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Robert Lopez [EH] <br /> From: Hendershot, Gary (WFP Tomball) <gary.hendershot@westwayfeed.com> <br /> Sent: Wednesday,June 5, 2019 9:06 PM <br /> To: Robert Lopez [EH] <br /> Cc: Torres, Andrew (WFP Stockton); LOPEZ, Keith (WFP Stockton); Darby, Chuck (WFP <br /> Seattle) <br /> Subject: RE: PR0520152; Westway Feed Products Inspection Report and Photos <br /> Attachments: WFP Stockton SJCEHD HMBP RTCC 20190605 (full report).pdf <br /> Mr. Robert Lopez, <br /> In response to the Hazardous Materials Program Inspection Report of May 10, 2019, 1 submit via email and <br /> USPS (Certified Mail° Receipt: 7017 1070 0000 7887 2252) the following corrective actions to address the <br /> reported "violations" and "repeat violations" to receive RETURN TO COMPLIANCE CERTIFICATION: <br /> #5 HCS 25505(a)(1) failed to complete and/or submit hazardous materials inventory for all reportable <br /> materials on site. <br /> • The two (2) 55-gallon drums of Coil Guard 400 has been added to <br /> CERSID-10183333—HazMatlnventory. This was an oversite when submitting the report on January 15, <br /> 2019. <br /> • Other reportable materials that were listed as "not being accurate" in relationship to "Chemical <br /> Location" versus the site map and hazardous material inventory have been updated, along with the <br /> site map (HMBP Figure 1, primary site map for "Chemical Locations" and "Grid Numbers") in CERS. <br /> • The HMBP Figure 1 "site map" and "Attachment" listing all hazardous materials on site (>500 lbs, >55 <br /> gallons and >200 cu.ft.) has been updated and uploaded to CERS. <br /> o Note: Oxygen and acetylene will be listed in the CERSID_10183333_HazMatlnventory and the <br /> "Attachment" to address this finding of May 10, 2019. As soon as I received confirmation that <br /> these two (2) chemicals have been removed from the facility, I will ensure the CERS has been <br /> updated within 30 days of the change. <br /> #6 HSC 25505(a)(2)failed to complete and/or submit a site map with all required contents. <br /> • As stated above, the HMBP Figure 1 "site map" and "Attachment" listing all hazardous materials on site <br /> (>500 lbs, >55 gallons and >200 cu.ft.) and CERSID_10183333_HazMatlnventory have been updated <br /> and/or uploaded to CERS. <br /> #11 HSC 25505(a)(4) failed to provide or document initial and/or refresher training to appropriate personnel. <br /> • The explanations provided in this section of the report do not provide us with accurate details as to <br /> what "documentation for initial and/or refresher training to appropriate personnel"? <br /> • Per the attachment, Keith Lopez provide Mr. Robert Lopez these "training reports" and Keith <br /> understood this information met the "training requirements" that were requested. <br /> • Per information in this section of the report, the two (2) 55-gallon drums of Coil Guard 400 was an <br /> oversite of the 1/15/19 submittal and have been updated in the CERSID-10183333—HazMatlnventory. <br /> • However, the seven (7), 265-gallon sodium hydroxide not being reported in the 1/15/19, this was <br /> reported in CERSID-10183333— <br /> 10183333_HazMatlnventory (1/15/19). This is referenced as Sodium Hydroxide <br /> Solution (aka —Caustic Soda —Sodium Hydroxide 50%; CAS 1310-73-2). This is listed as a "mixture (b)", <br /> 1 <br />