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AUGUST 2001 CUPA NEWS PAGE 2 ANNUAL TESTING: CUPA Q & A Underground Storage Tanks Q• I have used paint booth filters Every underground storage tank (UST) in San Joaquin County that I would like to put in the is required to have an annual monitoring certification. All pres- regular trash. Is that okay? surized piping systems must have a line leak detector test annu- ally (regardless of whether mechanical or electronic leak detec- A: It may be okay to dispose of your tors are installed). Most pressurized piping systems are re- used paint booth filters in the mu- quired to have a piping tightness test conducted by a licensed nicipal landfill. Prior to disposing of tester as well. Only systems which the Environmental Health paint booth filters in this manner, Division(EHD)has verified to be in compliance with the positive you must make sure that they are shutdown requirements of the California Code of Regulations not a hazardous waste. When dry (CCR), Section 2636(g), are exempt from the piping tightness paint booth filters are ready to be test. disposed of, many of the volatile or- Here are some tips for getting this testing done in an efficient ganic chemicals (VOCs) are gone, as manner which will help you to stay in compliance: is the flammability risk of the waste. • Choose a tester that is certified for the equipment you have in- However, filters can accumulate stalled. Effective January 1, 2002, only licensed contractors toxic metals or other components will be allowed to do monitoring certifications. These contrac- that will lead to classification as a tors must also be trained and recertified by the manufacturers hazardous waste. of the equipment which they work on. According to Title 22 of the Califor- ' Have the tester schedule the testing with the EHD. Effective nia Code of Regulations (CCR), Sec- January 1, 2000, all UST systems must be inspected annually. ® tion 66261.10, the generator of the It will save the owner/operator money if they have the inspector out at the same time as the tester. The best way to do this is to waste may use knowledge of their have the tester contact your CUPA inspector for scheduling. • waste to characterize it as hazard- Effective January 1, 2002, the owner or operator is required to ous, or may conduct laboratory test- notify the EHD 48 hours in advance of installing, repairing, re- ing as outlined in Chapter 11,Article placing,calibrating or certifying monitoring equipment. 3• • Pick a date for this testing when business is slower. Many of If a generator always uses the same the tests will require that the USTs be shut down for testing. types of paint in the same quantities, Make sure your testing company knows which days are prefer- an initial laboratory analysis should able. be sufficient. If there is a change in ' Verify that the testing company sends a report to the EHD the paint or the process, new testing within 30 days of any testing. A report must be sent even if an should be conducted. If many differ- inspector was onsite. Beginning on January 1, 2002, a stan- dardized reporting format will be required for all monitoring ent paints are used in different certifications. Testers are encouraged to begin using the stan- quantities, the generator should test dardized report now. the filters before each disposal. • It is a tank owner or operator's responsibility to make sure that Remember, if you choose to dispose this testing is done annually. It is not up to your inspector to of a waste as non-hazardous based remind you when you are due for testing, although many will. on "generator knowledge" or labora- If you miss your annual testing you are in violation of the law. tory analysis, and your wastestream If you aren't sure what testing you need, ask your CUPA in- later tests at hazardous waste levels, spector. you are in violation of the law and may be subject to enforcement ac- CUPA PHONE LIST tion. Letitia Briggs(468-3468)—East Stockton,Farmington,Linden Do you have a question you would like Dennis Catanyag(468-3459)-Tracy answered in CUPA Q&A? Michelle Sterni-Le(468-9847)—Lodi,Lockeford,Northeast Stockton ; Write to CUPA NEWS, Attention Alison Alison Youngblood(468-9848)—Manteca,Lathrop,Ripon,Escalon Youngblood: Kasey Foley,Lead Senior(468-3451) MAIL: 304 E. Weber Ave., Third Floor, Doug Wilson,Supervisor(468-3446) Stockton,CA 95202 : CUPA Information(468-3427) FAX:209-468-3433 San Joaquin County Office of Emergency Services (468-3969) - EMAIL:ayoungblood@phs.hs.co.san-joaquin.ca.us Hazardous Materials • ....... .. . ... .... .. ... . .. .. . . ... .... .. ...... ........ ...