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FAIP-Hayward 7-21-09

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     Facility Audit Information Package
            Recycling Services &
        Environmental Information


    Container Management Services, LLC
                 21301 Cloud Way
                Hayward, CA 94545
                  (510) 786-9762


                STEEL CONTAINER
          RECONDITIONING AND RECYCLING

               IBC RECONDITIONING

     POLY DRUM RECONDITIONING AND RECYCLING




                 Revised July 24, 2009, 2009
                                   TABLE OF CONTENTS

                                                                 Page

1.       Facility Identification                                  3

2.       Company Organization                                     3
         2.1  Facility                                            3
         2.2  Corporate                                           3

3.       Permits and Authorizations                               4
         3.1   Permits                                            4
         3.2   Agency Contacts                                    4

4.       Facility Description                                     5

5.       Container Reconditioning                                 5
         5.1   Container and IBC Acceptance Criteria              6
         5.2   Tighthead Reconditioning-Wash Line (Plant 2)       6
         5.3   Sanitize and Crush-Steel Recycling                 7
         5.4   Poly Drum Recycling                                7
         5.5   IBC Reconditioning                                 7
         5.6   Transportation Services                            8
         5.7   Waste Generation and Disposal                      8

6.       Processes Generating Wastes                              8
         6.1   Primary Wastes                                     8
         6.2   Secondary Wastes                                   8
         6.3   Excluded Recyclable Materials                      9

7.       Training, Safety, Inspection and Contingency Plan        9
         7.1    Employee Training                                 9
         7.2    Safety                                            9
         7.3    Inspections                                       9
         7.4    Contingency Plan                                  10

8.       Insurance                                                10




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Environmental Compliance and Facility Audit Information Packet
9.       Exhibits
         1 – Plant Location                                      11
         1A – Site Map                                           12
         2 – CMS, LLC and Myers Acceptance Policy                13
         3 – Waste Streams and Disposal Facilities               15
         4 – IBC Reconditioning Process                          16
         5 – Poly Drum Reconditioning Process                    17
         6 – Corporate Structure                                 18
         7 – Site History                                        19
         8 – Organization Chart                                  20




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Environmental Compliance and Facility Audit Information Packet
1.       FACILITY IDENTIFICATION

Facility Name                                             Container Management Services, LLC
                                                          Hayward Steel Drum and IBC
                                                          Reconditioning, Poly Drum
                                                          Reconditioning and Recycling

Facility Address                                          21301 Cloud Way
                                                          Hayward, CA 94545

Phone Number                                              (510) 786-9762

EPA ID #                                                  CAR000031526

SIC Code                                                  7699

NAICS                                                     811310

Corporate Office                                          Container Management Services, LLC
                                                          8435 NE Killingsworth
                                                          Portland, OR 97220


2.       COMPANY ORGANIZATION




2.1      FACILITY

Operations Manager                                        Andres Barajas

Plant Manager                                             Benjamin Rivera

IBC Manager / EH&S Tech                                   Carmelo Portillo

2.2      CORPORATE

CEO                                                       Kyle Stavig

Vice President/CFO                                        Christian Stavig

Director of Operations                                    Andres Barajas

Environmental Manager                                     Sean Reynolds

Environmental Technician                                  Larry Jenkins
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Environmental Compliance and Facility Audit Information Packet
3.       PERMITS AND AUTHORIZATIONS

The Hayward facility is permitted as a hazardous waste generator.

3.1      PERMITS

Permit                                           Permit No.             Issued By

EPA ID Number                                    CAR000031526           EPA

Conditional Authorization                        N/A                    CAL/EPA-DTSC

Hazardous Waste Transporter                      3665                   CAL/EPA-DTSC

Permit to Operate                                #1965                  BAAQMD

Wastewater Discharge                             88-101-IMN             City of Hayward

Fire Department HM Storage                       96-101                 Hayward Fire Dept.

