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Ga rret, <br />I believe we will get a letter for the sumps; however, we are still working on the Environ penetrations. I have attached a <br />statement from Cory and it seems we could use a P.E. for non -integral secondary containment parts (which would include <br />penetrations). <br />Jesse Diaz <br />West Coast Environmental Manager <br />Love's Travel Stops & Country Stores, Inc. <br />Cell: (405) 687-1060 <br />E -fax: (405) 254-3473 <br />Jesse.Diaz@loves.com <br />www.loves.com <br />Jesse <br />R E �,,, �;- E �vi, L . <br />APR 2 6 2016 <br />HEAUP <br />I thought I would clarify and summarized the point of our conversation this morning. As mentioned earlier, California <br />underground storage (UST) owners/operators are subject to federal UST requirements as well as State requirements. The <br />attachment is a notice we sent out about ethanol compatibility but the concepts and requirements should still apply the same <br />for biodiesel. <br />Below are California state requirements. <br />All (UST) systems are required to be compatible with the substance stored.(Health and Safety Code, sections 25291, 25290.1, <br />25290.2. ) <br />All primary containment including any integral secondary containment system shall be approved by an independent testing <br />organization in accordance with industry codes, voluntary consensus standards, or engineering standards, effective as follows. <br />Tanks of all USTs installed on or after July 1, 1991, piping on all USTs installed on or after July 1, 1992, and all other components <br />on all USTs installed on or after January 1, 1995 are required to obtain an approved by an independent testing organization in <br />accordance with industry codes, voluntary consensus standards, or engineering standards. (California Code of Regulations, <br />section 2631(b).) Testing and approvals of USTs has not kept up with the introduction of and desire to use alternative fuels, such <br />as biodiesel, in California. Underwriters Laboratory (UL) approvals such as a UL1316 listing/approval satisfies the independent <br />testing organization approval requirement; however, a UL 1316 listing/approval does not guarantee that the tank is compatible <br />with biodiesel. The State Water Resources Control Board (State Water Board) adopted regulation providing an option for <br />compliance with existing independent testing and approval and compatibility requirements so that UST owners and operators <br />can store any substance in USTs in a manner that does not create any significant risk of adverse impacts to water. When a UST <br />owner/operator intends to store a substance that is not included in the independent testing organization approval or listing of a <br />component on their UST system, such as biodiesel and a UL listing, the owner/operator must submit to the Certified Unified <br />Program Agency (CUPA) an affirmative statement of compatibility from the manufacturer of that component for the specific <br />substance being stored, including blend ratio. At a minimum the statement of compatibility should include the manufacturer(s) <br />name, specific model or part number, containment type, current independent testing organization standard/approval, dates of <br />manufacture, size, and the specific substance and blend that is compatible. This ability to use an affirmative statement of <br />compatibility from the manufacturer in conjunction with the independent testing organization approval to satisfy the <br />