-------
A
National Enforcement Investigations Center, Denver
.S. Environmental Protection Agency
WU jnamr
MBSSF
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/2-89-019
ENVIRONMENTAL AUDIT
AMERECO ENVIRONMENTAL SERVICES, INC.
Kingsville, Missouri
DEFENSE REALIZATION AND MARKETING SERVICE
Contract Numbers DLA 200-87-0044 and 0048
April 1989
John Ellison
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
-------
CONTENTS
INTRODUCTION 1
SUMMARY OF FINDINGS 4
AMERECO ENVIRONMENTAL SERVICES, INC., KINGSVILLE, MO 4
PCBs/PCB Items Weight and Volume Discrepancies 4
Compliance with Federal/State Regulations 5
Compliance with DRMS Contract Requirements 5
DEPARTMENT OF DEFENSE, DEFENSE REUTILIZATION AND
MARKETING SERVICE 7
ENVIRONMENTAL AUDIT RESULTS 8
AMERECO ENVIRONMENTAL SERVICES, INC., KINGSVILLE, MO 8
Compliance with Federal/State Regulations 9
Compliance with DRMS Contract Requirements 17
Section C.1 (Disposal of PCB and PCB Contaminated
Material) 18
Section C.5 (Department of Transportation Requirements 18
Section C.10 (Permits) 18
Section F.9d [Variation in quantities (Delivery Orders)] 18
CHEMICAL WASTE MANAGEMENT, INC., EMELLE, AL 18
DEPARTMENT OF DEFENSE, DEFENSE REUTILIZATION AND
MARKETING SERVICE, ROBINS AIR FORCE BASE
WARNER ROBINS, GEORGIA 19
APPENDICES
A AMERECO'S DRMS CONTRACTS
B MANIFESTS/DOCUMENTS TRACKING PACKAGE
C CWM-EMELLE TRACKING PACKAGE
D TSCA DOCUMENTS FOR AMERECO, DRMO ROBINS AND
CWM-EMELLE
-------
CONTENTS (cont.)
TABLES
1. Volume Discrepancies in PCB Shipments, January 1989
Rollins Environmental Services, Inc 10
2. Weight Discrepancies in PCB Shipments, January 1989
Chemical Waste Management, Emelle, Alabama 12
3. Weight Discrepancies in PCB Shipments, January 1989
CWM Chemical Services, Inc. Model City, New York 15
4. Weight Discrepancies in PCB Shipments, January 1989
Envirosafe Services of Idaho, Inc. Grandview, Idaho 16
-------
INTRODUCTION
The Department of Defense (DOD), Defense Reutilization and Marketing
Service (DRMS) awarded AmerEco Environmental Services, Inc., (AmerEco)
four contracts [Appendix A] for PCB/PCB item transport and disposal. AmerEco
completed two contracts which included removal and disposal of PCB/PCB
items generated at specified DOD installations during each 12-month contract
period which ended in 1988. Additionally, the DOD flew PCBs/PCB items from
DOD radar installations in Canada to Robins Air Force Base, Warner Robins,
Georgia. AmerEco then picked up these PCBs/PCB items at Robins Air Force
Base under terms of one of the existing contracts. When sufficient PCBs/PCB
items accumulate at one or more DOD storage facilities, DRMS issues a
delivery order for their removal. AmerEco transports most PCBs/PCB items to
their facility in Kingsville, Missouri [EPA ID No. MOD980962849] for processing
and then transports PCB solids for landfill disposal and PCB liquids and large
PCB capacitors for treatment by incineration.
Landfill facilities used included :
• Chemical Waste Management, Inc., Emelle, Alabama
CWM Chemical Services, Inc., Model City, New York
Envirosafe Services of Idaho, Inc., Grandview, Idaho
U.S. Ecology, Beatty, Nevada
Incineration facilities used included:
Rollins Environmental Services, Inc., Deer Park, Texas
• CWM Chemical Services, Inc., Chicago, Illinois.
AmerEco contracts DLA 200-87-D-0044 and 0048 were audited during
the week of January 9, 1989, by the EPA National Enforcement Investigations
Center (NEIC) and DRMS. The audit evaluated both DOD domestic and
-------
2
Determine if PCB management practices of AmerEco and their
subcontractors complied with Federal and State environmental
regulations and with environmental requirements of the DRMS
contracts
Determine if DRMS PCB management practices complied with
Federal and applicable State environmental regulations.
The audit included:
Review of Dun and Bradstreet reports and EPA databases to
gather background information and/or compliance history regard-
ing AmerEco and selected subcontractors
Inspection of selected PCB records and the PCB handling and
storage facility at AmerEco
Inspection of DRMS records and the Robins Air Force Base PCB
storage building at Robins Air Force Base, Warner Robins,
Georgia
Inspection of selected PCB records and the PCB handling and
disposal facility at Chemical Waste Management, Inc., Emelle,
Alabama (CWM-Emelle)
Tracking DOD PCBs/PCB items manifested to CWM Chemical
Services, Inc., Model City, New York (CWM - Model City);
Envirosafe Systems of Idaho, Inc., Grandview, Idaho (ESI); and
Rollins Environmental Services, Inc., Deer Park, Texas (RES).
The audit focused on cradle to grave manifest tracking of selected DRMS
PCB wastes from contracts DLA 200-87-D-0044 and 0048. AmerEco provided
manifests and inventory records confirming receipt of all 149 loads for which
-------
3
record check which included weight tickets, unloading logs, chemical analysis,
inventory records, loading logs, and disposal manifests. Additionally, the PCB
facility was inspected including storage areas, laboratory, loading docks, tank
farm, recordkeeping areas, and processing areas. The 1987 Annual Document,
-------
4
SUMMARY OF FINDINGS
The environmental audit of PCB management practices associated with
the DRMS contracts revealed that AmerEco could not account for all PCBs/PCB
items and did not comply with two TSCA/State regulations and four DRMS
contract requirements. The audit did not reveal noncompliance by sub-
contractor CWM-Emelle and the DRMS office at Robins Air Force Base (DRMO
Robins). Although noncompliance was not directly observed at DRMO Robbins,
records for dates PCBs/PCB items were placed in storage at other DOD
facilities indicate storage for disposal exceeding 1 year. Federal regulations
require disposal within 1 year of when PCBs/PCB items are taken out of service
and placed in storage for disposal. Specific instances of noncompliance with
Federal/State regulations and DRMS contract requirements are discussed
below.
AMERECO ENVIRONMENTAL SERVICES. INC.. KINGSVILLE. MISSOURI
AmerEco provides transportation for DRMS PCBs/PCB items but sub-
contracts all treatment and disposal. This includes transportation both from the
DOD installation to AmerEco and from AmerEco to the treatment or disposal
facility. Most wastes are transported to AmerEco's storage and processing
facility before shipment to a disposal facility. PCB transformers are drained and
flushed and PCBs/PCB items are consolidated/bulked at AmerEco's facility.
The inspection of AmerEco revealed the following:
PCBs/PCB Items Weight and Volume Discrepancies
Treatment and disposal facilities' measurements of PCB/PCB item
weights and volumes often did not agree with AmerEco's manifested weights
and volumes. The manifested weights averaged about 14% higher than the
weights measured by three landfill disposal facilities and the manifest volumes
-------
5
Compliance with Federal/State Regulations
PCBs are regulated in Missouri under hazardous waste regulations
found in the Code of State Regulations, Title 10, Department of Natural
Resources, Division 25, Chapter 13 (10 CSR 25-13). The State has adopted
40 CFR 761 by reference and also require PCB facilities such as AmerEco to
comply with 40 CFR 265 Subparts B through D and F through Q.
Based on these findings and requirements previously listed, AmerEco
did not comply with the following Federal/State regulations:
FEDERAL/STATE REGULATION DESCRIPTION OF NONCOMPLIANCE
Compliance with DRMS Contract Requirements
Additionally, AmerEco did not comply with the following DRMS contract
requirements:
DRMS CONTRACT REQUIREMENT DESCRIPTION OF NONCOMPLIANCE
10 CSR 25-13.010(5)(C)2*
Site Security. AmerEco did not have a
fence around the active portion of the
facility. Access was observed during the
inspection when a stray dog walked into
the PCB storage area.
40 CFR 761.180(b)(3)/
10 CSR 25-13.010(3)(E)1
and 2D and F
Recordkeeping Requirements: AmerEco
prepared annual documents based mostly
on estimates. Weights and volumes of
PCBs/PCB items were not always mea-
sured at AmerEco. Large weight/ volume
discrepancies were not corrected in the
annual documents.
Section C.1
Disposal of PCB and PCB Contaminated
Material: AmerEco did not comply with
40 CFR 761 and 10 CSR 25.12.020
recordkeeping requirements, as discussed
above.
-------
6
Department of Transportation Require-
ments: AmerEco manifested PCB ship-
ments listing weights up to 65,043 pounds.