Stormwater Discharge                             2-01S003334            SWRCB

3.2      AGENCY CONTACTS


Bay Area Air Quality Mgmt. District                              Hayward Fire Dept. (CUPA)
939 Ellis Street                                                 Hazardous Materials Office
San Francisco, CA 94109                                          777 B Street
415.771.6000                                                     Hayward, CA 94541-5007
                                                                 (510) 583-4910
                                                                 Steve Buscovich

City of Hayward-Public Works Dept.
Water Pollution Source Control
24499 Soto Road
Hayward, CA 94544
(510) 881-7997
Will Freeman




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Environmental Compliance and Facility Audit Information Packet
4.       FACILITY DESCRIPTION

The Container Management Services, LLC Hayward reconditioning plant is a
10.2 acre facility located in Hayward, California. The facility is located in an area
zoned for light industrial and commercial activities. The facility is bounded on the
east by Cloud Way and Avitech Aviation, on the south by Antone Manufacturing,
on the west by AC Transit, and on the north by Sabre Street. The entire facility is
fenced and access to the site is limited. The site is paved and there is one
building which houses office, warehouse and reconditioning process areas.
EXHIBIT 1 is a map showing the location of the facility.

The CMS, LLC facility primarily reconditions tighthead 55 gallon steel drums,
Intermediate Bulk Containers (IBC’s), and to a lesser degree, polyethylene
drums. The facility is separated into three processing areas:
      Plant 1 - (formerly used for new drum manufacturing) warehousing and
                painting of steel drums
      Plant 2 – steel drum and poly drum wash line
      Plant 3 - poly drum rinsing, grinding, shredding and plastic recycling,
                 and the IBC reconditioning line

EXHIBIT 1A is a site layout map.


5.       CONTAINER RECONDITIONING

Drum reconditioning plays a vital role in resource recovery. For every new drum
manufactured in a given year, two drums are reconditioned. In California, empty
drums are considered a hazardous waste unless they are managed by sending
them to a drum reconditioner (Title 22 §66261.7(e)(3)). In the past, empty drums
were frequently crushed and sent to a Class 1 landfill. A crushed, empty
container occupies about two cubic feet of space. For every 200,000 drums
reconditioned – that is the equivalent of one acre-foot of landfill space (think of 13
football fields, one foot deep). This is in addition to the energy and resource
savings obtained in reconditioning the drum or reclaiming it as scrap steel, as
opposed to the manufacturing of steel to make a new drum. At an average of 45
pounds per drum, that same 200,000 reconditioned drum equates to 4,500 tons
of steel that has not been sent to a landfill. Drums that have reached the end of
their usable life are cleaned, crushed and sent to a steel recycler.

Although Title 22 §66261.7 requires an empty drum to be “emptied to the extent
possible” (i.e. drip dry), up to two cups (or 16 ounces) of residuals may in fact
remain in the drum. As the preponderance of drums received at the CMS, LLC
Hayward facility have previously contained oil, the wash process is able to
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Environmental Compliance and Facility Audit Information Packet
recover it for recycling by a permitted oil recycler. This equates to 25,000 gallons
of oil recovered for every 200,000 drums processed.

CMS, LLC accepts only containers that are empty as per Title 22 §66261.7 at the
Hayward facility. Container acceptance is based on the residuals of the former
contents of the container.

5.1      CONTAINER AND IBC ACCEPTANCE CRITERIA

Before an empty container can be sent to this facility for processing, it must first
be approved by the Environmental Department. Approvals are necessary due to
the presence of trace amounts of residue that may still be in an empty container.
Some of these residues are an unacceptable risk from an employee health and
safety standpoint, are not compatible with the cleaning process, or are
specifically prohibited by permit conditions.

New customers are required to submit a Material Safety Data Sheet for the
product that the drum last contained. The MSDS is reviewed and a decision is
made as to its suitability for either the wash or burn cleaning process.

For our Acceptance Policy, see EXHIBIT 2.

