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MFS Response to Hazardous Material Violations: PR0543520-1325 EI Pinal-Compliance-8-3-21 OIR Page 4 of 8 112. CCR 67450.3(c)(8-9) Failed to prepare and implement a waste analysis plan and retain analytical results. OBSERVATION: This hazardous waste treatment facility does not have a complete and correct waste analysis plan. The facility operators could not provide a waste analysis plan during the inspection for the hazardous waste treatment system. According to Chad Yelm and Jason Torres, the facility processes the following waste streams using the hazardous waste treatment system: Rinse tanks 3,4,6,7,9,10,11 and clean out of the secondary containment under the processing line. These eight unique waste streams need separate chemical analysis at the point of waste generation before the wastes enter the treatment system. This data must demonstrate that the fluoride or metal content of the waste streams do not exceed hazardous waste regulatory levels. The treatment system only adjusts for the pH and does not remove fluorides or metals. Chad Yelm stated that the contents of tanks 2, 5 and 8 are removed from the site as hazardous waste multiple times a year, when the tank contents become waste. The following tanks do not contain waste: Tank 1 is a loading area, Tanks 12 and 13 are driers. CORRECTIVE ACTION: Provide a complete treatment system waste analysis plan to the EHD within 30 days. See the REGULATION GUIDANCE above for details needed in the waste analysis plan. The plan must include point of waste generation analytical data for all hazardous waste streams that are processed through the treatment system (rinse tanks 3,4,6,7,9,10,11 and clean out of the secondary containment under the processing line). For example, for tank 3, the sample must be taken from the tank just prior to pumping the waste to the treatment system. Metal Finishing Solutions (MFS) Response: Per discussions with SJC-EHD on August 23, 2021, and correspondence with SJC-EHD Staff, MFS was gathering information for which process tanks needed to be sampled and analyzed for the Waste Analysis Plan (WAP). During our August 23, 2021 discussion, SJC-EHS Staff directed all process tanks should be tested and analyzed for the WAP, but subsequently gave updated information that only the rinse tanks (waters that are treated by the PBR — WTS) should be analyzed. These tanks are 3,4,6,7,9,10 & 11. These tanks will be analyzed for CAM 17 metals, fluoride and mercury using methods 208.1, 245 and 300.1, and will be inclorporated into the Facility's WAP, scheduled for completion by October 2, 2021. 113. CCR 67450.3(c)(8-9) Failed to prepare a treatment system inspection program and maintain inspection logs REGULATION GUIDANCE: Title 22 California Code of Regulati