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I hope that you had a nice weekend. I just wanted to follow up with you and let you know that I received your email and I am still trying to track down the appropriate person who can make this determination for you. Hopefully we will be able to assist you soon. Thank you e5amantha La faker Environmental Scientist/Regulatory Assistance Officer Industry Assistance,Training, and Outreach Unit Hazardous Waste Management Program Phone: (916)324-0092 California Department of To)dc Substances Control DTSC Regulatory Assistance Officers provide informal guidance only about management of hazardous waste for the convenience of the public. Such oral or electronic mail advice is not binding upon DTSC,nor does it have the force of law. If you would like a formal opinion on a matter by DTSC,please contact the responsible program office directly. You should also refer to the statutes and regulations,DTSC Policies and Procedures,and other formal documents. If you would like to provide us feedback please do so at: https://caIepa.ca.gov/wp-content/uploads/sites/62/2016/10/Customer-CustForm.pdf From:Jeff Bennett<jbennett@earthcon.com> Sent:Thursday,January 31, 2019 4:14 PM To: Lawler, Samantha@DTSC<Samantha.Lawler@dtsc.ca.gov> Subject: Hazardous Waste Tank Question Hi Samantha, Thanks for your call back on 1/30/19. As discussed on the phone, we have a client that has an above-ground 385-gallon secondarily contained poly tank for the storage of used oil (cut sheet attached). The local CUPA requested records documenting that the tank had been tested for tightness prior to being placed in use in accordance with 22CCR §66265.192(k)(10). The facility does not have records indicating that the tank was tested prior to being put into service. The facility contacted a local tank testing firm to get a current integrity test and was told that, because of the tank configuration, a vacuum test could not be performed (apparently there is not a way to provide an adequate seal on the 16-inch manway cover). The recommendation was to fill the tank and check it for leaks, which is essentially what the facility does on a regular basis. Customers place used oil into the tank and facility personnel periodically inspect the exterior and annular space for evidence of leakage. The facility also does not have a record of the age of the tank; however,visual inspection of the tank did not reveal any crazing or degradation of the materials of construction and it appears to be in good condition. The tank is on a concrete slab inside the fenced perimeter of the facility. While the periodic inspections would seem to provide equivalent confirmation of tank integrity,the CUPA is requesting evidence of tank testing to approve use of this tank unless DTSC can provide further guidance. At this point the options for storage of this material include developing a way to authorize use of the existing tank with ongoing inspections or replacing the tank with drums or other equivalent storage containers. Based on our conversation,you were not aware of any DTSC policy memos or guidance documents that address this. We would appreciate DTSC's opinion on this matter to assist with determining a method to store this material in a compliant manner. Thanks, 5