 months of employment. Quezada stated that they keep all current and former employee records permanently.

Recycled Oil Certifications - Iaali reviewed recycled oil shipment certifications and corresponding lab analyses made for out-going loads from the months of April and October, 1995. Analyses since the September 15, 1994 ROV had been conducted by Sterling Analytical Laboratory until EWC's lab was certified on April 7, 1995 (see Attachment 16) . i. There are no logs kept by EWC that show each shipment of recycled oil.

Tank Assessments - Joseph R. Johnson, P.E., of JRJ Associates certified the structural integrity: of all of EWC's tanks, except for tank #2501, which was certified, by William A. Teipe, P.E (see Attachment 22). There was a certification letter for tank #V2 however the letter was not signed by Johnson. I reviewed the complete assessment packages for each, tank at the facility, except for tanks #5001 & 5002 which were not provided. Petty and Jackson stated that these two tanks were presently being emptied to perform assessments. In my review I read that tanks #HT-1, HT-2A and HT-2B were not emptied prior to assessment and thus, the interior was not inspected. Tanks #Rl-3 were not ultrasonicailly measured due to external pitting. Tanks #D1 and D2 were not internally inspected. ;Tank # 501 was being repaired at the time of the inspection. New patches had just been welded in place and several seams had been welded (it was noted that seams were.leaking prior to repair). Tank #602 did not have the floor inspected and report for #606 was not provided. Tank #402 was under repair;at the time of inspection and the floor had not been measured due to a coating.

The certification reports claim that most of these tanks require footings to meet seismic requirements. Johnson included designs of the required footing for each tank in his assessment. During our walkthrough I observed that none of the tanks had the required'footings installed.

Enviropur West Corp. Nov. 6, 7, 15,.21, 1995 Page 18

Secondary Containment - I reviewed EWC's most recent tank assessment documentation and read that the following tanks had no foundation and sit directly on soil: tanks # 301, 1001, 501, 601-606, 401, 403 and 404. Therefore, PRC had previously poured concrete around these tanks which does not provide adequate secondary containment. Carol Green, of the Department, reviewed containment capacities (review conducted at the Department's office) and found that some of the structures did not provide adequate containment.

At approximately 1130 hours we were informed that a batch of recycled oil had been finished and analyzed and was ready for shipment. I informed EWC that I would like to collect samples and asked if I could have their assistance for sampling the tanks. Jackson arranged for an employee, Paul Svay, to collect our samples. We met back at the facility, made preparations and collected 3 samples from tanks # R-3, D1/D2 and 606 with EWC's assistance starting at approximately 1250 hours (see Section IX). I requested a copy of the certification and the analysis for the out-going recycled oil batch from tank # D1/D2. that we sampled (see Attachment 23).

We left the facility at approximately 1330 hours.

On November 13, 1995, at the Region 3 office, Cecilia Rosana, Financial Responsibility Coordinator, from the Department's Region 3 office reviewed EWC's financial responsibility records and found the following:

Financial Responsibility - According to Rosana's review, EWC should have a balance of $ 800,040.25 in its closure trust fund. At the time of review, EWC had a document amount of $ 52,411.52 in its fund which is deficient by $747,628.73 (see Attachment 19). EWC does have liability coverage for sudden accidents in the amounts of $1 million per incident and $2 million aggregate as required.

(November 15, 1995)

At approximately 1015 hours, Iaali and I returned to EWC and met with Petty to review more records. The records reviewed and the findings are as follows:

Annual Reports - Rowden stated that he is still finalizing the 1994 annual report. He provided a copy of a letter to the Department requesting an extension for submitting this report. He stated that he received no response from the Department.


Incoming Manifests - Iaali reviewed all manifests received in January and on July 28, 1995. 1 reviewed all manifests received on July 3-5, 10, 11, 16, 17 and 21-23, 1995. Copies of the operating logs are kept with each day's'manifest for cross-reference.