Personnel from the Missouri Depart-ment
of Natural Resources, which has a grant to
enforce DOT requirements, indicated a
maximum legal load would be 40,000 to
45,000 pounds for the type of trucks used
by AmerEco. Fourteen of 72 manifested
PCB shipments to CWM-Emelle listed
weights greater than 50,000 pounds.
Permits: AmerEco did not comply with
State regulations for site security, as dis-
cussed above.
Variation in Quantities (Delivery Orders^:
The contract requires adjustments when
actual delivery quantities are more than
3% different than the quantity stated in the
delivery order. AmerEco did not notify the
government and no adjustment was made
in delivery order weights and volumes
which exceeded this limit in AmerEco's
favor. However, AmerEco often requested
changes to receive more money if actual
delivery quantities were greater than the
stated delivery order quantity.
The following AmerEco management practices probably contributed to
the weight and volume discrepancies:
In most cases, AmerEco did not weigh material received and
instead used weights/volumes provided by DRMS (most
commonly nameplate weight for PCB transformers).
AmerEco drained transformers and used nameplate volumes
instead of measuring actual volume.
PCB analysis at AmerEco was limited to screening for
concentration. The specific gravity was not measured and factors
for PCB weight were assumed, (e.g., mineral oil 7.3 pounds per
gallon, >10,000 ppm PCB 13 pounds per gallon).
In most cases, manifested weights and volumes for PCBs/PCB
items shipped to treatment or disposal facilities were based on
reported or estimated/calculated weights and volumes, not on
actual measurements.
Section C.5
Section C.10
-------
7
AmerEco was not maintaining original records for some
information entered onto computer inventory records, (e.g.,
unloading logs, pro-cessing information).
DEPARTMENT OF DEFENSE. DEFENSE REUTILIZATIQN AND MARKETING
SERVICE
Department of Defense PCBs/PCB items were picked up by AmerEco at
many installations. AmerEco records for dates of when these items were placed
in storage for disposal indicate storage periods by DOD/DRMS greater than
1 year. Actual DOD or DRMS records were not observed except at DRMO
Robins where no storage periods exceeding 1 year were observed. Federal
Regulations require disposal within 1 year of when PCBs/PCB items are taken
out of service and placed in storage for disposal.
The DOD airlifted PCBs/PCB items from DOD installations in Canada to
Robins Air Force Base. AmerEco picked up eight of the nine shipments of these
items from Canada. Although special care was taken in transportation and
initial processing at AmerEco, the Canadian PCBs/PCB items were then
processed the same as and mixed with domestic shipments. After the
processing of Canadian shipments began in the summer of 1988, shipments
from AmerEco to disposal facilities usually contained both domestic and
Canadian PCBs/PCB items. Weight/volume discrepancies were noted for these
-------
8
ENVIRONMENTAL AUDIT RESULTS
These findings are based on inspections, record review, and tracking
185 manifests PCB items on 72 manifests were tracked from the DOD facility to
final disposal sites. The audit emphasized review of records required by
Federal/State regulations and DRMS contract requirements.
AMERECO ENVIRONMENTAL SERVICES. INC.. KINGSVILLE. MISSOURI
AmerEco currently operates under interim status as a PCB facility per
Missouri Hazardous Waste Regulations. AmerEco operates as a PCB broker
and storage for disposal facility and is not required to have any EPA approvals
for these activities. EPA Region VII approvals of proposed transformer decom-
missioning and PCB oil detoxification operations are pending. AmerEco began
operations in June 1983 as "PCB Disposal Systems, Inc.," the name was
changed to AmerEco in December 1986.
AmerEco primarily uses Chemical Waste Management, Inc., Emelle,
Alabama; SCA Chemical Services, Inc., Model City, New York; Envirosafe
Services of Idaho, Inc., Grandview, Idaho; and U.S. Ecology, Beatty, Nevada, for
landfilling PCB solids and Rollins Environmental Services, Inc., Deer Park,
Texas and SCA Chemical Services, Inc., Chicago, Illinois for incinerating PCB
liquids.
AmerEco has had four DRMS PCB contracts [Appendix A] beginning in
November 1985 through September 1988. The contracts were originally
estimated at $3,226,784 total; however, $7,083,204 total was actually obligated.
AmerEco currently has no DRMS contracts, but is still submitting contract bids.
When the DOD decided to dispose of PCBs/PCB items from 17 radar
installations in Canada, an existing AmerEco contract (DLA 200-87-D-0044)
was extended and additional delivery orders were issued. Nine weekly
shipments of PCBs/PCB items were flown to Robins Air Force base by DOD
where the first eight shipments* were picked up by AmerEco and transported to
The ninth shipment was picked up Aptus, Coffeyville, Kansas which is the current PCB
-------
9
AmerEco's Missouri facility for processing. DRMS provided extra personnel to
monitor these retrograde activities. A DRMS monitor observed the unloading
and weighing of each item from the Canadian shipments at AmerEco. At EPA
Headquarters' request, EPA Region VII inspected and reported on AmerEco's
handling of DOD PCB shipments from Canada.
The NEIC audit evaluated AmerEco's procedures and regulatory
compliance for both DOD domestic and Canadian PCB shipments. For
example, AmerEco was awarded contract DLA 200-87-D-0044 for six geo-
graphic areas including DOD installations in GA, SC, AR, TN, MS, AL, LA, TX,
OK, Puerto Rico, and Panama. PCBs/PCB items from selected DOD
installations in these areas, retrograde PCBs/PCB items from DOD installations
in Canada, and from selected DOD installations from contract DLA 200-87-D-
0048 (New England, Central Atlantic, Midwest, and Plains States) were tracked
through AmerEco to final treatment and disposal. Processing of Canadian
PCBs/PCB items at AmerEco after the initial unloading and weighing was
similar to domestic PCB shipments. After processing of Canadian shipments
began in the summer of 1988, shipments from AmerEco to disposal facilities
usually contained both domestic and Canadian PCBs/PCB items. Weight/
volume discrepancies were noted for these shipments also.
Compliance with Federal/State Regulations
AmerEco was not in compliance with Federal/State requirements for
recordkeeping and State requirements for site security.
Manifested weights and volumes did not always match between
AmerEco and treatment/disposal facilities. The volume of PCB liquids
manifested to Rollins Environmental Services, Inc., Deer Park, Texas, was often
different than the volume actually treated. The volume received was often less
than the volume manifested [Table 1, Appendix B]. AmerEco claimed the
-------
Table 1
VOLUME DISCREPANCIES IN PCB SHIPMENTS
AMERECO ENVIRONMENTAL AUDIT
DRMS Contractor:
AmerEco Environmental Services, Inc.
Kingsville, MO
EPA ID No. MOD980962849
January 1989
TSDF:
Rollins Environmental Services, Inc.
Deer Park, TX
EPA ID No. TS055141378
Volume
Date Manifest Date Volume* Difference** Percent
Manifested Manifest No. Volume Received Received (Gallons) Difference***
08/19/87
355361
4,000
08/20/87
4,118
-118
-3
09/09/87
318908
6,001
09/10/87
5,117
884
17
09/10/87
318906
4,000
09/11/87
3,288
712
22
09/23/87
354780
6,230
09/24/87
4,610
1,620
35
02/23/88
485506
5,871
02/25/88
5,357
514
10
03/08/88
488141
5,936
03/09/88
5,565
371
7
06/10/88
461819
4,009
06/11/88
3,514
495
14
07/26/88
488353
4,005
07/27/88
3,640
365
10
08/03/88
472302
4,002
08/04/88
3,454
548
16
08/23/88
472217
4,219
08/24/88
3,668
551
15
08/30/88
472231
4,002
08/31/88
3,600
402
11
09/20/88
472331
5,353
09/21/88
3,972
1,381
35
09/27/88
472306
3.532
09/28/88
2.580
952
36
Totals
61,160
52,483
8,677
16.5
Based on weight as measured at Rollins and AmerEco Specific Gravity Factor
Difference between manifest volume and volume received
-------
11
and reportedly checked truck volumes with a calibrated stick. Rollins reportedly
used specific gravity and weight to determine volume. In most cases,
AmerEco's computer records were not measured volumes. AmerEco admitted
some transformers were not full and some transformers had no liquid inside.
For example, a transformer from contract 87-D-0044 delivery order No. 136
listed on manifest F108A was received at AmerEco on June 20, 1988, and was
listed as containing 42 gallons of PCB liquid. Laboratory records indicate no
sample was collected and operations personnel indicated the transformer was
empty. However, the computer inventory report lists 42 gallons of PCB liquid
from this transformer was sent for disposal on manifest J1385 on September 18,
1988. DRMS is charged for disposal of this "phantom" volume and the
manifested volume is short 42 gallons. AmerEco indicated it was easier "to
make the records look good" than to correct DRMS records and get change
orders approved. Additionally, AmerEco usually drained transformers without
measuring actual volumes. This would account for some differences in PCB
liquid volumes.
