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The following is an itemized list of our response to the hazardous waste violations for the Louise <br /> Avenue Water Treatment Facility: <br /> Violation#101 Managed a hazardous waste without an identification number. <br /> The City has an identification number, which is inactive. The City has submitted an application to <br /> reactivate identification#CAL000379085, which is attached. <br /> Violation#105 Failed to determine if a waste is a hazardous waste or retain waste analysis on site for <br /> 3 years. <br /> On May 25, 2016, a waste analysis was performed by BSK Laboratories for both the filter cake and the <br /> liquid from the filter press (filtrate); see attached analysis. The analysis is now kept on site inside the <br /> operations building. <br /> The summary of violation indicated the liquid from filter press was discharging into the storm drain. <br /> This is incorrect and the liquid, which is water is actually being discharged into the sanitary sewer drain. <br /> All barrels on the property,whether cut in half or not had been properly rinsed and cleaned after all <br /> hazardous material was used. The City had kept the barrels on site until they could be properly dispose, <br /> or used as garbage and recycling cans. When the barrels are rinsed they are triple rinsed with water and <br /> the water used to triple rinse the barrels is captured and emptied into the spray rig, which is used to <br /> spray pesticide. The half-cut barrels that had a liquid in them was rain water caused by recent rain <br /> events. These half-cut barrels had previously been rinsed and cleaned prior to rain water accumulating <br /> in them. After the inspection and concern from EHD the City retrieved all barrels, emptied all rain into <br /> the sanitary sewer from the barrels, and took them to San Joaquin County for recycling; see attached <br /> receipt and recycling program information. <br /> The ferric chloride tank which stores ferric chloride for the removal of arsenic from the water supply had <br /> leaked into the secondary containment area and also sprayed ferric chloride onto the rocks surrounding <br /> the containment. The leak was caused by a break in the chemical feed line. Ferric Chloride caused <br /> excessive staining to the rocks and the rocks remain in place. The ferric chloride, which leaked into the <br /> secondary containment was cleaned up by spraying down with water and using the vactor to pick up the <br /> water and ferric chloride. The vactor emptied the ferric/water into the 20-yard sludge storage <br /> container. The vactor was rinsed and scrapped with water to clean, and the water was dumped into the <br /> 20-yard storage container. The City also moved the rocks that had been sprayed with ferric chloride, <br /> and removed any soil containing ferric chloride with a shovel and placed in the bucket of a tractor. The <br /> bucket of the tractor emptied the waste into the 20-yard storage bin. The rocks were put back in place, <br /> but still show the staining of ferric chloride. See attached photo of ferric chloride tank area. <br /> Violation#106 Failed to prepare and implement a contingency plan. <br /> The City has completed and implemented a contingency plan, and a copy is attached. <br /> Violation#107 Contingency plan is incomplete. <br /> The City has completed and implemented a new contingency plan, and a copy is attached. <br />