Manifests show that EWC was accepting large quantities of D001 wastes (see Attachment 9). D001 wastes were added to PRC's October 5, 1992 Part A, however, this wastestream was not authorized by the Department in PRC's December 21, 1990 ISD or March 3, 1993 "Changes in Interim Status" letter. The majority of D001 waste loads are gasoline/water, however other wastestreams accepted included isopropyl alcohol and waste paint.

Manifest # 93482405 shows that D00T waste gasoline (manifested as D018) was accepted and the receiving ticket shows that this waste (700 gallons of gasoline) was placed in tank #603, a tank for non-RCRA used oil (see Attachment 10). Manifest # 95206457 shows that DO01 waste oil (manifested as used oil #221) was accepted and the receiving ticket shows that this waste, with a flash point <100*, was placed in tank #606, a tank for non-RCRA used ~ oil (see Attachment 11).

Manifests #92769858 and 93283093 and the receiving tickets show that used oil was pumped directly into tanks D1/D2, used to store treated and certified oil (see Attachment 12).

Manifests, bills of lading and receiving tickets show that wastewater sent as non-hazardous and hazardous wastewater have been accepted and placed into tank #1001, used to store wastewater treated in EWC's treatment system (see Attachment 13).

'^TheNiri»cexyln'g:^':ti'ckets show that EWC ran fingerprint analyses on these'wastes^which are not complete and valid to make a non-hazardous determination on the wastes. Specifically, fingerprinting does not include metals or toxicity testing. EWC's waste analysis plan states that all oily water will be treated prior to discharge.

Manifests and receiving tickets show that EWC has transported hazardous Waste simultaneously using standard manifest and modified milkrun procedures (see Attachment 14). Receiving tickets; indicate?that used oil loads have been contaminated with flammables including solvents. These loads, though manifested as

•: used^il^f^lzi^ had been accepted by EWC, despite the discrepancies. ' EWC noted the discrepancies on each manifest.

j . ' Manifests and receiving tickets show that EWC is accepting a wide range of wastestreams, including naphtha, alcohols, waste paint, xylene; toluene/ trichloroethane, formaldehyde and photdchemicals, some of which do not have oil constituents.


These wastes were received in drums and bulked in various tanks cr rolloff bins.

Transporter Manifests - The Department's manifest database indicated that several loads of hazardous wastes transported by EWC were stored longer than 144 hours at EWC under the transfer facility exemption. Manifest # 93308303 indicates that EWC stored this load of hazardous waste for longer than 16 days (see Attachment 15). The generator and TSDF are both located in the southern California area. Manifest # 93308308 indicates that EWC stored this load for approximately 14 days. .-Manifests.# 93310870 and 93310869 indicate that EWC stored these loads for approximately 8 days.

Out-going Manifests - Iaali reviewed out-going manifests which were filed by names of TSDFs to which wastes were sent. She reviewed manifests sent to 5 TSDFs and found no problems. Iaali also reviewed a file of bills of lading for "cutter fuel oil" sent off-site to PetroAmerica, Wilmington (see Attachment ). There were no recycled oil certifications for these shipments. Petty stated that it was shipped as recyclable material but would have to ask Rowden why they didn't need certifications. This oil was from tank #403 which was designated for low flash oil (D001) until EWC stopped accepting this waste in mid-October.

Load Rejections - Iaali reviewed EWC's file of recent lpad rejections which included loads that they already.accepted by signing the manifests. There were approximately 5 records in this file.

CIosure Cost Estimate - I requested a copy of the most recent updated closure cost estimate. Petty provided me with a closure cost estimate.prepared by Larry Varome dated 11/15/95 (see Attachment 20). varome stated that he updated this estimate at the time it was requested on November 15, 1995 and that he had not updated the estimate since the bankruptcy proceedings ended in February 1994.

Biennial Report - Not reviewed.

We left the facility at approximately 1530 hours.

(November 21, 1995)'

At approximately 1000 hours;1 I arrived at EWC's office to finish reviewing records and hold a closing meeting. I met with Petty and reviewed the following records:

Enviropur West Corp. ! Nov. 6, 7, 15, 21, 1995 ! Page 21 ,

Waste Analysis Plan - I reviewed Section 2.0 "Facility Description" through 2.3 "Oily Water". This plan states that all oily water will be treated (see Attachment 17).