The weight of PCB solids manifested to CWM-Emelle was often different
than measured weight at the facility and usually the weight measured by CWM-
Emelle was less than the weight manifested [Table 2]. CWM-Emelle personnel
indicated AmerEco was not necessarily aware of these discrepancies since the
weight difference was not marked on the manifest and CWM-Emelle invoices
AmerEco based on cubic feet of waste not weight. CWM-Emelle personnel
check each shipment for piece count and serial numbers and no piece count or
serial number discrepancies were noted. AmerEco indicated that except for
retrograde items, most DRMS transformers were not weighed. DRMS reported
weight came from transformer nameplates or actual weight. Currently there is
no accounting for differences in manifested verses landfill facility measured
weights. If PCBs/PCB items were not incinerated or landfilled then AmerEco
was not in compliance with 40 CFR 761.60 disposal requirements.
Similarly, the difference between manifest weight and weight measured
at CWM Chemical Services, Inc., Model City, New York and Envirosafe
Services of Idaho, Inc., Grandview, Idaho for AmerEco PCB shipments was
checked for 10 and 14 shipments, respectively. The results were similar to
-------
Table 2
WEIGHT DISCREPANCIES IN PCB SHIPMENTS
AMERECO ENVIRONMENTAL AUDIT
DRMS Contractor:
AmerEco Environmental Services, Inc.
Kingsville, MO
EPA ID No. MOD980962849
January 1989
Disposal Facility:
Chemical Waste Management, Inc.
Emelle, AL
EPA ID No. ALD000622464
Weight
Date Manifest Date Weight Difference* Percent
Manifested Manifest No. Weight Received Received (Pounds) Difference**
06/03/87
293611
50,780
06/05/87
41,660
9,120
22
08/07/87
293613
43,940
08/10/87
40,940
3,000
7
09/07/87
293617
42,337
09/08/87
38,340
3,997
10
09/11/87
293620
46,844
09/15/87
32,920
13,924
42
09/11/87
293621
33,800
09/14/87
25,980
7,820
30
09/18/87
293622
44,129
09/22/87
39,980
4,149
10
10/02/87
293623
41,714
10/06/87
40,380
1,334
3
10/12/87
293624
36,924
10/13/87
41,980
-5,055
-12
10/23/87
293627
44,927
10/26/87
37,920
7,007
18
12/04/87
293628
44,192
12/07/87
40,440
3,752
9
12/05/87
293629
59,001
12/07/87
44,700
14,301
32
12/04/87
293630
49,555
12/07/87
39,320
10,235
26
12/24/87
293631
41,130
12/29/87
39,260
1,870
5
01/07/88
293633
51,975
01/11/88
40,960
11,015
27
01/08/88
293634
45,429
01/11/88
40,920
4,509
11
01/08/88
293635
47,893
01/11/88
38,680
9,213
24
01/08/88
293636
50,154
01/12/88
42,380
7,774
18
01/26/88
293637
44,528
02/01/88
40,860
3,668
9
02/04/88
293638
51,542
02/09/88
41,260
10,282
25
02/22/88
293639
44,345
02/24/88
40,980
3,365
-------
-1
6
7
30
57
24
38
19
27
34
6
39
8
10
7
8
8
10
4
¦18
8
2
0
6
16
-2
12
16
Table 2 (cont.)
Weight
Manifest
Date
Weight
Difference
Manifest No.
Weight
Received
Received
(Pounds)
293640
39,822
03/07/88
40,160
-338
293641
43,486
03/14/88
40,860
2,626
293642
43,967
03/21/88
41,060
2,907
293643
46,377
03/28/88
35,720
10,657
293645
65,043
04/11/88
41,320
23,723
293675
50,620
05/09/88
40,940
9,680
293676
46,157
05/10/88
33,440
12,717
293677
45,869
05/17/88
38,500
7,369
293678
51,985
04/18/88
40,940
11,045
293679
54,512
06/01/88
40,680
13,832
293680
43,099
06/14/88
40,580
2,519
293681
56,345
06/07/88
40,460
14,885
293682
43,913
06/06/88
40,720
3,193
293683
45,857
06/20/88
41,860
3,997
293684
43,742
06/20/88
40,860
2,882
293685
37,123
09/15/88
34,320
2,803
293689
47,748
01/04/88
No Receipt Control Form
293695
43,928
08/11/87
40,540
3,388
293700
38,780
07/13/87
35,320
3,460
293712
41,786
07/13/87
40,140
1,646
293716
33,400
06/17/87
40,700
-7,300
293717
40,164
07/15/87
37,240
2,924
293718
40,360
07/20/87
39,500
860
293719
40,732
07/20/87
40,760
-28
293722
41,980
07/21/87
39,520
2,460
293723
46,629
07/21/87
40,300
6,329
293726
40,023
07/29/87
40,660
-637
293728
46,186
07/28/87
41,200
4,986
293729
41,265
07/29/87
35,620
-------
Table 2 (cont.)
Weight
Date
Manifest
Date
Weight
Difference*
Percent
Manifested
Manifest No.
Weight
Received
Received
(Pounds)
Difference**
06/15/87
293730
43,257
06/17/87
38,260
4,997
13
05/27/87
293731
49,674
06/02/87
38,940
10,734
28
06/24/88
403301
32,217
06/27/88
41,010
-8,803
-21
06/24/88
403302
46,536
06/28/88
41,220
5,316
13
09/22/88
403328
46,076
09/27/88
41,660
4,986
12
08/19/88
403330
47,492
08/23/88
41,360
6,132
15
08/19/88
403331
48,629
08/24/88
41,080
7,549
18
08/12/88
403332
55,679
08/15/88
41,000
14,679
36
08/05/88
403334
62,360
08/08/88
39,580
22,780
58
07/29/88
403335
49,116
08/01/88
41,120
7,996
19
07/29/88
403336
54,757
08/02/88
41,180
13,577
33
07/29/88
403337
46,018
08/01/88
40,920
5,098
12
07/22/88
403338
47,619
07/26/88
39,480
8,139
21
07/22/88
403339
42,401
07/26/88
38,440
3,961
10
07/22/88
403340
48,580
07/27/88
34,200
14,380
42
07/22/88
403342
55,624
07/25/88
39,060
16,564
42
07/15/88
403344
28,791
07/18/88
24,040
5,751
24
07/15/88
403345
50,683
07/18/88
41,960
8,723
21
07/15/88
403346
52,845
07/18/88
40,900
11,945
29
07/08/88
403348
43,399
07/11/88
Truck was not tared
07/08/88
403349
56,294
07/11/88
40,500
15,794
39
06/09/88
403350
42,262
06/14/88
41,380
882
2
06/03/88
403351
51,146
06/07/88
40.960
10.186
25
Totals
2,761,810
465,876
16
Difference between manifest weight and weight received
-------
Table 3
WEIGHT DISCREPANCIES IN PCB SHIPMENTS
AMERECO ENVIRONMENTAL AUDIT
DRMS Contractor:
AmerEco Environmental Services,
Kingsville, MO
EPA ID No. MOD980962849
January 1989
Inc.
TSDF:
CWM Chemical Services, Inc.
Model City, NY
EPA ID No. NYD049836679
Weight
Date Manifest Manifest Date Weight Difference* Percent
Manifested (NY A) Weight Received Received (Pounds) Difference**
10/03/87
3306240
43,585
10/05/87
40,920
2,665
6
10/15/87
3306363
47,520
10/20/87
41,200
6,320
15
11/13/87
3306442
31,696
11/17/87
30,160
1,536
5
11/19/87
3306464
40,595
11/23/87
40,380
215
0.5
12/11/87
5887791
44,605
12/14/87
39,960
4,645
12
01/07/88
5153598
53,993
01/11/88
41,560
12,433
30
01/15/88
5153607
42,682
01/19/88
37,580
5,102
14
01/22/88
5887845
46,426
01/25/88
40,800
5,626
14
02/05/88
5887917
30,944
02/08/88
39,380
-8436
-21
02/19/88
5887962
53.782
02/22/88
40.740
13.042
22
Totals
435,828
392,680
43,148
1 1
Difference between manifest weight and weight received
-------
Table 4
WEIGHT DISCREPANCIES IN PCB SHIPMENTS
AMERECO ENVIRONMENTAL AUDIT
DRMS Contractor:
AmerEco Environmental Services, Inc.
Kingsville, MO
EPA ID No. MOD980962849
January 1989
TSDF:
Envirosafe Services of Idaho, Inc.
Grandview, Idaho
EPA ID No. IDD073114654
Date
Manifested
Manifest No.
Manifest
Weight
Date
Received
Weight
Received
Weight
Difference
(Pounds)
Percent
Difference
09/18/87
J187W
39,479
09/23/87
40,000
-521
-1
10/12/87
K097W
46,126
10/14/87
37,460
8,666
23
10/23/87
K237S
39,160
10/27/87
39,460
-300
-1
10/23/87
K237V
42,233
10/27/87
35,310
6,923
19
11/02/87
K307U
36,260
11/04/87
36,580
-220
-1
11/09/87
L067V
50,443
11/11/87
39,320
11,123
28
11/25/87
L137V
40,050
12/01/87
40,840
-790
-2
11/25/87
L277T
48,323
12/01/87
41,020
7,303
18
01/14/88
A158T
39,450
01/18/88
39,880
-430
-1
01/14/88
A158U
36,770
01/18/88
37,240
-470
-1
03/10/88
C118U
40,400
03/14/88
40,780
-380
-1
04/22/88
D228U
38,130
04/28/88
41,060
-2,930
-7
05/13/88
E138W
37,720
05/16/88
38,580
-830
-2
05/13/88
E138X
37,840
05/16/88
38.6QQ
-760
-2
Totals
546,130
26,384
-------
17
from different sources cannot be compared due to mixing when manifested to
treatment and disposal facilities. ESI received several loads that contained
PCB solids, articles, and capacitors and only small weight differences were
noted. However, for loads of transformers, large weight differences similar to
CWM-Emelle and CWM-Model City were noted.