5.2      TIGHTHEAD RECONDITIONING - WASH LINE (Plant 2)

The tighthead reconditioning process consists of interior rinsing with hot water to
remove the bulk of any product residues remaining in the drum. Drums that
require additional interior cleaning are sent to the hard flusher (sodium hydroxide
solution interior rinse). Drums that are rusty or have hardened residues are sent
to the chainer. The chaining process involves placing steel abrasive chains and
approximately one gallon of caustic inside the drum and rotating it for a period of
time. The next step is a hot water exterior rinse to remove oil and dirt adhering to
the outside of the drum. The next step is the Roto-flush interior cleaner. The
Roto-flusher cleans the interior of the drums with a combination of hot caustic
and high pressure. This operation is followed by a hot water rinse. At this point
in the process, if the drum still contains rust or scale, it is diverted to the acid
rinse station. The drums are then tested for leaks, dried in an oven, and shot
blasted to remove the exterior paint. The drums are then painted to customer
specifications and shipped out.

Drums are inspected at every point in the reconditioning process; those not
meeting quality standards, or are defective, are diverted for either processing as
an openhead drum, or they are sent to a steel recycler. A process flow diagram
is included as EXHIBIT 4.




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Environmental Compliance and Facility Audit Information Packet
5.3      SANITIZE AND CRUSH - STEEL RECYCLING

Steel drums that are not reconditionable, or have reached the end of their usable
lifespan, are cleaned, crushed and sent to a steel recycler. Drums that are
rejected during the wash process are sent directly to the crusher for processing.

5.4      POLY DRUM RECYCLING

Polyethylene drums are processed by a series of rinse cycles. Most are returned
to the original filler, and are refilled with the same product that was previously
contained in the drum. Poly drums that are not reconditioned are cleaned,
shredded and pelletized. The plastic pellets are sent to a plastic recycler.

5.5      IBC RECONDITIONING

The IBC reconditioning process consists of:

1.       Interior rinsing with hot water and sodium hydroxide solution to remove the
         bulk of any product residues remaining in the IBC.

2.       Second rinse with hot water to clean and flush out the sodium hydroxide
         solution.

3.       Rinse the interior and exterior of the IBC with clear, hot water at.

4.       At this point the IBC is dried; Reconditioned or new drain valves are
         installed as required, then IBC is pressure tested.

Reference:
49CFR Part 180 – Continuing Qualification and Maintenance of Packagings
Subpart D. Qualification and Maintenance of Intermediate Bulk Containers

See EXHIBIT 6 for flow chart.



5.6      TRANSPORTATION SERVICES

CMS, LLC will pick up a minimum of fifty empty steel drums in the local area of
the plant location. All drums picked up by CMS, LLC are inspected prior to being
loaded on the truck. Drums that do not meet acceptance criteria, (i.e. excessive
product or are on the non-accept list) are not picked up. Drums arriving at the
facility by other carriers (common carriers or customer delivery) are inspected at
the facility. Drums that do not meet the acceptance criteria are returned to the
customer.


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Environmental Compliance and Facility Audit Information Packet
5.7      WASTE GENERATION AND DISPOSAL

Wastes are generated as a result of the various reconditioning processes.
Hazardous and nonhazardous wastes are segregated at the point of generation
and are not commingled. The CMS, LLC Hayward facility is permitted as a
Generator for wastes generated during the reconditioning process. The facility
also has a Conditional Authorization permit for the treatment of wash waters
which are reused or discharged to The City of Hayward POTW.

Hazardous wastes generated at this facility are manifested and sent for disposal
at an approved and permitted disposal facility. EXHIBIT 3 is a list of wastes and
the disposal facility used for each waste stream.


6.       PROCESSES GENERATING WASTES

6.1      PRIMARY WASTES

           Waste Stream                                     Process Generating
           Shot Blast Dust/Grit/Ash                         Exterior cleaning of tighthead drums and ash
                                                            collected from the drum furnace.
           Caustic Liquid                                   Spent sodium hydroxide cleaning solution.
           Used Oil                                         Siphoning oil residues from containers,
                                                            generated during interior and exterior wash
                                                            cycles.
           Caustic Sludge                                   Removal of sludge from process equipment.
           Paint Booth Debris                               Cardboard, plastic and aluminum foil used in
                                                            the paint booth.