Incoming Manifests - I reviewed all manifests received on October 20, 25 & 31 and November 1-6, 1995. I did not observe any. manifests indicating that D001 wastes had been accepted since mid-October, 1995. I did observe manifests and receiving tickets indicating that sludge wastes were accepted and transferred into rolloff bins (see Attachment 28). Jackson stated that sludge from the centrifuge is typically not mixed with off-site sludge. EWC implied that the off-site sludge was typically previously solidified. At least 3 receiving tickets indicate that incoming used oil was pumped directly into recycled oil tank # D1/D2.

.VI11. UNRESOLVED ISSUES: j

Despite being cited in the December 20, 1994 ROV, EWC continued to accept a wide variety of D001 wastes until the civil complaint was filed in October 1995. EWC still accepts D001 wastes as long as they are additionally F-series wastes . .

EWC's waste analysis plan did not include specific limits of constituents or characteristics of wastes as parameters for accepting or rejecting incoming wastes. The plan references the regulations which give the allowable iimits^(see Attachment 17). After further review we decided that including specific limits would not neccessarily be appropriate.because these limits could change and EWC would need a permit modification to accept the wastes. • • .

EWC has. accepted' a large quantity! and•'variety^of wastestreams that though,.flammable, have been classifiedvas-waste codes other than DOOl.. : Usually these wastes are classifieds as F-series wastes-,. .which EWC • can • accept."

EWC adds absorbant to sludge materials, bulked:, in rolloff bins and mixes the waste using a rented backhoe priorfto shipment offsite. The Department has determined that this activity, is considered treatment. Adding absorbant is allowable under Title 22, section 66265.1(d) (13) if it is added at the time waste is first placed in the container. '

EWC accepted several loads of oil manifested.as used oil #221 when analyses indicate the oil has been contaminated and should have been manifested as D001 or F-series wastes.. .EWC accepted these wastes since they are jauthori2.ed::'tb^;;'4'ccOp.t' F-series wastes and claimed they were authorized td. accept DOOl wastes. EWC noted the discrepancies on the mani^fests^and rsdmetimes,-:'sent the generators a notice of price change, document!i however, it does


not appear that EWC has taken any further action. These loads often came in on a combination of both standard manifests and milkrun manifests. The Department is reviewing the use of both manifesting procedures for the same load.

EWC accepted several loads shipped as non-hazardous ana hazardous wastewater which EWC fingerprinted and placed into tank $1001. EWC's fingerprint analyses are not adequate to make.a non-hazardous waste determination. EWC did not follow its waste analysis plan which states that all oily water will be treated in its wastewater treatment system. Since this treatment system can not accept hazardous wastes, oily wastewater must be properly determined to be non-hazardous or must be managed as hazardous waste.

EWC sent many loads of MDO or cutter oil from tank $403 on bills of lading without recycled oil certifications (see Attachment 29). These waste streams should only be shipped under a bill of lading along with a recycled oil certification or under a hazardous waste manifest.

EWC accepted a drum of used oil filters which EWC later found were contaminated with PCBs after testing residual oil at the bottom of the drum. The Department has determined that EWC is not in violation since EWC followed its waste analysis plan and it would not be expected to sample the oil dripping to the bottom of the drum prior to acceptance, provided that EWC manages this waste properly and promptly.

IX. SAMPLING:

On November 7, 1995, at approximately 1250 hours Paul Svay, of EWC, collected a sample, # LS-ESH-01 and split, from tank #,R-3 at my request (see Photo 25). The sample was collected using a glass one liter bottle inside a weighted bottle holder attached to a steel tape. The bottle was lowered to the bottom of the tank and slowly raised collecting a running sample. The sample, slightly cloudy wastewater was then poured into a one liter amber glass bottle. The sampling procedure was repeated to obtain a duplicate sample for EWC.

We then went to tank ID1/D2 and followed the same procedures for collecting running samples. This sample, # LS-ESH-02 was black oil (see Photos 26-28).

