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California Environmental Protection Agency <br />Facility: California Tank Lines Inc. <br />Safety Data Sheets If SDSs) <br />The following three SDSs were reviewed <br />➢ Hydro Flurosillicic Acid (HAS) <br />➢ BlackCat 236 <br />➢ Nitric Acid <br />Tank Assessment Documents <br />Department of Toxic Substances Control <br />Inspection Date: September 29, 2016 <br />DEC 0 5 2016 <br />ENVIRONMENTAL HEALTH <br />DEPARTMENT <br />During the inspection the following hazardous tank systems were observed: (1) wash rack <br />wastewater treatment system (2) used oil skimmer tank system, and (3) a used oil tank <br />maintenance shop. According to Mr. Bishop, the cone-shaped tank in the wastewater <br />treatment system tank and used oil storage tank in maintenance shop were recently installed. <br />Mr. Bishop informed DTSC staff that two tanks in wash rack wastewater treatment system were <br />taken out of service and a new cone tank installed several months ago. California Code of <br />Regulations Title 22, Section 66260.10 defines a new tank as a tank constructed after July 14, <br />1986. Because the tanks were installed recently, i.e. after 1986, the facility's tank system is <br />classified as a new tank system. California Code of Regulation T 22, 66265.192(a) states, in part, <br />that "Owner or operators of a new tank system shall ensure that the foundation, structural <br />support, seams, connections, and pressure controls ... are adequately designed..." The owner or <br />operator "shall obtain a written assessment reviewed and certified by an independent, <br />qualified, professional engineer, registered in California." <br />When asked to supply a valid tank assessment for the hazardous waste tank systems including <br />the treatment tank units, the only available tank assessment document Cal Tank Lines had was <br />for 3,000 gal caustic tank. Therefore, at the time of the inspection Cal Tank Lines could not <br />make available for inspection the following tanks and related ancillary components: <br />➢ Cone-shaped tank in the wastewater treatment area, which was recently installed <br />➢ Oil skimmer tank in wash rack <br />➢ Used oil tank in the lube shop recently installed <br />➢ Used oil tank in wash rack by the oil skimmer <br />➢ The pH neutralization tanks known as Tank Nos. 1, 2 and 3 in wastewater treatment <br />system <br />Therefore, Cal Tank Lines violated California Code of Regulations T 22, 66265.192(a) on or <br />about September 29, 2016 in that Cal Tank Lines failed to demonstrate that it had obtain a valid <br />tank assessment performed by a professional engineer for the hazardous waste tank systems <br />since assuming operations of the facility. Failure to perform a written, certified tank <br />assessment was noted in the Summary of Observation/Concerns that was left with Cal Tank <br />Lines at the end of the inspection, and as violation #6 in section VII of this report. <br />After the inspection, Mr. Bishop wrote a letter to DTSC on October 31, 2016, and informed <br />DTSC staff that "Tank assessments had been completed on all the tanks except the cone bottom <br />