6.2      SECONDARY WASTES

           Waste Stream                                     Process Generating
           Sludge Containing Metals                         Cleanout of California Permitted IWW
                                                            treatment tanks.
           Corrosive Liquids,                               UF/NF Concentrate
            Liquids Containing Metals




6.3      EXCLUDED RECYCLABLE MATERIALS

           Waste Stream                                     Process Generating
           Paint and Solvent                                Flushing of paint lines during color changes.



         CMS recovers all of the paint and solvent generated during color changes
         at the drum paint booth. This mixture of paint and solvent is collected in a
         drum and applied to the bottoms of the reconditioned drums as a coating.


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Environmental Compliance and Facility Audit Information Packet
7.        TRAINING, SAFETY, INSPECTION AND CONTINGENCY PLAN

7.1       EMPLOYEE TRAINING

All employees are given training for site safety and general operations.
Employees whose job responsibilities include handling of hazardous waste or
materials receive Emergency Action Plan, Hazardous Communications, and
Hazardous Waste Generator training. Additionally, training is provided under
DOT HM-126f, Function Specific and General Awareness Training. Employees
required to wear respirators receive training and fit testing prior to issuance of
respirators.

7.2       SAFETY

Employee health and safety is a primary concern for CMS, LLC. Safe work
practices and prevention to exposures of hazardous materials include:

         Regular safety meetings that address the potential hazards associated
          with specific plant operations and general safety issues, such as accident
          prevention.

         Providing appropriate safety equipment to employees such as safety
          glasses, hearing protection and gloves.

         Requiring the use of air purifying respirators in areas of potential
          employee exposure to hazardous materials or wastes.

7.3       INSPECTIONS

Inspections are performed daily, weekly and/or monthly, and are recorded on
appropriate checklists. Inspections include hazardous waste storage, satellite
accumulation areas, stormwater discharge monitoring, safety equipment and
outside drum storage and Conditional Authorization Permitted units. Items
requiring corrective action are noted on the inspection form along with the
corrective action taken.

Additional inspections and audits are performed periodically by CMS, LLC
environmental compliance personnel and by customers selling drums to CMS.
Results of these inspections are reported to the plant manager for corrective
action.

7.4       CONTINGENCY PLAN

The CMS, LLC contingency plan was developed in accordance with 40 CFR
265.50 – 265.56, and California Code of Regulations Title 22 §66262.34 (a) (4).
This plan describes the actions facility personnel will take in response to fires,
explosions or unplanned releases of hazardous wastes. This plan also identifies
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Environmental Compliance and Facility Audit Information Packet
the primary Emergency Coordinator (EC) and alternate EC’s who are authorized
to coordinate required actions in the event of an emergency.

This contingency plan has been distributed to all appropriate agencies. Plan
changes or updates are also distributed.


8.       INSURANCE

CMS, LLC maintains general liability, automobile and workers’ compensation
insurance coverage. A copy of the insurance certificate is available upon
request.


9.       OTHER EXHIBITS

Exhibit 4                    IBC Reconditioning Process

Exhibit 5                    Poly Drum Reconditioning Process

Exhibit 6                    Corporate Structure

Exhibit 7                    Site History

Exhibit 8                    Organization Chart




EXHIBIT 1 -- PLANT LOCATION
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EXHIBIT 1A -- SITE MAP




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 2 – CMS, LLC ACCEPTANCE PROCEDURE AND POLICY

RoundTriptm Empty Container and IBC Disposal
CMS is only permitted to accept empty containers. Failure to abide by these rules may
result in substantial charges.

Step 1 - Review our Acceptance Procedures
All Drums or IBCs with Hazardous and Non-Hazardous residues must be:
        Pourable Materials - Drip-dry empty - (if we can pour it, you can pour it...)
If the hazardous material which the container or inner liner held is pourable, no hazardous
material can be poured or drained from the container or inner liner when the container or
inner liner is held in any orientation (e.g., tilted, inverted, etc.); and
        Not Pourable Materials - No hazardous material remains in or on the container
If the hazardous material which the container or inner liner held is not pourable, no
hazardous material remains in or on the container or inner liner that can feasibly be
removed by physical methods (excluding rinsing) which comply with applicable air
pollution control laws and which are commonly employed to remove materials from that
container or inner liner. Following material removal, the top, bottom and sidewalls of such
a container shall not contain remaining adhered or crusted material resulting from buildup
of successive layers of material or a mass of solidified material. A thin uniform layer or
dried material or powder is considered acceptable.
        All Labels must be in place (as when you received the container)

        Closures secure (all plugs, rings, valves in place and secure as when full)

Additional information: Container Acceptance Policy and IBC Acceptance Procedures at
www.myerscontainer.com.

