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AUG-14-99 09 :02 AM John M Cruikshank 310 329+4143 P. 02 <br /> 2 John M. Cruikshank Consultand <br /> 76921 S. Weomn Awe,Suite 301 <br /> Car@ea, CA 90247 <br /> Phone: 310.329.4144 Fax: 310.329.4143 john_crulkshonk@msn.com wivw,jmc-2.com <br /> August 13, 1999 <br /> Mr. Louis Bailey <br /> Environmental Health & Safety Manager <br /> Onyx Industrial Services,Inc. <br /> 12501:- 23'a Street <br /> Signal Hill,CA 90806 <br /> SUBJECT: CERTIFICATION OF SECONDARY CONTAINMENT SYSTEM FOR <br /> TRANSPORTABLE TREATMENT UNITS <br /> Mr. Bailey_ <br /> I have reviewed the information you provided on your proposed secondary containment systems for your <br /> Transportable Treatment Units and find they meet the requirements set firth in the California Code of <br /> Regulations (CCR) Title 22 Section 66264.175 Containment. <br /> BACKGROUND <br /> Onyx Industrial Services, Inc. (OiS) utilizes a Transportable Treatment Unit(TTU)to treat Stretford <br /> solutions from refinery activities. These solutions are considered a hazardous waste. The TTU facilities <br /> must therefore comply with tite regulations set forth in CCR Title 22('Hazardous Waste). <br /> Section 66264.175 of CCR Title 22(Containment) requires the secondary containment system to be <br /> reviewed against the requircmnnts of Section 66264.175 by an independent.,qualified professional <br /> engineer, registered in California. OIS provided me with the information on which this review is based. <br /> FACILITIES AND OPERATION <br /> The OIS TTU consists of up to five portable polypropylene containers each with a capacity of up to <br /> 15,750 gallons,and a non-liquid containing Filter 1'ress Trailer. Within each container, accumulated <br /> liquid from industrial cleaning activities is neutralized through the addition of acid and/or caustic. When <br /> neutralization is complete, the treated liquid is disposed. These activities can take place at any site where <br /> OIS performs these services. Note that the container, neutralization activities, and product disposal are <br /> covered under different sections of Title 22 and are not included in this review. <br /> Secondary containment for the container is an erected, on-site 23,875-gallon berm system that consists of <br /> a 40' x 60' pad surrounded by a 16"high sidewall all lined with an acid and corrosive resistant <br /> polyethylene"tarp"material secured by nails to the top of sidewalls. The Containment system is erected <br /> and inspected prior to placing the TTU within the berm area. <br /> According to OIS,the container and the secondary containment system are placed and erected from <br /> qualified suppliers, For this review, OIS provided information about the size and number of tanks only. <br /> This certification is contingent upon the containment system meeting the design parameters as reviewed. <br /> It is the sole responsibility of OIS to verify that the design parameters are consistent. <br /> ' 7 <br />