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Item # 501 —CCR 66265.192(a) Failed to comply with hazardous waste tank system ass.Es I Fm C F.IN <br /> requirements. <br /> FEB 16 2016 <br /> December 2015 Response ENVIRONMENTAL. <br /> HEALTH RF:p4PTMc"'T <br /> Tank 420 is presently used to store oily water for no more than 90 days. Historically the water from the <br /> Tank has been transported on a uniform hazardous waste manifest and recycled at Demenno Kerdoon in <br /> Southern California (TSDF). <br /> Based on recent discussions with DTSC, Tesoro is evaluating whether this material should be managed as <br /> oil-bearing material in accordance with HSC 25144. To the extent Tesoro determines that the material <br /> should not be managed as oil-bearing material, Tesoro will obtain a written assessment reviewed and <br /> certified by an independent, qualified California professional engineer, attesting that the Tank 420 system <br /> has sufficient structural integrity, is acceptable for the transfer/storage of hazardous waste, and that the <br /> Tank and containment system are suitably designed. <br /> Tesoro disputes the classification of this violation as Class I. If this is a violation, Tesoro maintains that this is <br /> a minor violation as defined by HSC 25404. <br /> January 2016 Supplemental Response <br /> Tesoro has determined that the Tank 420 material should be managed as oil-bearing material in accordance <br /> with HSC 25144. Tesoro disputes that this is a violation. Because the Tank 420 material is not a hazardous <br /> waste, no hazardous waste tank assessment was needed. <br /> 3 <br />