AmerEco's recordkeeping includes computer inventories which are
based on information not actually measured at AmerEco. AmerEco also
entered information onto computer records and did not keep the original
operating records. As a result of these procedures, the 1987 Annual Document
is inaccurate and does not comply with 40 CFR 761.180(b)(3). According to
AmerEco personnel the weight and volume discrepancies were not corrected in
the Annual Document for 1987. The regulations allow weight/volume of PCB
liquids to be calculated if the internal volume of containers and transformers is
known and included in the Annual Document, together with any assumptions on
the density of PCBs contained in the containers or transformers. AmerEco
indicated they only estimated many volumes. Also, AmerEco did not include
assumptions on PCB densities in the Annual Document.
Missouri requires PCB facilities to comply with 40 CFR 265 subparts B
through D and F through Q. AmerEco did not have a fence around the active
portion of the facility. Thus, AmerEco was not in compliance with 40 CFR
265.14 by reference. During the inspection, a stray dog walked into the PCB
storage area.
Compliance with DRMS Contract Requirements
AmerEco is responsible for complying with all contract requirements and
ensuring similar compliance by all subcontractors. The company did not
comply with four provisions of contracts DLA 200-87-D-0044 and 0048, as
-------
18
Section C.1 (Disposal of PCB and PCB Contaminated Material)
AmerEco was responsible for complying with 40 CFR 761 regulations.
PCBs/PCB items have not been managed in compliance with applicable TSCA
regulations, as previously discussed.
Section C.5 (Department of Transportation Requirements)
AmerEco manifested PCB shipments listing weights up to 65,043
pounds. Personnel from the Missouri Department of Natural Resources, which
enforce DOT requirements in Missouri, indicated a maximum load would be
40,000 to 45,000 pounds for the types of trucks used by AmerEco. Fourteen of
72 manifested PCB shipments to CWM-Emelle [Table 2] listed weights greater
than 50,000 pounds.
Section C.10 (Permits)
AmerEco was responsible for complying with all local and State
requirements. PCBs/PCB items have not been managed in compliance with
applicable State site security regulations, as previously discussed.
Section F.9d [Variation in Quantities fDeliverv Orders)!
The contract requires adjustments to delivery quantities (amount of
material actually picked up) more than 3% above or below the quantity stated in
the delivery order, AmerEco did not notify the government and no adjustment
was made in delivery order weight/volume variances which exceeded this limit
in AmerEco's favor. However, AmerEco often requested changes and more
money when actual delivery quantities were greater than stated delivery order
quantities.
CHEMICAL WASTE MANAGEMENT. INC.. EMELLE. ALABAMA
As an AmerEco subcontractor, CWM-Emelle has received and landfilled
numerous PCB solids (mostly drained and flushed transformer carcasses) from
-------
19
CWM-Emelle. Both DOD and non-DOD PCB items are manifested, but most
PCB items were from the DRMS contracts. CWM-Emelle receives PCB items at
their PCB processing unit after the truck is weighed. The manifest is checked
and appropriate measurements/records made. An example of CWM-Emelle
records is in Appendix C. The PCB items are transferred to a CWM truck and
usually landfilled the day received. CWM-Emelle issues a certificate of disposal
upon request.
The facility is located on a 2,400-acre parcel of land in rural Alabama.
The active fenced portion of the site is 400 acres and the landfill cells are dug
about 100 feet into a 700- to 900-foot-deep chalk formation. PCB items and
hazardous waste are landfilled in the same trench. PCB items are landfilled
under approval of EPA Region IV. Each trench's approval from Region IV refers
to the facility operating plan and the original 1978 approval. The facility also is
subject to the terms of a 1984 consent agreement with EPA.
CWM-Emelle provided 72 "tracking" packages requested. Each package
contained the manifest, receipt control form, transformer total sheet, waste
transfer log, and waste mapping log. The results of comparing manifest weights
and CWM-Emelle weights are presented in Table 2. An example of a CWM-
Emelle "tracking" package is in Appendix C. The audit included records review,
laboratory, PCB processing unit, receiving area and landfill inspection. The
1987 Annual Document was also reviewed. During this inspection, no
noncompliance with TSCA regulations or DRMS contract requirements was
noted.
DEPARTMENT OF DEFENSE. DEFENSE REUT1LIZATION AND MARKETING
SERVICE. ROBINS AIR FORCE BASE. WARNER ROBINS. GEORGIA
The DRMO Robins is responsible for PCBs/PCB items manifested from
seven locations in Georgia. DRMO Robins has a new permitted
(September 29, 1988) hazardous waste storage facility. The base has a new
PCB storage building with approval from EPA Region IV. Both areas were
inspected. Custody of PCBs/PCB items is transferred to DRMS on a Form
1348-1 Turn-in-Document. Information is taken from nameplates and the base
-------
20
AmerEco made four pickups under contract DLA 200-87-D-0044 of DRMO
Robins PCBs/PCB items.
Additionally, the retrograde PCBs/PCB items from DOD radar
installations in Canada were picked up at Robins Air Force Base. On nine
Tuesdays from June to September, the retrograde PCBs/PCB items were flown
to Robins Air Force Base. The PCBs/PCB items were transferred directly to
AmerEco trucks for shipment to Kingsville, Missouri with three exceptions. The
first shipment arrived and only one of four trucks was loaded that day. The
waste (most of it overpacked) sat on the flight line overnight. This happened on
one other occasion and only overpacked waste sat overnight. The third
occasion was the last shipment which was loaded onto another contractor's
vehicles (Aptus). Aptus, Coffeyville, Kansas (formerly known as National
Electric) is the current PCB contractor for DRMO Robins.
The AmerEco vehicles were driven to AmerEco's Kingsville facility and
unloaded in the presence of a DRMS representative. In contrast to DOD
domestic PCB shipments, each item was weighed and the delivery orders
modified as necessary. All items had been sent for disposal, both from the
regular contracts and from the added retrograde delivery orders at the time of
the NEIC inspection. The EPA Region VII inspection revealed that DOD
Canadian PCBs/PCB items had been in storage for disposal for more than
1 year.
DRMO Robins provided copies of all manifests to the EPA Region IV
inspector who inspected the retrograde project. During the NEIC inspection,
there were only a few items in either the PCB or RCRA storage buildings. The
PCB items were all in drip pans marked and no noncompliance with TSCA
regulations were noted.
Copies of TSCA forms for AmerEco, CWM-Emelle and DRMO Robins are
presented in Appendix D.
Although noncompliance was not directly observed at DRMO Robins,
AmerEco records for dates PCBs/PCB items were placed in storage at other
-------
21
regulation requires disposal within 1 year when PCBs/PCB items are taken out
-------
APPENDICES
A AMERECO'S DRMS CONTRACTS
B MANIFESTS/DOCUMENTS LISTING VOLUME DISCREPANCIES
C CWM-EMELLE TRACKING PACKAGE
D TSCA DOCUMENTS FOR AMERECO, DRMO ROBINS, AND CWM-
-------
APPENDIX A
-------
Appendix A
AMERECO'S DRMS CONTRACTS
Contract No. Date* Estimate Obligated
DLA 200-86-D-0012 14 Nov. 85 $658,566 $251,880
DLA-200-86-D-0024 15 Aug. 86 $392,922 $1,186,630
DLA-200-87-D-0044 20 Mar. 87 $1,176,265 $4,196,663'*
DLA 200-87-D-0048 16 Apr. 87 $999,031 $1,448,031
Normal contract periods are for 1 year from contract date.
** Retrograde PCBs/PCB items from DOD installations in Canada were added onto this
-------
APPENDIX B
-------
01/09/89
INVENTORY REP0R1
D i: F i: N S E REUMl 1 Z A 1 ION AND HARK f 1 I NO SERV
File Aanifest
I _ I
Account Date
.1 Rec'd
Wist I
Date
Site Stored
tbs. Gals. Cu. Ft.
