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0 0 Page 1 of 2 <br />Garrett Backus [EHI <br />From: Garrett Backus [EH] <br />Sent: Thursday, September 18, 2008 2:25 PM <br />To: 'Eric Schmitz' <br />Subject: RE: PE Certification for Tanks <br />Attachments: SQG and HW tank assessments.pdf <br />Eric„ <br />See the attached PDF file for a short explaination of SQGs and HW tank assessments. <br />Garrett Backus, REHS <br />San Joaquin County Environmental Health Department <br />600 E. Main Street <br />Stockton, CA 95202 <br />telephone: (209) 468-2986 <br />fax: (209) 468-3433 <br />email: gbackus@sjcehd.com <br />From: Eric Schmitz [mailto:eric@kpaonline.com] <br />Sent: Monday, September 15, 2008 12:57 FM <br />To: Garrett Backus [EH] <br />Cc: Sharon Karagozlu; Rob Singh; ronaguiar@stocktonnissan.com <br />Subject: PE Certification for Tanks <br />Garrett, <br />Thank you for taking my call today concerning Stockton Nissan's tanks and their possible <br />classification as containers. I understand your stance that these large storage vessels <br />with attached piping should not be considered containers. Ron Aguiar, (service <br />manager), is moving forward with getting quotes to have a PE certify his tanks in <br />compliance with your notice. <br />In regards to the general application of Title 22 §66265,192 1 am concerned that it may <br />apply to more of KPA's clients and that these clients are unaware of the issue. I <br />understand that your guidance states that this regulation only applies to facilities that <br />generate more than 1000 kg's f month of hazardous waste including used oil. Can you <br />please direct me to the section of Title 22 that exempts generators of less than <br />1000kglmonth and requires generators of more than 1000kg/month of used oil to comply <br />with Article 10 of Chapter 15? Once I am confident in the applicability of this section of <br />the regulations I will draft a letter to all of our 800 clients throughout the state with a <br />recommended course of action. <br />Thanks in advance for your assistance, <br />Eric Schmitz <br />Vice President <br />KPA <br />9/2212008 <br />