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MFS Response to Hazardous Material Violations: <br /> PR0543517-1325 EI Pinal-Compliance-8-3-21 OIR <br /> Page 1 of 7 <br /> 3. HSC 25507 Failed to establish and implement a hazardous materials business plan. <br /> OBSERVATION: A Hazardous Materials Business Plan has not been established or implemented. <br /> According to the Lathrop-Manteca Fire Department and personnel at Forward Landfill, located <br /> at 9999 S. Austin Rd. Manteca, CA, on 7/8/2021 Metal Finishing Solutions transported twenty- <br /> one (21)(21) 55-gallon hazardous materials drums and sixty-two (62) 5-gallon hazardous <br /> materials containers to Forward Landfill for disposal, causing a hazardous materials spill and off- <br /> gassing of hazardous materials at the landfill.According to Rob Ashe, Metal Finishing Solutions <br /> representative,twenty-three 55-gallon hazardous materials drums and seventy-one 5-gallon <br /> hazardous materials containers were transported to the landfill. Per Rob,the drums and <br /> containers had been triple-washed and were empty except for the following: <br /> - A triple-washed 55-gallon plastic drum of Gardobond 7140/1 (UN 2031)contained 1-gallon <br /> of water based on pH reading. <br /> - A(non-triple-washed) 55-gallon plastic drum of Gardobond 7140/1 (UN2031) contained 1- <br /> gallon of Gardobond 7140/1 mixed with water based on pH reading. <br /> - A triple-washed 55-gallon plastic drum of Gardobond 7140/1 (UN 2031)contained 1/2- <br /> gallon of water based on pH reading. <br /> - A(non-triple-washed) 55-gallon plastic drum of Inproclean 3800 (UN 3266) contained 1- <br /> 1/4-gallons of Inproclean 3800 mixed with water based on pH reading. <br /> - A triple-washed 55-gallon plastic drum of Enprox 702 (UN 2796) contained 3/4-gallon of <br /> water based on pH reading. <br /> - A triple-washed 55-gallon plastic drum of Gardobond x 4707-E (UN 1760) contained 1/16- <br /> gallon of water based on pH reading. <br /> - A(non-triple-washed) 55-gallon plastic drum of Hydrochloric acid 31% (UN 1789) contained <br /> 1/2-gallon Hydrochloric acid mixed with water based on pH reading. <br /> - A(non-triple-washed) 5-gallon container of Gardobond Additive 7255 (UN 2922) contained <br /> 1/2-gallon Gardobond Additive 7255 mixed with water based on pH reading. <br /> - A(non-triple-washed) 5-gallon container of Gardobond Additive 7255 (UN 2922)contained <br /> 1/4-gallon Gardobond Additive 7255 mixed with water based on pH reading. <br /> - A triple-washed 5-gallon container of Gardobond Additive 7255 (UN 2922) contained 1/4- <br /> gallon water based on pH reading. <br /> REGULATION GUIDANCE:A Hazardous Materials Business Plan shall be established and <br /> implemented for emergency response to a release or threatened release of a hazardous <br /> material when storing hazardous materials at or above the thresholds quantities of 55 gallons <br /> for materials that are liquids, 500 pounds for solids, or 200 cubic feet for compressed gas, at <br /> standard temperature and pressure. <br /> Metal Finishing Solutions (MFS) Response: <br /> A Hazardous Material Business Plan was established in 2017-18 and submitted. At the end of <br /> 2020, MFS submitted and Certified the 2021 HMBP Updates. From this, SJC-EHD approved all <br /> aspects of the HMBP by January 2021—below: <br />