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<mhenry Cd s'sov.ora>; Florido, Elia nna [EHD]<efloritlo CNsiaoy.org>;Tony Grizelj<tonva(b7JLPrecisionsom> Subject RE: Metal Finishing Solutions RTC Follow Up Hi Scott, 1 reviewetl the information we have and here's the list of Items remaining to resolve the open violations: RCRA Larg¢Quantity Generator Inspection: 1. Violations 112, 201,202,203,and 406- a. Train employees on how to empty hazardous materials containers to California standards.Submit proof of training.See attached training records,both Haz Mat Waste and Universal Waste Training. In addition, MFS Stockton Supervisory personnel also plan to sign up a another 2022 NES Haz Mat Waste training Seminar b. Demonstrate how the empty containers will be managed. You can do one or more of the following per Title 22 California Code of Regulations 66261.7 i. 5entl the containers off site as hazardous waste using a uniform hazardous waste manifest. No. ii. Demonstrate that the non-rinsed empty hazardous materials containers are not haza rtlous waste with a documented hazardous waste determination for each type of container/material. No. iii. Update your hazardous waste treatment permit and rinse the containers on-site. Once the containers are rinsed to remove any remaining residue they can be placed in the trash. Explain how the residue will be managed properly.The rinsate Is extremely dilute and treated in the Waste Neutralization System sim filar to the process line rinse tank's waters.Once the containers are rinsed Tripled Rinsed,containers are s[a cked for recycling purposes. iv. Reclaim the containers scrap value on-site.No. v. Use the container to store hazardous materials or hazardous waste on-site.A few of the rinsed container are utllizetl of to score and then ship haza rtlo us waste off-site. vi. Send the container to a person who reclaims the containers scrap value.The bulk of the rinsed containers are shipped off-site for recycling.This recycling is a paitl service i vii. Recondition or reman ufacture the container on-site. No. will. Shipping the container to a person who reconditions or remanufactures the container. No. c. If you are shipping non-rinsed empty hazardous materials containers to ABCO Products or anyone else, submit a letter from the receiving facility that explains how the containers comply with- -. The letter must list all of the hazardous materials the containers were used to store. Additionally,submit complete shipping papers to demonstrate that the containers are going From Metal Finishing Solutions to the receiving facility. No. 2. Violation 115-At the time of inspection on 7/20/21 Chad Velm stated the processing line baths 2,5,antl 8 were clea netl out within the two months prior.Submit a statement co nflrming when the waste cleaned out from baths 2, 5, and 8 was shipped off-site for disposal and provitle the uniform hazardous waste manifests for this waste.See Statement and Manifest 016134872 FLE—attoched. 3. Violation 303- Submit the uniform hazartlous waste manifest for the clean out of the processing line secondary containment containing solids and liquids with pH 1.5 observed at the time of inspection.See Manifest 016135035FLE—ottoched. 4. Violation 505-Submit photos of the corrosive resistant coated concrete secondary containment for the wastewater treatment system. Submit a statement describing the coating used on the concrete. P¢rmit By Rule Treatment Insp¢ction: violation 112: a. Provide more tleta]I and clarification in the waste analysis plan on the following items: 3