COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

the treatment system.The data must demonstrate that the fluoride or metal content of the waste streams do not exceed hazardous waste regulatory levels. a. Response:The Treatment System Waste analysis plan for rinse tanks 3,4,6,7,9,10, and 11 will be submitted separately to Elianna Florido -San Joaquin County Environmental Health Department, pending sampling laboratory analysis report review and incorporation into the Waste Analysis Plan. 3. Violation 113-Submit a copy of the hazardous waste treatment inspection schedule. a. Response:The facility's hazardous waste treatment inspection schedule is a daily inspection that occurs during all operation days.The facility typically operates two (2) 8 hours shifts Monday— Friday. In some instances, operations will also occur on some Saturdays, and the hazardous waste treatment system will be inspected. Hazardous Materials Program Inspection: 1. Violation 3—Submit a corrective action statement and supporting documentation explaining how the facility's Hazardous Materials Business Plan has been updated to prevent future releases/inappropriate waste disposal similar to the disposal that occurred on 7/8/2021 at Forward Landfill. a. Response: A Hazardous Material Business Plan was established in 2017-18 and submitted.At the end of 2020, MFS submitted and Certified the 2021 HMBP Updates. From this, SJC-EHD approved all aspects of the HMBP by January 2021.The Emergency Response Plan (ERP)that was implemented was based more on potential releases in and around the Facility.The ERP was based on training, a coordination of emergency response MFS employees, a certified Hazardous Materials contractor and Agency Notifications. Increased supervisory and personnel training will ensure that this error will not occur again. 2. Violation 5— a. Update the hazardous materials inventory on CERS to include the two 250-gal totes and one 55-gal drum labeled "Cleaning Compound Sludge and Waste Corrosive Basic Liquid", and the seven 55-gal drums of unknown possible hazardous waste. i. Response: Manifest#016134871 FLE for the two (2) 250-gallon totes— attached. ii. Response: Manifest#016134872 FLE, which included the 8 mentions 55-gallon drums—attached. b. Update the hazardous materials inventory on CERS to correct the following: i. The max daily amount for Hydrochloric Acid 15-37% is inaccurately reported on CERS as 110 gallons. At least sixteen 55-gallon drums, or 880 gallons, of Hydrochloric Acid 15-37%was observed on-site. 1. Response: CERS has been updated on September 30, 2021. ii. The max daily amount for Sodium Hydroxide 1-50%aqueous solution is inaccurately reported on CERS as 110 gallons.At least twenty 55-gallon drums, or 1100 gallons, of Sodium Hydroxide 1-50%aqueous solution was observed on- site. 1. Response: CERS has been updated on September 30, 2021. iii. The max daily amount for Diesel Fuel No. 2 is 100 gallons and the largest container amount is 120 gallons.The max daily amount cannot be less than the size of the largest container. 1. Response: CERS has been updated on October 5, 2021.