Laserfiche WebLink
11 <br />1 INTRODUCTION <br />The Certified Unified Program Agency (CUPA) for the Forward Landfill with regard to the <br />Aboveground Petroleum Storage Act (APSA) program is the San Joaquin County, Department of <br />Environmental Health (County Inspector). In June 2010, the County Inspector stated that the <br />Forward Landfill lacked a tank assessment for its 250 gallon used oil storage tank and requested a <br />written tank assessment to be performed in accordance with 22 CCR 4 66265.191 and submitted by <br />July 7, 2010. The tank assessment must be reviewed and certified by an independent, qualified <br />professional engineer registered in California. <br />In accordance with the CAL-CUPA Forum Guidance Document (Requirements for Hazardous <br />Waste Tank Systems, October28, 2005), the 250 gallon used oil tank at the Forward Landfill is <br />considered an existing tank since it was in use prior to July 1, 1991. Existing tanks that have proper <br />secondary containment and leak detection per 22 CCR 4 66265.193 are not required to have a tank <br />assessment. The used oil tank has satisfactory secondary containment and leak detection and, <br />therefore, should not be subject to the 22CCR 1 66265.191 requirements. <br />In addition, the used oil should qualify for a recycling exclusion from being managed as a hazardous <br />waste in accordance with California Health and Safety Code Sections 25250.1(b)(1)(A), <br />25250. 1 (a)(3)(B), 25250.4, 25143.2(b), 25143.2(e)(7)(A) and 25143.9. The used oil from the tank is <br />sent to a certified recycling facility. Because of the recycling exclusion for used oil, the used oil <br />does not need to be managed as a hazardous waste and the tank should not be subject to the tank <br />assessment requirements in 22 CCR 4 66265.191. However, to comply with the County Inspector's <br />request, this report provides a written tank assessment and certification for the 250 gallon used oil <br />tank at the Forward Landfill. <br />1 The guidance document was sent, by letter, from Kim F. Wilhelm, Chief, Statewide Compliance Division, <br />Department of Toxic Substance Control, to Michael Dorsey, Chief, San Diego County, Department of <br />Environmental Health, Hazardous Materials Division <br />9 0 <br />