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Becky Sundilson <br /> From: Jeff Bennett <br /> Sent: Friday, April 05, 2019 8:49 AM <br /> To: Becky Sundilson <br /> Subject: FW: Hazardous Waste Tank Question <br /> Jeffrey D. Bennett <br /> Principal Hydrogeologist <br /> CA PG 6027, CA CHG 400,AZ RG 34764, NV CEM 1784 <br /> Earth Con Consultants CA, Inc. <br /> 1500 South Sunkist Street,Suite D <br /> Anaheim, CA 92806 <br /> Office: (714)500-5454 <br /> Mobile:(714)743-0482 <br /> FAX. (714)960-2462 <br /> Statement of Confidentiality.This email and any attachments transmitted with it are confidential and intended solely for the use of the individual <br /> or entity to which they are addressed. The information contained in this email is highly confidential and may be subject to legally enforceable <br /> privileges. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient,you are hereby notified that <br /> any disclosure, reliance, copying, distribution, dissemination or use of any of the information contained in or attached to this transmission is <br /> STRICTLY PROHIBITED. If you have received this communication in error,please notify Earth Consulting Group, Inc.immediately by replying <br /> to this email.Please delete all copies of this message and any attachments immediately. <br /> From: Lawler, Samantha@DTSC<Samantha.Lawler@dtsc.ca.gov> <br /> Sent: Friday, March 01, 2019 2:21 PM <br /> To:Jeff Bennett<jbennett@earthcon.com> <br /> Subject: RE: Hazardous Waste Tank Question <br /> Good afternoon Jeff, <br /> I have been reaching out to several units within DTSC trying to find a resolution to your clients tank <br /> assessment issue. This week, one of my colleagues brought up the California Aboveground Petroleum Storage <br /> Act (APSA). <br /> https://Ieginfo.legislature.ca.gov/faces/codes displayText.xhtml?lawCode=HSC&division=20.&title=&part=&c <br /> hapter=6.67.&article I have been reading through trying to determine if your client is regulated under this act. <br /> If so, I have not yet found any pressure testing requirements. This Act is Implemented and enforced by the <br /> CUPA's, not DTSC. On page 11 of the attached FAQ sheet it covers who is subject to the requirements of ASPA. <br /> Since the tank is only 385g, the second scenario does not apply, but I do not have enough information on the <br /> facility to know if the first applies or not (Are they subject to oil pollution prevention regulations specified in <br /> Part 112 (commencing with Section 112.1) of Subchapter D of Chapter I of Title 40?). <br /> In your email, you stated that the CUPA was basing their requirements on 22CCR §66265.192(k)(10). This <br /> regulation pertains to new above ground storage tanks, not existing. You stated that "The facility does not have <br /> record of the age of the tank'; so apparently the CUPA has determined that the tank construction commenced after July <br /> 14, 1986 if it is holding RCRA HW or after July 1, 1991 if it is holding non-RCRA HW.As such, new tanks have to have <br /> more rigorous tank integrity testing, so you may want to have the age of it assessed again if it is an older tank. <br /> I <br />