Step 2 - Submit Material Safety Data Sheets for approval
This step is for New Emptiers or Existing Emptiers with new material types only. Attached
are MSDS’s for empty packaging’s that are being proposed for acceptance at Container
Management Services, LLC.

Once you have determined that you can meet the requirements above please Open, Save
and Complete (or Print and fill out manually) the Fax Cover / E-Mail Attachment page (link
below) and submit with the MSDS copy by Mail, Fax or Email.

             Drum Acceptance Fax _ Email Cover Sheet.doc
E-MAIL OR FAX TO:
Sean Reynolds



Fax 503.501.4929




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 2 – CMS, LLC ACCEPTANCE PROCEDURE AND POLICY


Step 3 - Provide Account Information, Obtain Pricing and Request a
Container Pick-Up (after Steps 1 & 2)
By Internet:        Empty Container Pick Up Request
By email:         orders@myerscontainer.com

By Fax:             503.501.4929
By Phone:           800.406.9377

Step 4 - Complete Empty Certification at time of collection

  Empty Container Receipt - Federal

  Empty Container Receipt - California Only




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 3 -- WASTE STREAMS AND DISPOSAL FACILITIES

                                                                                                     TSDF and
                                                                               Federal EPA            Profile
        Proper Shipping Name                    Common Name              CWC     Codes                Number

                                                       #121348
                                                                                                      st
      RQ Hazardous Waste Solids, N.O.S.              Paint Solids                                   21 Century EMI
       ( Lead,Chrome) 9, NA 3007 PG III              Paint Debris        352      D007 - D008           #121348
                                                                                                      Previously:
                                                                                                      Romic Env.
                                                                                                      New TSDF:
                                                                                                     Clean Harbors
  Hazardous Waste Solid, N.O.S. 9, NA3077 PG          #362102                                          San Jose
       III (Absorbent (clay), Paint Solids)          Solid Waste         352         D007               #362102
                                                                                                      Previously:
                                                                                                      Romic Env.
                                                       #362378                                        New TSDF:
                                                IBC Hard Flusher and                                 Clean Harbors
             Corrosive Liquids, N.O.S. 8,         9/11 Drum Flusher                                    San Jose
                UN 1760 PG II                     Sodium Hydroxide       121   D002 - D007 - D008       #362378


                                                      #DZ 1612                                          CWMI -
      RQ Hazardous Waste Solids, N.O.S.         Tank Sludge Resin and                                  Kettleman
       ( Lead, Chrome) 9, NA 3007 PG III                Debris           181      D007 - D008          # DZ 1612


                                                                                                    21st Century EMI
        Waste Paint Related Material, 3,               # 364939                                          Fernley
               UN1263, PG III                   Paint Related Material               D001               # 364939


                                                                                                    21st Century EMI
                                                      #312979                                            Fernley
      Non-RCRA Hazardous Waste Liquid             Cationic Polymer       343      Non-RCRA              # 312979
                                                                                                      Previously:
                                                                                                      Romic Env.
                                                                                                       New TSDF:
                                                                                                     Clean Harbors
  Non- RCRA Hazardous Waste Liquid (Water,             #361873                                          San Jose
                Polymers)                               Liquid           343      Non-RCRA              #361873


                                                                                                    21st Century EMI
                                                      #314160                                            Fernley
      Non- RCRA Hazardous Waste Liquid           Glue and Adhesive       281      Non-RCRA              # 314160
                                                                                                        Various:
                                                                                                         Asbury
                                                                                                       DeMenno
   Non-RCRA Hazardous Waste Liquid (Used               Various                                          Kerdoon
              Oil/Mixed Oil)                      Used Oil/Mixed Oil     221      Non-RCRA              # 362104