PC6 Repack Process Disposal Disposal
level Date Date Manifest Date
dotes
SO "fe (0
880629 G018S
880629 G018S
G088U
H198V
G158H
G058S
G058S
G15BS
H238S
H238S
J138S
J8-0SO5 F108A
88-0505 F108A
88-0505 F108A
BS:05Q5.fl0?A
88-0505 F108A
88-0505 F108A
88-0505 F108A
88-0505 F108A
88-0505 F108A
88-5505 FJ08A_
88 0505 F108A
88-0505 F108A
6V-0044
6V-0044
GV 0044
GVJ»44
6V-0044
GV-0044
GV 0044
GV-0044
GV-0044
GV-0044
6V-0O44
GV-0044
880620
880620
880620
880620
880620
880620
880620
B8O620
880620
880620
880620
880620
J001s
1002s
1003$
1004s
0005s
[0061
10071
10081
20091
20101
LOill
CD
B-H
B-H
B-H
H
B-h
B1-*
BIX
BID
BIB
Bl-J
81-E
860801__37_30
860801 3740
860801 3020
860801 2800
860801 13330
860801 845
860801
860801
880629
880629
860801
881109
845
360
845
845
336
65
65
45
42
0
65
65
45
65
65
42
•10000 880627
•10000 880627
148 880629
<500 880819
<500
•10000
•10000
148
>500
>500
<500
880705 10061/ ZOO1}
880705 10071/ ZO10
880711 L008I
880824 10111
880718
880711
880721
880903
880903
880918
-------
tv-31
REQUEST NUMBER
PCB ANALYSIS REQUEST & LABORATORY REPORT
AmtrEco Environmental Servient, Inc.
Rt #1, Bex 159, Klngcvlllft, UO «40«1
Phono: (816) 732-8501
ACCOUNT NUMBER; GENERATOR INFO:
K-D'^
00- M
DATE RECEIVED IN LAB; (p ^ % date completion:
SAMPLE •
A coot
E8TIMATE0
, PCB LEVEL
LABORATORY
NUMBER
PCB ANALYSIS //V*
ie>- Wn
Tan! */
>s?-r
QHW
?/o.oco
',4-
Too\
> rj&c
MS
?/OO0O
Toe*
n
>/6.0CQ
~T<->
TnoH
n
Ui£L i
' I
LAB MANAQER; 7~7 p*™-
-------
AMERECO OUANTITY VARIENCES IN SHIPMENTS TO ROLLINS,
DEER PARI , TEXAS
Tms table was generated using AmerEco's weight estimation
factors, as -fallows:
C'CB ppm. lbs. /gallon
1 . 500 8
2. ¦500 10
3. 10000 13
Gal 1 un
Sample No. Manifest No. Oty Listed ppm C'ty Recv ' d Conversion "/. Var
R-l
R-2
R-3
R-4
R-5
R-6
R —7
R-8
R- 9
R-10
R-l 1
R-l 2
R-l 3
R-14
00461819
•1)047 1096
00472231
00472302
00472217
U0472331
00472306
00488353
00318905
00318906
00355361
00354780
00485506
00498141
4009 gal 3
40300 lbs NA
4002 gal 3
4002 gal 3
4219 gal
5353 gal 2
3532 gal 3
4005 gal 3
oOOl gal 1
4000 gal 3
4000 gal 2
6230 gal 2
5871 gal 1
5936 gal 1
45680 lbs
41830 lbs
46800 lbs
44900 lbs
47680 lbs
39720 lbs
33540 lbs
47.320 lbs
40940 lbs
42 740 lbs-
4 1 180 lbs
46100 lbs
42860 lbs
44520 lbs
3514
NA
3600
3454
36 6 S
3972
2580
3640
5117
3288
4118
4610
5357
C C J c
JJOJ
1 0
1 4
1 8
9
-------
R-i
t'XAS WATER COMMISSION
P.O. 8«jk 13087, Capitol Station
Justin, Texas 7 1-3087
Please 0"nI * tvpe. (form designed tor ull on (lit* 112-Ditch) typewriter I
JUN I 61988
Form eoordvn) OMB Nr~?090-0039. *«oir« 9 30 gg
UNIKJRM HAZARDOUS
WASTE MANIFEST
1. Generator s US EPA ID No
M 0 D- 9- 8- 0 9 6 2 8
4 9
Mdmlest
| FTT'A
2. Page 1
\ o' 1
Information m the shaded areas
i» nol required by Federal tew
3. Generator s Name and Mailing Address
AmerEco Environmental Services, Inc.
Rt. 1 Box 159, 21 mi. E. on 50 Hwy.
4 VnontTai ^2-5591
A. Slate Manifest Document Number
~-N°" 00451819'
State Generator's 10
99929"
5 Transporter 1 Company Name 6.
Custom Environmental Transport. | D
US EPA ID Number
D. 9- 8. 0. 9. 1. 8. 8. 5. 8
C. State Transporter's ID 40756
0. Transporter's Phone 713-479-4801
7. Transporter 2 Company Name
US EPA 10 Number
E. Stale Transporter's ID
F.'Transporter's Phone
9. Designated Facility Name and Site Address
Rollins Environmental Services,
t0 US EPA ID Number
(TX), Inc.
P.O. Box 609, 2027 Battleground Rd.
Deer Parle, TX 77536 | T- X- D- 0- 5- 5- 1
G. State Facility'! to
01429JJ-*
4- 1- 3 7- 8
H. Facility's Phon#
r i< 713-479-6001
11 A.
HM
11 US DOT Oetcnotion {including Proper Shipping Nama, Hazard Clasi. and 10
Number)
12. Comamart
Wo. Typa
13
Total
Quantify
14
linn
Wl/Vo<
t
Watt* No.
1 RQ Waste Hazardous Substance, liquid, N.O.S.,
.. OSM-E, NA 9188 (Polychlorinated Biphenyls)
0 0 1
r i
0" 4' 0' 0' ?
sti ;D>
: 116080
b.
all
371 "(3!
.U"... i >(,T :, ij-
: M
- T
Y
e .).r*
~t- i>f.
S'i'
: i?. ,i c.-.
' -r. ' i i
3-njj)
•nbDs^T (0
Bwrlwri"
J.- Additional Descriptions foe.Materials 'bated Above cuoiuMGri iioifian^ Src.lJ.
•?H'i'0C#2€093-'389:j °>'V*t0700d? ppm' oil^1* 816 nolJBOil.naa notiatimtnim oi«»v
«ai 19nb02r.su »noncrij sinmil leteionsO sanseaiq art) ni ^noqeoetf lairt erti ydU>
K. Handling Codes for Wastes-Listed Abo*
- a eiem 01 vti.bti^* ^t* nouslugoi
ttrvan€T/p«n ^-tr/Trninim
abUifib^oie^ttJfnisiYSrr'a.Tr t IT*
15. Special Handling Instructions and Additional Information
PCB Manifest - Clean up any leaks or spills. In case of an emergency call 816-732-5591
Tor. 816rJ32r6563". ~U.S7. Coas't.~Guard 1-800-424-8802. J Chemtrec 1-800-424-9300. LI
16. GENE BATOR'S CERTIFICATION' I hereby declare thet the contents of this consignment era fully and accurately described above by proper shipping nemo end are
^ classified, packed, marked. and labeled, and are wi all respects tn proper condition for transport by highwer according to applicable international and national
government regulations, including applicable state regulations.
If I am a large quantity generator. I canity that I have a program m place to reduce the volume and toxicity of wests generated to the degree I have determined 10 be
economically practicable and that I have seleci ad the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and
1 future threat to human health and the environment; OR. rt I am a small quantity generator, I have made a good laith effort to mimmiie my waste generation and select
-I'll the best waste management method mat is available to me and that I can afford.
Printed/Typed Nama
!David Taylor- '
17. Transporter 1 Acknowledgement of Receipt of Materials
Primed/Typad Name _ y-
Cjfk/ft. C£ c
18. Transporter 2 Acknowledgement of Receipt of Materials
Month Day Year
ot> I To\ 8%
Date
Month D»y f«»'
11.6 \ Jo|gy
Data
in.-- Printed/Typed Nama vm- ry;
Signature .
Month Day' Yt»r
I'll'
:19; Discrepancy indication Space
20. Facility
rato/Cemiication of wceipt of hazardous materials covered by this manifest except as noted in hem 19.
• I vtV-- v«'vi -¦ <» - v. .. .
Data
Signature-
1
"WW
-------
Rollins
JUNE 23. 195S
AMERECO ENVIRONMENTAL SERVICES. INC.
ROUTE #1. BOX 159
KINGSVILLE. MO 640bl
ATTN: "*¦ . yarv Randolph
Dear Ms. Randolph:
This is to certify the material referenced below was incinerated
as of 06/21/88 at our Deer Park facility - Rollins Environmental
Services (04) Inc.. P. 0. Box 609, Deer Park. Texas 77536 in
accordance with 40 CFR 761 as it pertains to incineration of PCB
solids, liquids, and capacitors.
TOTAL POUNDS
-45680
H. 0. NUMBER
-26093-38
DATE RECEIVED
-06/10/88
RES (TX) INC. B/L NUMBER
-111328
RES (TX) INVOICE NUMBER
-161593
TVC MANIFEST NUMBER
—00461S19/F103S
SINCERELY.
RES (TX) INC.
