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SUMIDEN WIRE PRODUCTS CORPORATION WKA No. 2714.01 August 18, 1994 Page 6 I Based on the above two statements, it can be concluded that secondary containment for the emergency evacuation sump is not required. CONCLUSIONS Based on review of Title 23, Division 3, Chapter 16, Section 2621 and subsequent conversations with the State Water Resources Control Board, it has been concluded that the underground sulfuric acid rinse water sump is exempt from the definition of "underground storage tank", and is therefore exempt from secondary containment requirements with respect to underground storage tanks under Chapter 6.7, section 25292 of the Health and Safety Code. Based on review of the Uniform Fire Code, Division III, Section 80.301 and subsequent conversations with the City of Stockton Fire Department, it has been concluded that the bulk sulfuric acid, bulk caustic soda, sulfuric acid bath, hot and cold rinse water baths, and borax above ground storage tanks comply with secondary containment requirements. The emergency evacuation sump serving as secondary containment is capable of handling the capacity of the largest aboveground storage tank plus 10 % of the capacities of the other aboveground storage tanks. Based on review of Title 22, Chapter 14, Article 10, Section 66264.190, and subsequent conversations with the California Department of Toxic Substance Control, secondary containment of the emergency evacuation sump is not required. Additionally, under Title 23, Division 3, Chapter 16, an emergency containment tank, or sump, pit, or lagoon, is exempt from the term "underground storage tank", and is therefore exempt from secondary containment requirements under Chapter 6.7, Section 25292 of the Health and Safety Code. LIMITATIONS The statements and conclusions in this report are based upon the scope of work described above and on observations made on our site reconnaissances of May 19, 1994 and July 12, 1994. No WALLACE•KUMI