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Page 2 7. Address the SJCEHD recommendation for the professional engineer (P.E.) to sign the DTSC required certification statement. Responses to items 1 through 6 above have been incorporated into the Revised Report attached to this transmittal. Specific sections where each response item has been incorporated are indicated above. In response to item 6, EarthCon reached out to the DTSC, on behalf of Pick-n-Pull, regarding requirements for tank testing through a series of phone calls and emails from January through March 2019. From the correspondence, DTSC clarified that tanks are required to have integrity or leak testing and that Title 22 California Code of Regulations (CCR) § 66265 provides a number of ways in which that can be accomplished, including internal inspections. In addition, the DTSC referenced 22 CCR § 66265, which states that any system integrity or leak test requirements must be in compliance with local requirements. The DTSC therefore recommended contacting the CUPA (SJCEHD) to discuss options for demonstrating tank integrity. However, since this question was brought up by the CUPA (SJCEHD) a clear determination for the type of testing needed to satisfy the requirement was not made. Because there continues to be no clear determination, EarthCon recommends that the Customer Drop Off tank be visually inspected for signs of potential tank integrity failure concerns. As was discussed with SJCEHD, pressurized integrity testing cannot be properly performed for this type of tank. This was determined by a tank testing engineering firm, Afforda-Test, and confirmed by the tank manufacturer Chem-Tainer. EarthCon also recommends that the customer oil drop-off tank continue to be inspected daily for leaks and/or damage by site personnel going forward to ensure continued proper function. In response to item #7, EarthCon researched certification requirements as referenced by the DTSC in CCRs. The following conclusions were determined: In reference to who is to sign the certification statement, as discussed with SJCEHD, the specific part of the hazardous waste tank regulation states: • 66265.192 (g) The owner or operator shall obtain and keep on file at the facility written statements by those persons required to certify the design of the tank system and supervise the installation of the tank system in accordance with the requirements of subsections (b) through (f) of this section to attest that the tank system was properly designed and installed and that repairs, pursuant to subsection (b) and (d) of this section were performed. These written statements shall also include the certification statement as required in section 66270.11(d) of this division. This written statement is from the persons required to certify the design of the tank system and it shall also include the certification statement as required in from 66270.11(d). The signatures described in 66270.11(d) are made by someone associated with the facility, as follows: § 66270.11. Signatories to Permit Applications and Reports. (a) Applications. All permit applications shall be signed as follows, emphasis added: WEAkTHCON6 1500 South Sunkist StreetA,Inc. P:714-500-5400 Suite D EffwwrmaWafChadenges Anaheim,CA 92806 www.earthcon.com BUSINESS SOLUTIONS s