\/Cj fa J/K.&
VELMA K. SHAFFER
PCB RECORDS ADMINISTRATOR
cc: Paula Arndt
Please call 713-479-6001 ext. 212 if there are any questions concerning
-------
APPENDIX C
-------
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53. BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
"Bte/c b
DATE
April 17, 1989
MEMORANDUM
SUBJECT:
FROM:
TO:
Transmittal of Final NEIC Report, "Environmental
Audit, AmerEco Environmental Services, Inc., Defense
Reutilization and Marketing Service!!-. Contract Nos.
DLA 200-87-D-0044 anc
Charles Aschwande,
Enforcement Spec
Regional Counsel, Regions IV and VII
Air and Toxics Division Directors, Regions IV and VII
Attached are copies of the subject report for your use.
This report details the findings of our audit of the handling of
PCBs/PCB items generated by Department of Defense installations
in the United States and Canada by AmerEco Environmental Ser-
vices, Inc. (AmerEco).
As stated in the report, AmerEco was not in compliance with
all TSCA requirements.
This investigation was conducted as part of NEIC's and
Department of Defense, Defense Reutilization and Marketing Ser-
vices' cooperative effort to monitor the performance of haz-
ardous waste/toxic substance disposal contractors. Copies of
this report have been sent to the DRMS Headquarters, Battle
Creek, Michigan.
If you have any questions regarding this report, please
contact John Ellison at (FTS) 776-5139.
Attachments
cc: Carroll G. Wills, Esq., Acting Director, NEIC (w/o att)
~Art :-Linton, Federal Facilities Coordinator, EPA Region IV
(w/att)
A.E. Conroy II, Director, OCM-OPTS (EN342) (w/att) ^ _
d?:
C
rt~
-------
:,-C-x7
t t : n n Li m
RECEIPT CONTROL FORM
96513
'AAr? ""
Truck *:
&> f &
Datp b/^ / <5" ' Time ' & Trailer J*
Manifest #'s. ^ O ° ^/
£)V^ 'O'J
Generato
nrR): J.AS&k
WEIGHT
55130 dr^s
T are
Net
Waste I D. / ft ^ ^ ^ Transporter L
Sched Date. fe ~ S ^?vdp (Circle one) Drums Dump Tanker Roll-off
# of Wastestreams: / Aooroval (initials). . Date'
44520 lk
6 ~s:-sn Tim,. /r.QQ«
BULK LOADS
SPECIAL INSTRUCTIONS
WPS #:
Sampler:
'X—d*
Technician:
T
| 1 1 >
iJj
ot£
PCB Results:
(Cl RCLE ONE)
CN~ Rea.?.
YES NO
CN- Results:
(CIRCLE ONE)
S Req.?
YES NO
S Results:
(CIRCLE UNt)
Disposal Method
D81 / T45 - D81
(CIRCLE ONE)
Disposal Method (Other)
Mix Ratio:
(FLUE OUST) (WASTE)
T renr.h.
Section:.
Density:.
(TANKER ONLY)
Wash Pad Release:
Released For Disposal By:
-------
HAZARDOUS WASTE MANIFEST
(As Required By The Alabama Department of Environmental Management)
Mea»e print or type (Form designed for use on elite ft 2-O'tch) typewriter I
UNIFORM HAZARDOUS
WASTE MANIFEST
Form Approved OMB No 2000-0*04 Sioires 7 1! 36
\ Generator s US EPA ID No.
Ml Q[ D| 91 81 0| 9] 6| 2[ 8| 4| 91F
Manifest
2 Page 1
of 1
Information in tns shaded arsis
is not required by Federal
law
J. generator s Name and Mailing Address
AmerEco Environmental Services, Inc.
Rt 1, Box 159, Kingsville, MO 64061
Generators Phone ( 816 I 73 205591
iSf8Bi
transporter 1 Company Name 5 US EPA ID Number
AmerEco Environmental Asevices, Inc.[MiQ|D|9|8|0|9| 6| 2| 8| 4i 9
/ transporter J. Company Name
~.Transport^,,
Designated (-aciluy Name and Site Address
CHEMICAL WASTE MANAGEMENT, iNC
Emelle Facility
Alabama Highway 17 at Mile Marker 163
Emelle, Alabama 35459
8 US EPA ID Number
I I I I I I I I I I
6.
10
US EPA 10 Number
F. Transporter's^ Ptttne >!'>¦*??>
G.Suta-FsdittV.,,vU_
-r-
H. Facility's PhOfti'
A. Li OiOj 0i 0 I 6 | 2 I 2 4 j 6 | 4
205/652-9721^:
it-'J*?
11 US DOT Oescnption (Including Proper Shipping Name. Hazard Class, and ID Number)
1 2 Containers
No. Type
13
Total
Quantity
14
Unit
Wt/Voi
»o.r*o 2
>SSSSsk
RQ Waste, Polychlonnated Biphenyls ORM
CWM Profile Number Q
E UN 23IS.
950
01 210
5 I 0 I 7 | 8 | 0
CWM Profile Number
CWM Profile Number
CWM Profile Number
T Additional Descriptions for Materials Listed Above
~7riaS\f-/orStf£+^t
'i-i:- ..S-:"'
V - J---*.-, -
J1--
~ >A-\
K. Handling Codas for Waste* Listed.*bov»¦>"&- ,
• T>?/
b.
15 Special Handling Instructions and Additional Information pCB Manifest - Clean up any leaks Or spills; call
emergency coordinator (016-732-5591/6563) in case of emergencies or questionable
developments.
IS. GENERATOR'S CERTIFICATE: I hereby declare that the contents of this consignment are fully and accurately described above by
proper shipping name end are classified, packed, marked, and labeled, and are m all respects m proper condition for transport by highway
according to applicable international and national government regulations
Unless i am a small quantity generator who has been exempted by statute or regulation from the duty to make a waste minimization certification
under Section 3002(b) of RCRA. i also certify that I have a program m place to reduce the volume and toxicity of waste generated to the degree I
have determined to be economically practicable and I have selected the method of treatment storage, or disposal currently available to me which
minimises the present and future threat to human health and the environment
Pnnted/Typed Name
David Taylor
nqni ^ aj
S'gnatilg 77/ ^ ~/7
Month Day Year
\Q\C>v?3\S\7
17.Transporter 1 Acknowledgement of Receipt of Materials
Printed/Typed Name
Gene Crabtree
18.Transporter 2 Acknowledgement of Receipt of Materials
Month Oay Year
Printed/Typed Name
Signature
Month Day Year
''''I'
19.Discrepancy Indication Space
20>«etIHy" #wnao«r Up®
\ ^myrt/Tyt^a Name
irator. Certification of receipt of hazardous materials
/I Signati
t>« noted m Item 19.
-------
UHMtlll) A n.USIIF.!) mMISrUMIEUS
niuCE5SllliTFUIU\
,uslomcr Information
enerator flame: Art\pr
enerator Location: V Wva< ; ;lU
5
WO
lanlfcst # 3 (j \\ j
Iransformors llanHesU
enerator'a storage Uatei
_m_0.
'^P
CUM Received Uate:_
Pnyc I of /
/&-r7
''•ansloriiier Identification liraliieiT+~TVu5fiiil~lJfilyt ¦
Serial i tlatiulactuier . tit, Empty tlbs.l
JO.
TA/f^sV
&7Ar>S9A
Fst/WsR-^A
L/j£Q//S>-&$P
%9 3o
&T0
^¦3 ^ PI
Hooma q
"isnaSSV
4&0
A UP
J£L
ISiO
JZ£
30 <3
UI mens i ons
^. a.v.v
/S~ :/(>,£/
>(»¦ <3!
Ft'
(th. in.
cOo r^n, ?i6> ) $
A I; ^ ¦
//
a.
3
1
1 .//
;r. /r. ^r>. I 3
i-?4? . otS.^I il
.r
/y,/f.^
^ ^ .v I 9
iransformer'Carcass Disposal Hccord-
tsposal Date;' 1 £ -r-*9
Aerator:
Total Cubic Feet
: 15%
Disposal Trench? Ji-T*,
y)Q/Yi /us/v
uuervlsor: £"*£> 5-feoj^e.iJ
Uate:_
Date:
o-s--r? 1
-------
uiiAimi) a ruisnri) lHAtisruuiiuis
PiiUCtS51llirFUIil\
.ustomcr Information
Generator Maine:
- - - -- h«\trin
Henerator Location: Yf\c<, \l ¦ )
'lanlfest # 11 "
lotal Traits/ornierp r>n MitilTisiT
Generator's storage Uatei
>o
—r—,—c20-
CtiM Received Uatet^
Pogc } of /
ransformer Identification—IJraln^'TTrusrieOnlyT""
Serial 9 Manufacturer , tit. Empty (lbs.)
Ocw-^cx^-ot
^)9r> ID
_tl±
LS <1
779
a At
Ql03
Vim
jY£S~
Dimensions
~iy. /*j. 3a
Fl'
^ //
ftf.W. ?/ 7^
3£l
k, sd.^ ' !• /?3
a x bo. •<&
-------
MANIFEST II:
pAC- E
/ 0F /
Disposer
t p r •
/-.e&cJ~~ ypj:
<=<1
6-5-f 7
Title
Date
C W M A
Wnste Code
-
Ouantitv
Unit
LOCATION
Commen t s
Process Code •
'retich
^evel r
^uai'
ao -
V+F
Vf/
•2 1
TJ
7S3 r.jl
f
« ...