Next, we went to tank $ 606 and collected sample # LS-ESH-03 following the same procedures (see Photo 29). This sample was a black oily wastewater.

Enviropur West Corp. Nov. 6, 7, 15, 21, 1995 ! Page 23

Each sample was immediately sealed and photographed after collection. When sampling was finished I put the samples in an ice chest with blue ice and locked them'in the vehicle.

On November 8, 1995 I delivered all of the samples collected to the Southern California Hazardous Materials Laboratory. I transferred custody of the samples to Janice Wakakuwa (see Attachment 21).

X. SAMPLE ANALYSIS RESULTS:

Sample # LS-ESH-01 did not exhibit hazardous characteristic levels. Sample # LS-ESH-02 met the:criteria for recycled oil. Sample # LS-ESH-03 met the criteria for used oil, CA Waste Code # 221. (see Attachment 26).

XI. VIOLATIONS:

CLASS 1 VIOLATIONS:

Count 1: Operation Plan.

On or about July 5 and 28 and November 6 and 8, 1995, EWC failed to follow its operation plan, in that, EWC received and placed manifested hazardous wastewater into tank #1001, a tank designated for holding non-hazardous wastewater prior to discharge to the POTW system.

Evidence: Attachment 13 includes copies of<hazardous waste manifests for wastes received and EWC's corresponding receiving tickets listing!incomplete analyses run and the tank (# 1001) to which the; wastes were sent. This tank is not authorized to receive hazardous wastes. EWC can only put this waste into a tank authorized for hazardous waste because the waste has been manifested to them as hazardous waste.

Compliance: EWC shall immediately send all wastewater manifested as hazardous waste through the hazardous waste treatment process according to EWC's operation plan.

Count 2: H&SC, section 25201.

On or about November 6, 7, 15 and 21, 1995, EWC accepted, treated and stored hazardous waste at the facility without the proper hazardous waste facility permit or grant of authorization from the Department, in that: !


a) EWC accepted and managed D001 wastes.

b) EWC operated two shaker screens, a conveyor system, tanks '#4 04, HT-1, HT-2A and HT-2B.

c) EWC mixed bulked sludge with absorbant in rolloff bins to solidify the wastes prior to transportation.

d) EWC stored unauthorized wastes, as the transporter, for longer than 144 hours.

Evidence: a) Attachments 9-10 show manifests and corresponding receiving tickets with lab results indicating acceptance of D001 wastes and tank destination.

b) Department inspectors observed the shaker screens, conveyor system, half tanks and tank #404. EWC managers stated that this equipment is still in use. Attachment 24 shows the daily tank inventory indicating tank #404's use.

c) EWC's managers stated that prior to shipment, centrifuge sludge is solidified by adding absorbant and mixing it with a rented backhoe.

d) Attachment 15 shows manifests' listing EWC as the transporter and the dates of acceptance and delivery indicate that EWC stored these wastes for at least 8 to 16 days.

Compliance: a) EWC shall immediately cease accepting D001 wastes.

b) EWC shall immediately cease operating hazardous waste units that have not been authorized by the Department.

c) EWC shall immediately cease mixing centrifuge sludge and absorbant with a backhoe to solidify the waste.

d) EWC shall deliver hazardous wastes to a second transporter, a transfer facility or the designated TSDF within 144 hours of acceptance as allowed under the transfer facility exemption.

Count 3: H&SC, section 25250.7


On or about January 3 and July 17, 1995, EWC intentionally contaminated used oil with other hazardous wastes, in that, EWC added waste gasoline to tank #603, waste code #21|3/D001 (hydrocarbon solvent) into tank #604 and contaminated used oil with <70* flash point and 12,883 pp'm halides to tank #606 containing used oil and water.

i Evidence: EWC's receiving tickets show that the above wastes

were sent to tanks #603 and 606 (see Attachments 10 & 1 1 ) .

Compliance: EWC shall immediately cease mixing wastes other than used oil and oily water, including oil that has a flash point below 100°, into tanks designated for, or containing, used oil. j

Count 4: H&SC, section 25250.19 (a) |.

