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RE.E ICED California Environmental Protection Agency Department of Toxic Substances Control Facility: California Tank Lines Inc. DEC U 2016 Inspection Date: September 29, 2016 `I R�NMENTAL HEALTH Safety training was provided or [I�rterl.y_basfs%EWployees. DTSC staffs reviewed the sign -in sheets, and certificates and observed that Mike Ellis, the primary emergency coordinator did not receive annual training, which is a violation of California Code of Regulation (CCR) section 66265.16, and is described as Violation #9 in section VII. (The compliance document from Cal Tank lines sent via email to DTSC on October 31, 2016, described "training is done by NES". However, on November 15, 2016, Cal Tank Lines submitted the updated Contingency and Emergency Plan at which Mr. Ellis name was removed from primary Emergency Coordinator. The Plan was modified to list Mr. Bishop as the Primary Emergency Coordinator, and Nathan Marleu as the Secondary. When DTSC staff checked the California Environmental Registration System, the Plan was submitted on November 2, 2016, and approved by CUPA on November 7, 2016.) List of approved products for tanker washout The list contains brand names of the allowed products, and chemicals, fertilizers, and miscellaneous products that may be washed out and then discharged to the POTW. DTSC staff observed hydrofluosilicic acid is one of approved chemical and requested the Safety Data Sheet (SDS) for review. The SDS indicated that the chemical exhibits two hazardous waste characteristics; being corrosive and toxic. At the time of inspection, the facility had conditional authorization for an elemental neutralization unit, but did not have Permit by Rule (PBR) authorization, which is required for waste streams with multiple waste characteristics. According to CCR Title 22 section 66260.10, an elementary neutralization unit is defined as a device which is used for neutralizing wastes that are hazardous only because they exhibit the corrosivity, and do not contain more than 10 percent acid or base concentration by weight. This definition also indicates treating wastewater containing acid higher than 10% is a violation. Treating hydrofluosilicic acid is a violation of California Health and Safety Code Sections 25201 and 25200.3 in that the facility conducted unauthorized treatment of a waste stream that has multiple characteristics. (Violation #2, in the section VII of this Report). Cal Tank Lines submitted PBR application to San Juaquin County CUPA on October 31, 2016, which was approved on November 7, 2016. Phase I Environmental Assessment Cal Tank Lines did not conduct the environmental assessment procedures required by California Health and Safety Code Section 25200.3 (c) (3) for the facility to verify if there is contamination resulting from the release of hazardous waste or constituents from a hazardous waste management unit at the generator's facility, regardless of the time at which the waste was released. This violation is cited as Violation #3 in the section VII of this Report. On November 9, 2016, Cal tank Lines submitted Tiered Permitting Phase I Environmental Assessment document to DTSC via email, which described Cal Tank Lines needs no further investigation to determine, existence, nature and existence of contamination at the facility. The Environmental Assessment checklist was certified by the professional engineer. 111