'
¦
1
'
•
EACH MANIFEST OR CONTINUATION MANIFEST MUST HAVE THIS FORK COMPLETED A HD
ATTACHED .
-------
WASTE; MAPPING LOG
1 1
GENERATOR
MANIFEST
NUM8ER
w 5/s v
NUMBER "S
\.
QUANTITY
TRENCK~:
•*^r i iTrr
GRID
COORDINATES
D-5b
> V . C~>ot>e}f',rJ-\
y
l>
i i
no • ro
L
»_-KI S~+rti^ol. <=»tj*vr»
y
STIteM £*">?
n.|
• u
1«; T ¦ OH
y
1
/
-r^s-c» last's
d-^rr^£)
L-nr\
CJ=, 1-T=1-T
u-'
-=hr-e3/s-ut
\
rv%.ro
S-k
1
e--p 4" mXw»~7
y
-^n^css
y'
rr-i^ R • loft 5^3.
- -rui
STMSbf?)
^ -r-t-
U^/ y
IIA-Q
L.- r
-V\
¦>
L)
T3
"ST-IS--®) '
Wh-?
-SaUM
p-H^r-iC l_OCt^Krr-
r-nf*Q Q, IO.cJ^S-
I
H-ur
M •
Pc/i-_P>c.'-'^ 1°! T~
5T7' 1^(§)
/
1
°f y TtOajS
NO
->
y
"* '
.. -i>_e
S UevP+ Sbtlla
l^SSSU
s
^-4 1 - rwj-»
-pJ
Lo
1 «W^T f? )
/
-w?fa / u.
0-
-OtH
. Gi=ocQ r i
y
^USIO
/
r.ai-i-cn^u-7
-u
T^lf-co—1 •*?
/
so- i«=rw /TTi
/
^
s
'V^I j)/,^ i/tto
'/is
1
•> — - 1 eA <—<-< 4-r»J Tl: e»_ d»
•»3«-iS2ra(a.''
/
bl-fVft QC^B7
"Rpt>
1 I
3- L,
3=sS3»
-r% ""BsGir-r*
SO-IS^Cf^"
L>-/~r-T_
£/£S u
UrxmS
i»0
u,n
/
¦ 1 ' ¦ ¦ NqT
2-7 •/£-«.. 0$
/
S /
^ ^
~r
S"7 /SvCE
/
^c^/TFcvn . tO
c;-u
"•=»-> 3.^=1 1
7l-,^
nnrw-tf |7t»l7
in
O c:
'
i
¦ 3=*®! I
EM1U54
/
/
313
~Ps>w*=1
y
H^n-T'^S3
;?
Pf/S '
1 — Fil# Copy
2 — P«rmit Copy
-------
WASTE TRANSFER LOG NUMBER
TRAILER NUMBER: f) 4 £ /& 4 DATE: ^ ~ 7 BY
/C ';
GENERATOR
MANIFEST
NUMBER
WPS
NUMBER
QUANTITY
DISPOSAL
4My F~r.n btvv,
l<=iZL U
v+f
lo
t>-st ,pJai-&
-------
APPENDIX D
-------
&EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
NOTICE OF INSPECTION
Forrrt Approved
OMB Xo 2070-0007
Approval expire! S-3JS5
1. INVESTIGATION IDENTIFICATION
2. TIME
DATE
INSPECTOR NO.
TT.r 941 [towoi
DAILY SEQ. NO.
Ol
3. FIRM NAME
Avw "See £ r\\J \ c c>-T) /7\£ nhi $
-------
US ENVIRONMENTAL P
VA A WASHINGTON
LaLfA TOXIC SUBSTANCE
* * TSCA INSPECTION CON
ROTECTION AGENCY
DC 204«0
S CONTROL ACT
FIDENTIALITY NOTICE
Form Approved
OMB No. 2070-0007
Approval *xp(rtt 8-31-85
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
Arv\£r ^Hl/lCOl\r^rfvi SSsV)C(£-
DATE | INSPECTOR NO. DAILY SEQ. NO.
I o&in-u 0\
3. INSPECTOR NAME
£7/ /5W>
4. FIRM ADDRESS
rc-u. 1, Qcn
^ "Jjr vi lie j
5. INSPECTOR ADDRESS
I/
-------
US ENVIRONMENTAL PROTECTION AGENCY
0^ VAJt WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
form Approved
OMB iVo 2070-0007
Approval expirit 8-3J 35
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
Aly^SLr -£c.a
DATE I INSPECTOR NO.
JO I otnni.
DAILY SEQ. NO.
C\
3. INSPECTOR ADDRESS
EFfi-NEZC
4. FIRM ADDRESS
I ^ BaX 1
k i i ^ j &yc>6/
INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION
NO.
DESCRIPTION
£S\w 0-e£./& ckS 0$ /£>/$ 9
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intend! to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE
CLAIMANT SIGNATURE /
—LX
NAME V
L ~ \ . £ f {iSc^n
NAME . '
TITLE
DATE SIGNED
TITLE
OATE SIGNED
iM*l
-------
&EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
RECEIPT FOR SAMPLES AND DOCUMENTS
Form ApprovKS
OMB No 2070-0007
Approval txplni 8-31-85
1. INVESTIGATION IDENTIFICATION
DATE
/ 6 jV-. Q 9
I INSPECTOR NO.
ocnnz.
3. INSPECTOR ADDRESS
EPP- -
daily seq.no
2, FIRM NAME
rv^-r £
\r a r) y\sl ^
do<.( 1/K,
4. FIRM ABDRE55
01 S3 , 0FC
Qoqxk
R-U I Bex 1^1
krn^si/ill* ^ bHoQl
The documents and samples of chemical substances and/or mixtures described below were collected in connection with the
administration and enforcement of the Toxic Substances Control Act.
RECEIPT OF THt: DOCUMENT(S) ANO/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
NO.
DESCRIPTION
^ ISO
1S
5 loi2jCt> ^ ~(J
tdb A^\yS\s L^orcJrcy
C £ L-1
OPTIONAL:
DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROVIDED D NOT REQUESTEdD
INSPECTOR SIGNATURE
T.
RECIPIENT
URE
NAME
I I I 50 1
h\ (^
TITLE
DATE SIGNED
IO 0^
£ )T\ \J - JJ- V/ ¦ 5^2
TITLE
DATE SIGNED
IM ^
EPA Form 7740-1 (12-82)
-------
f/EPA
us environmental protection agency
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
NOTICE OF INSPECTION
Form A pproved
OMB So 20 70 000 7
Approval expirei 3-31 Sj
1 INVESTIGATION IDENTIFICATION
2. TIME
DATE __
f/
INSPECTOR NO.
6677Z
DAILYSEQ NO.^^3^
3 FIRM NAME
DA/HO Rei{n$
4 INSPECTOR ADDRESS
A - A^no ^ _
T-S221
0 & , C & Q&2-2-J?
5. FIRM ADDRESS
RoCl'nf Qlr pe/-C*_ fec.
{jJcArrJlr , C-
C-«-
-h
IA
REASON FOR INSPECTION
&
Under the authority of Section 11 of the Toxic Substances Control Act;
For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establish-
ment, facility, or other premises in which chemical substances or mixtures or articles containing same are manufactured, proc-
essed or stored, or held before or after their distribution in commerce (including records, files, papers, processes, controls, and
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same in connection
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether the
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such premises or
conveyance have been complied with.
CD In addition, this inspection extends to (Check appropriate blocks)'.
CD A. Financial data CD D. Personnel data
CD 8. Sales data
CD C. Pricing data
CD E. Research data
The nature and extent of inspection of such data specified in A through E above is as follows;
INSPECTOR SIGNATURE
RECIPIENT SIGNATURE
NAME
NAME
T cn,
5~o >->
TTTUr
DATE SIGNED
ZDoma/-/? JS f /)lc2>o Que //
TITLE
pdC. • /IP?
3 OFFICE: 1983-661-893 /"?£/.2 - //¦> INSPECTION FILE
DATE SIGNED
EPA Form 7740-3 112-82)
•U.S. GOVERNMENT PRINTING OFFICE: 1983-661-893
-------
US ENVIRONMENTAL PROTECTION AGENCY
is WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
^^"1 M m TSCA INSPECTION CONFIDENTIALITY NOTICE
Form Approved
OMB So. 1070 0007
Approval txpfru 8-3 1-85
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
0 (2 /"V"\ C> fc? a i > »¦» 5"
DATE ] INSPECTOR NO. DAILY SEQ. NO.
ti ^ | 06 nnoi
3. INSPECTOR NAME
4. FIRM ADDRESS
fit's* Fc*s£,x2-S
6. CHIEF EXECUTIVE OFFICER NAME
«
TITLE
TITLE DATE SIGNED
ADDRESS /
-------
US ENVIRONMENTAL PROTECTION AGENCY
Mk WASHINGTON. DC 20460
TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
Form A pprooid
OMB So. 2070-0007
Approval expirtt 8-31-85
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
o ^o6)»os
DATE 1 INSPECTOR NO. DAILY SEQ. NO.
if ^ | can 2_ o i
3. INSPECTOR ADDRESS
£ *iC'xc-
3 1^5 gj } Sex 25221, ore.