On or about November 15, 1995, EWC failed to test and certify oil as being in compliance with the standards specified in H&SC, section 25250.1, in that, EWC failed to complete, attach and keep a copy of recycled oil certifcations for cutterstock or marine diesel oil (MDO) sent on bills of lading to Petro America.

Evidence: Attachment 29 shows shipping documents for cutterstock or MDO. Iaali reviewed the file for this material sent to Petro America. There were no complete analyses or recycled oil certification forms* for these shipments. EWC could not provide these documents: .

Compliance: EWC, shall immediately analyze all recycled cutterstock or MDO to ensure that it meets recycled oil standards and send a recycled oil certification with each load.

Count 5: Title 22, Cal. Code Regs.; section 66265.142.

On or about November 15 and 21,/1995, EWC failed to update its closure cost estimate; in that, EWC did not update its closure cost estimate to include the inflation factor or any operation changes within 60 days prior to the anniversary date of the establishment of its financial instrument each year.

Evidence: On November 15, 1995, I was provided with a closure cost estimate that Larry Varome had just completed (see Attachment 20). On November 21, 1995, Varoon stated


that he had not adjusted the closure cost estimate since the bankruptcy proceedings in 1993/1994.

Compliance: EWC shall within 60 days, match the Department's estimate for EWC's closure costs. EWC shall update this estimate for inflation within 60 days prior to the anniversary date of the establishment of EWC's financial instrument (trust fund).

Count 6: Title 22, Cal. Code Regs., section 66265.143 (a)(3).

On or about November 6, 1995, EWC failed to provide adequate financial assurance for closure, in that, EWC failed to maintain their closure trust fund at an amount at least equal to the value that the fund would have if annual payments were made.

Evidence: Cecilia Rosana, Financial Responsibility Coordinator, from the Department reviewed EWC's financial statements and found that EWC should have fully funded their closure trust fund of $800,040.25 based on annual payments. EWC has only funded $52,411.52 to present. A financial review is included as Attachment 19.

Compliance: EWC shall fund its closure trust fund as required by Title 22,* Cal. Code Regs., section 66265.143.

Count 7: Title 22, Cal. Code Regs., section 66265.191 (a).

On or about November 6, 1995, EWC failed to have tanks certified by an independent, qualified, professional engineer, registered in California to attest to the tank systems' integrity, in that, records indicate that tanks # 5001, 5002, HT-1, HT-2A & B, R1-R3, D1 & D2, 501, 602, 606 and 402 had not been fully or adequately assessed and certified. According to assessments none of the tanks meet seismic requirements.

Evidence: Attachment 22 is excerpt from tank assessment reports for tanks # 501, 601 - 606. The certifications acknowledge that the tanks do not meet the seismic footing requirements. A record; review revealed that 14 tanks have not been adequately assessed for certification.

Compliance: EWC shall complete tank assessments as required by Title 22, Cal. Code Regs., section 66265.191.

Count 8: Title 22, Cal. Code Regs., section 66265.193 (b).


On or about November 6, ;7, 15 and 21, 1995, EWC failed to design and maintain a secondary containment system capable of collecting releases and accumulated liquids until the collected material is removed, in that, EWC's secondary containment system was installed around several of the tanks, but not underneath.

Evidence: EWC's tanks assessments state that tanks # 301, 1001, 501, 601-606, 401, 403 and 404 sit directly on soil (see Attachment 22). EWC's managers have stated that some tanks are directly jon soil but no one could provide documentation oh which tanks sit on soil and which sit on concrete. Carol Green reviewed containment capacities and found that some of the structures did not provide adequate containment.

Compliance: EWC shall install secondary containment as required by Title 22, Cal Code Regs., section 66265.193 (b).

CLASS 2 VIOLATIONS:

Count 1: Title 22, Cal. Code Regs., section 66265.15 (d) .

On or about November 6, 11995, EWC failed to follow inspection requirements,; in that, EWC failed to include the date, and nature of repairs on several occasions in the inspection log. Also missing from the inspection log were inspection results for tank #5002.

