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The following is an itemized list of permit by rule tiered permit violations that have not been addressed for METAL FINISHING SOLUTIONS - STOCKTON CA as of December 14, 2021. Open violations from July 20, 2021 inspection Violation #112 - 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 flouride 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. REGULATION GUIDANCE: (a)(1) Before an owner or operator transfers, treats, stores, or disposes of any hazardous waste, or non -hazardous waste if applicable under section 66265.113(d), the owner or operator shall obtain a detailed chemical and physical analysis of a representative sample of the waste. At a minimum, this analysis shall contain all the information which must be known to transfer, treat, store, or dispose of the waste in accordance with the requirements of this chapter and chapter 18 of this division. (2) The analysis may include data developed under chapter 11 of this division, and existing published or documented data on the hazardous waste or on hazardous waste generated from similar processes. (A) The facility's record of analyses performed on the waste before the effective date of these regulations, or studies conducted on hazardous waste generated from processes similar to that which generated the waste to be managed at the facility, may be included in the data base required to comply with subsection (a)(1) of this section. (B) The owner or operator of an off-site facility may arrange for the generator of the hazardous waste to supply part or all of the information required by subsection (a)(1) of this section, except as otherwise specified in section 66268.7(b) and (c). (3) If the generator does not supply the information as specified in subsection (a)(2)(B) of this section, and the owner or operator chooses to accept a hazardous waste, the owner or operator shall obtain the information required to comply with this section. (4) The analysis shall be repeated as necessary to ensure that it is accurate and up to date. At a minimum, the analysis shall be repeated: (A) when the owner or operator is notified, or has reason to believe, that the process or operation generating the hazardous waste, or non -hazardous waste, if applicable under section 66265.113(d), has changed; and (B) for off-site facilities, when the results of the inspection required in subsection (a)(5) of this section indicate that the hazardous waste received at the facility does not match the waste designated on the accompanying manifest or shipping paper. (5) The owner or operator of an off-site facility shall inspect and, if necessary, analyze each hazardous waste movement received at the facility to determine whether it matches the identity of the waste specified on the accompanying manifest or shipping paper. (b) The owner or operator shall develop and follow a written waste analysis plan which describes the procedures which the owner or operator will carry out to comply with subsection (a) of this section. The owner or operator shall keep this plan at the facility. At a minimum, the plan shall specify: (1) the parameters for which each hazardous waste, or non -hazardous waste if applicable under section 66265.113(d), will be analyzed and the rationale for the selection of these parameters (i.e., how analysis for these parameters will provide sufficient information on the waste's properties to comply with subsection (a) of this section); (2) the test methods which will be used to test for these parameters; (3) the sampling and sampling management methods which will be used to obtain a representative sample of the waste to be analyzed. The sampling, planning methodology, equipment, sample processing, documentation and custody procedures shall be in accordance with either: (A) one of the sampling methods described in Appendix I of chapter 11 of this division; or (B) an equivalent sampling method. (4) The frequency with which the initial analysis of the waste will be reviewed or repeated to ensure that the analysis Page 2 of 3