           Contents Under Analysis                   Description:               IF UNKNOWN - 10
        ___________________________                                            DAYS TO ANALYZE


 Excluded Recyclable Material Paint,3,UN1263,
                    PG II                           Bottom Paint         N/A     Not Applicable      Not Applicable

                                                       #121354
                                                Bag house Waste Shot                                Nevada Cement
          Non Hazardous Waste Solid                   blast/Iron                                    Fernley #121354

                                                                                                     PSC/ Idaho
                                                      #121352                                       Waste Systems
            Non Regulated Liquid                  IBC Rinse Sludge                                    #121352


                                                       #312578                                      21st Century EMI
         Non Hazardous Waste Liquid                   IBC Rinse                                     Fernley #312578


                                                      #366328                                         Romic Env.
      Non Hazardous Waste (Latex Solids)            Latex Solids                                     Tech. #366328
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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 4 -- IBC RECONDITIONING PROCESS


                                                                   Not Reconditionable


                                                                Clean at Shred                            Disposal -
       Receiving        Inspection              Classify
                                                                 Line Flusher
                                                                                     Shred and Grind
                                                                                                       Plastic Recycler



                                             Measure and
                                              Document
                                               Residue

                                                               Customer
                                                               Notification
                                               Returned
                                                Product
                                             Inventory and
                                              Classification


                                               IBC to
                                              Customer
                                              Inventory



                                                 Drain



                                         Valve Removal
                                         When Required



                                              First Wash
                                               2%NaOH
                                              Solution at
                                                 800psi


                                             First Rinse
                                             W arm W ater
                                                800 psi


                                           Final Rinse
                                          Fresh W ater
                                         2000psi Interior
                                           and Exterior



                                             Vacuum Dry


                                                                                  Bad Bottle
                                     Dirty
                                                               Install New
                                                Inspect        Valve When            Leak Proof Test   Final Assembly
                                                                 Required



                                                                                                       Warehouse and
                                                                                         Install New      Shipping
                                                                                            Valve




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 5 -- POLY DRUM RECONDITIONING PROCESS



                                                                         Not Reconditionable


                                                                      Clean at Shred                                 Disposal -
         Receiving         Inspection                   Classify                           Shred and Grind
                                                                       Line Flusher                               Plastic Recycler

                                      Good

                                                                                                                Customer
                                                       Inventory                                               Notification -
                                                                                                             Inventory Status




                                                     Interior First
                                                     Wash - Water



                     Caustic Wash -
                      if Necessary

                                                 Second Water
                                                 Wash - interior




                                                     Final Rinse -
                                                     Fresh Water




                                                        Steam



                                                     Vacuum Dry



                                                 Exterior Wash




                                                         Leak
                                                                      Leaks
                                                         Test


                                             Dirty



                                                                                                             Warehouse and
                                                        Inspect               Final Assembly
                                                                                                                Shipping




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 6 -- CORPORATE STRUCTURE

                               Container Management Services, LLC
                                   CORPORATE STRUCTURE


       New Container Operations                                Reconditioning Operations
         Myers Container, LLC                              Container Management Service, LLC




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Environmental Compliance and Facility Audit Information Packet
EXHIBIT 7 -- SITE HISTORY

                            Container Management Services, LLC
                        SITE HISTORY – 21301 Cloud Way / Hayward


                                             Vacant - 1952


                              Western Sky Manufacturing


                                               ChrisCraft
                                              Boat Building


                                    Mack Trucks
                             Manufacturing and Assembly


                                Western Drums, Inc./CMS
                                      1983 - 1996


                  Container Management Services, LLC
                  Joint Venture, IMACC & Western Drum
                           1996 - Oct. 10, 2007


                    Container Management Service, LLC
                          Oct. 11, 2007 - Present

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Environmental Compliance and Facility Audit Information Packet
                                       EXHIBIT 8 -- ORGANIZATION CHART


                               Container Management Services, LLC
                                     ORGANIZATION CHART




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