Evidence:,'Attachment 25 includes; copies of inspection checklists showing! problems but no date or nature of repairs. The checklists do not include an entry for tank #5002.

Compliance:. EWC certified compliance; no further action is neccessary.

XII. DISCUSSION WITH MANAGEMENT:

At the end of our. inspection on November 21, 1995, I met with EWC's managers and' discussed potential violations as well as other areas of concern. We.discussed whether incoming wastewater was actually, run through EWC's treatment system. EWC implied that it-was, but statements contradicted each other. I decided to remove it as a- violation and change it to an unresolved issue on the Summary of. Violations. . I asked Larry Varome when he had completed the; latest closure,cost estimate (provided to me on 11/15/95). Varome stated that he,finalized it on November 15, 1995. He was asked when-the previous estimate was made and. he stated a couple of years ago. I asked why,tank # 606 was ; designated as a feed tank on the.daily tank inventory sheets.

Enviropur West .Corp. Nov. 6,7,15,21,1995 Page 28

Jackson stated that the water phase of each 600-series tank is fed to |606 which in turn feeds the centrifuge. Jackson stated that oil is still pumped to #6.06 for treatment the same as the other 600 series tanks. I explained that there were several unresolved issues (noted in the Summary of Violations) which could be determined as violations and other violations might be found after reviewing copies of documents I received. I issued a Summary of Violations and gave EWC a copy (see Attachment'27).

I left the facility at approximately 1530 hours.

XIII.ATTACHMENTS:

1. Facility Plot Plans - 3 pages. 2. Photographs from November 6 & 7, 1995 - 15 pages. 3. Facility Process Flow Diagrams - 2 pages. 4. Wastewater Treatment Process Flow Diagrams - 2 pages. 5. Part A applications dated April 24, 1990 & Oct. 5, 1992

15 pages. 6. ISD letter dated Dec. 21, 1990 3 pages. 7. ISD clarification letter dated March 3, 1993 - 6 pages. 8. In-coming manifests for PCB wastes accepted by PRC - 7

pages. 9. Manifests showing that PRC accepted D001 wastes - pages. 10. D001 gasoline pumped into tank # 603 - 3 pages. 11. Manifest/receiving tickets showing EWC pumped D001 wastes

into tanks # 604 & 606 - 12 pages. 12. Manifest/receiving tickets showing used oil pumped into tank

# D1/D2 - 8 pages. 13. Manifest/receiving tickets showing" wastewater pumped into

tank #1001 - 12 pages. 14. Manifested loads using standard'and milk-run procedures

pages. 15. Manifests for transfer wastes stored over 144 hours - 4

pages. 16. EWC's laboratory certification frOm ELAP - 3 pages. 17. Excerpts from Waste Analysis Plan - 10 pages. 18. Facility operating records - 28 pages. 19. Financial Responsibility Review - 2 pages. 20. EWC's up-dated Closure Cost Estimate - 4 pages. 21. Sample Analysis Request/Chain of Custody & Sample Receipt

2 pages. 22. Excerpts from tank assessment - 36 pages. 23. Used oil shipment certifications and analyses - 18 pages. 24. Daily tank inventory sheets - 7 pages. 25. Daily inspection logs container/tank/facility - 2 pages. 26. Department's sample analyses results - 34 pages. 27. Summary Of Violations - 5 pages. 28. Manifests for sludge waste - 12 pages.

Enviropur West Corp. Nov. 6,7, 15, 21, 1995 i Page 29

29. Shipping documents for cutterstock/MDO sent without recycled, oil certifications - 16 pages. •

30. In-coming high halide loads rebutted - 13 pages.

XIV.SIGNATURES:

Larry Stuck j Hazardous Substances Scientist | Region 3 (Glendale) Statewide Compliance Division j Department of Toxic Substances Control

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Robert Kou I Supervising Hazardous Substances Scientist I Region 3 (Glendale) j Statewide Compliance Division • Department of Toxic Substances Control

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Date Submitted

/ ! : - ) I ' / $

Date Approved

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