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Page 2 <br /> The material thickness entry on Table 4 will be modified on future documents to indicate <br /> that the field verification of the wall thickness was completed using a tape measure. <br /> Comment 3: The assessment did not address inspection for the presence of weld breaks, <br /> punctures, scrapes of protective coatings, cracks, corrosion, and other structural damage or <br /> inadequate construction or installation. [22 CCR 66265.192(b)] <br /> Response: The text of 22 CCR 66265.192(b) states (emphasis added): <br /> (b) The owner or operator of a new tank system shall ensure that proper handling <br /> procedures are adhered to in order to prevent damage to the system during <br /> installation. Prior to covering, enclosing, or placing a new tank system or component in <br /> use, an independent, qualified installation inspector or an independent, qualified, <br /> professional engineer, registered in California, either of whom is trained and experienced <br /> in the proper installation of tank systems, shall inspect the system or component for the <br /> presence of any of the following items: , .� <br /> r D(1) weld breaks; <br /> (2)punctures; �7 <br /> DEC 0 02016 <br /> (3) scrapes of protective coatings; <br /> (4) cracks; ENVIRONMENTAL HEALTH <br /> (5) corrosion; D`pARTMENT <br /> (6) other structural damage or inadequate construction or installation. All discrepancies <br /> shall be remedied before the tank system is covered, enclosed, or placed in use. <br /> These stipulations are specific to potential damage that could occur during installation, <br /> which that must be verified prior to putting the tank system into use. The tank system <br /> was already in use at the time of our inspection; therefore, EarthCon could not complete <br /> a pre-use inspection. EarthCon did; however, evaluate each tank and found them to be <br /> in satisfactory condition, with no evidence of leakage. The tanks are molded crosslinked <br /> polyethylene so there are no welds or protective coatings and they are not susceptible to <br /> corrosion. Any punctures or structural damage sustained during their installation would <br /> be evidenced by leakage. No cracks were observed. In addition, the daily inspections <br /> conducted by facility staff will identify future leakage and such leakage will be captured <br /> by the secondary containment structures. <br /> Comment 4: The assessment did not discuss tank tightness testing or include passing results. <br /> [22 CCR 66265.192(d) & (k)(10)] <br /> Response: The texts of 22 CCR 66265.192(d) & (k)(10)state (emphasis added): <br /> (d) All new tanks and ancillary equipment shall be tested for tightness prior to being <br /> covered, enclosed or placed in use. If a tank system is found not to be tight, all repairs <br /> necessary to remedy the leak(s) in the system shall be performed prior to the tank <br /> system being covered, enclosed, or placed in use. <br /> "I EarthCon Consuants CA, <br /> EAkTHCON' 1914 West OrangewoodAvelnc P:714-500-5400 <br /> Suhe 102 F:714-960-2462 <br /> Enwonmerxe!G, s Orange,CA 92868 www.eartheon.eom <br /> ausrxess sownonsd <br />