-e_r , C
4. FIRM ADDRESS/^t
UUc-rAJw ^ £ '( tTo S&
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE
CLAIMANT SIGNATURE
/) Y??e£)(U*ouje //
TITLE DATE SIGNED
TITLE DATE SIGNED
&u). J
-------
A EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
RECEIPT FOR SAMPLES AND DOCUMENTS
IdatB
\\ To SB
h iNDCk^'I'OR ADDRE
1. INVESTIGATION IDENTIFICATION
daTpfTRTNTF
[TNlRCTSTFre-
£ PA - U E?
T3 Bo> 2£nn .PFC
y ) '
; CO goia5-
Form Approved
OMB So 2070-0007
Approval expirtt 8 31-85
2. FIRM NAME
\)(l TAO ' y< r
4. FIRM ADDRESS
Ro6,^5 A^~(3
VO orr r~—£ r o i
The documenti and samplei of chemical substances and/or mixtures described below were collected in connection with the
administration and anforcement of the Toxic Substances Control Act.
hbCEIPT OF THi; POCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
DESCRIPTION
CAOfa/ P,r\C^C&? 1^1
p > v^.
r
| OPTIONAL:
DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROVIDEO ~ NOT REQUESTED ~
INSPECTOR SIGNATURE
NAME
[TITLE
-T.
DATE SIGNED
x -1 y\ \j . 5
1 ( ~5<>-s Q'-f
RECIPIENT SIGNATURE
ZPotfA/fl B. ff}ZE>6tn
-------
c/EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DO 20460
TOXIC SUBSTANCES CONTROL ACT
NOTICE OF INSPECTION
Form Aooroved
OMB No 2070 0007
Etptres 3 31 -88
1 INVESTIGATION IDENTIFICATION
oc
12- ,}*»¦> u '
INSPECTOR NO.
06 7*12_
DAILY SEQ. NO.
01
2. TIME
OQZO
3. FIRM NAME
4. INSPECTOR ADDRESS _ NCl^
J&ox Z5~2.jl1. t QFc
0
I
-M
5. FIRM ADDRESS
in i-f a> &r
I LA J fil-
REASON FOR INSPECTION
Under the authority of Section 11 of the Toxic Substances Control Act:
% For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establish-
ment, facility, or other premises in which chemical substances or mixtures or articles containing same are manufactured, proc-
essed or stored, or held before or after their distribution in commerce (including records, files, papers, processes, controls, and
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same in connection
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether the
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such premises or
conveyance have been complied with.
~ In addition, this inspection extends to (Check appropriate blocks)'.
~ A. Financial data
G B. Sales data
~ C. Pricing data
O D. Personnel data
(Zl E. Research data
The nature and extent of inspection of such data specified in A through E above is as follows;
INSPECTOR SIGNATURE
7
RECIPIENJ^SIGN ATURE
NAME
J
£"///
$ o r>
TTTlT
/
DATE SIGNED
II of
NAME 7""
TITLE
(j-C ei<*W
DATE SIGNED
///*?
EPA Form 7740-3 (12-82)
-------
xvEPA
us environmental protection agency
WASHINGTON. OC 20460
TOXIC SUBSTANCES CONTROL ACT
TSCA INSPECTION COiM FIDENTIALITY NOTICE
Form Approved
0MB No 2070-000?
Eio/res 3-31 88
1. INVESTIGATION IDENTIFICATION
T
INSPECTOR NO.
OC102-
DAILY SEQ. NO
SEQ. I
01
2. FIRM NAME
I (Ac,
3 J-nc_
3 INSPECTOR NAME
D e ho
4. FIRM ADDRESS
£r U(for\
in fvr,u nv^r as
5. INSPECTOR ADDRESS
£pt\ -AJ£JTC
eici,. S3&°r ,DFC
Deists- CP
£rrdz\U j /lL
6. CHIEF EXECUTIVE OFFICER NAME
*\QcAcyLr
7. TITLE
g_ ( fa
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that EPA will receive public requests for release of the
information obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act (FOIA), 5 USC 552; EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act ITSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of the
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the information collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to be confidential business infor-
mation. If you assert a CBI claim, EPA will disclose the information
only to The extent, and by means of the procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you have claimed as confidential business information.
A confidential business information (CBI) claim may be asserted at any
time. You may assert a C8I claim prior to, during, or after the infor-
mation u collected. The declaration form was developed by the Agency
to assist you in asserting a CBI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential business information," it is
not necessary for you to use this form. The inspector will be glad to
answer any questions you may have regarding the Agency's CBI
procedures.
While you may claim any collected information or sample as confiden-
tial business information, such claims are unlikely to be upheld if they
are challenged unless the information meets the following criteria:
1. Your company has taken measures to protect the confi-
dentiality of the information, and it intends to continue
to take sucfi measures.
3.
4.
The information is not, and has not been, reasonably obtainable
without your company's consent by other persons (other than
governmental bodies) by use of legitimate means (other than
discovery based on showing of special need in a judicial or
quasi-judicial proceeding).
The information is not publicly available elsewhere.
Disclosure of the information would cause substantial
harm to your company's competitive position.
At the completion of the inspection, you will be given a receipt for all
documents, samples, and other materials collected. At that time, you
may make claims that some or all of the information is confidential
business information.
If you are not authorized by your company to assert a CBI claim, this
notice will be sent by certified meil, along with the receipt for docu-
ments, samples, and other materials to the Chief Executive Officer of
your firm within 2 days of this date. The Chief Executive Officer must
return a statement specifying any information which should receive
confidential treatment.
The statement from the Chief Executive Officer should be addressed
to:
and mailed by registered, return-receipt requested mail within 7 calen-
dar days of receipt of this Notice. Claims may be made any time
after the inspection, but inspection data will not be entered into the
special security system for TSCA confidential business information
until an official confidentiality claim is made. The data will be handled
under the agency's routine security system unless and until a claim is
made.
A42-^
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE;
I have received and read the notice
If there is no one on the premises of the facility who is authorized to make
business confidentiality claims for the firm, a copy of this Notice end other
inspection materials will be sent to the company's chief executive officer. If
there is another company official who should also receive this information,
please designate below.
SIGNATURE
NAME
T"
NAME
TITLE
c h >->! i • £T/ /1
So n
Q£*e.-rti(
TITLE
DATE SIGNED
(2_ S H
ADDRESS
So*.
EPA Form 77404 (12-82)
-------
US ENVIRONMENTAL VfiOTEC + ION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
i
form Aoprove<3 I
OMB No 2070-OQQ7
Etoires 3 3) 38
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
C. l~—i e y*t j -I J1 C.
DATE
11 3V. 01
INSPECTOR NO.
oenn -L.
DAILY SEQ. NO.
a /
3. INSPECTOR ADDRESS £¦ f
G f«*j £1 jyiLl ; O^C
) C 0 6C,^g-
4. FIRM ADDRESS
(9 mn',u fVisrlG^ /LI
£ 1 L< ^ L
information designated as confidential business information
NO.
DESCRIPTION
D-zc/frrtd O.S of ! 1- 8
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above it designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: 11) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information it not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE
(Lr^ \ ^—<
CLAIMAfp^JIGNATURE ,
NAME //
l-> V\ I - ^11 1
G~£neV*/
title
£ rs o . jT 1/ -
-------
AEPA
us environmental protection agency
WASHINGTON, DC 10*00
TOXIC SUBSTANCES CONTROL ACT
RECEIPT FOR SAMPLES AND DOCUMENTS
Form Approved
OMB No 2070-0007
Approval expires 3-31-88
1. INVESTIGATION IDENTIFICATION
1. FIRM NAME
^ 1 v«^ ^je. -I n<; _
DATE (INSPECTOR NO. DAILY SEQ. NO.
12 9 -i
' J
AL
The documents and samples of chemical substances and/or mixtures described below were collected in connection with the
administration and enforcement of the Toxic Substances Control Act.
RECEIPT OF THE DOCUMENTS) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
NO.
DESCRIPTION
Tl
6 1i,^ (Lg. /I ft
4- $ u. j^, p (j£ r~-H v-ClS^ ^ ^ 1 5 tj
OPTIONAL:
DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROV
IDED^^
NOT REQUESTED
~
INSPECTOR SIGNATURE
NAME
Jol-n
TITLE
FuJ. L
IT CU,c*
date signed
_Lr\ S<
j-sfl <
I 2_
R ECIPIENJLSIG NATURE
^Z.
NAME
TITLE
/O /c
U-&vye^i. f
(jSyi. At'
EPA Form 7740-1 (12-82)
------- |