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PFCEIVE-n California Environmental Protection Agency DEC 0 5 2016 Department of Toxic Substances Control Facility: California Tank Lines Inc. Inspection Date: September 29, 2016 VII. Violations ENVIRONMENTAL HEALTH DEPARTMENT SECTION I: NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION (Violations not considered Minor Violations) You must correct the following violation(s) within the specified time frame for each violation listed below: Violation #1 On or about September 29, 2016, Cal Tank Lines violated California Code of Regulations section 66265.196 (c) in that it did not clean spill/release in the secondary containment of the pH neutralization treatment system, which is utilized to treat corrosive hazardous waste from the facility's wash rack operations. In particular, DTC observed a spill of liquid on the floor of the secondary containment in close proximity to the pH neutralization tanks. DTSC tested the liquid with pH paper that indicated the pH range to be approximately pH 13, which is a corrosive waste. Corrective action: Cal Tank Lines must immediately clean releases found in the secondary containment and log the spills including cleanup activities in the daily tank inspection logs. In addition Cal Tank Lines must make a determination if the spills are hazardous waste using generator's knowledge or with an analytical method, i.e. test the waste. Thereafter, Cal Tank Lines must properly manage and dispose of the any hazardous in accordance with Hazardous Waste Control Laws. Within 15 days of receipt of this SOV, Cal Tank Lines must submit detail plans to DTSC that describes the corrective action(s) taken or planned, including but not limited to training facility personnel, to (1) cleanup spills in a timely and safe manner, (2) how to conduct inspections, (3) how to complete the log including the findings of any spill events and (4) any additional steps necessary in order to prevent the reoccurrence of this violation in the future. Response from Cal Tank Lines: In the letter dated October 31, Cal Tank Line described that "The event that created the pH13 was my operator filling the Sodium Hydroxide tank and I believe that we probably had a drip from the hose. After filing the tank, he would have washed down the containment to our treatment tanks. However, I had the operations halted for your walk around inspection. Following your inspection, all containments were washed down and the water was pumped to our treatment system." In addition, on November 11, 2016, DTSC received the corrective action documents, via email, which described Cal tank Lines washed down the secondary containment and the wastewater was pumped to its wastewater treatment system. Also in a separate email, Mr. Bishop informed DTSC that Cal Tank Line had hired an Environmental consultant who will help with the training and writing a report for DTSC that lists each violation and Cal Tank Lines' response to them. 29