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RECEIVED BY SJCEHD (EF) ON 1/29/2020 <br /> 1 <br /> Sent via Email to EFlorido@sjgov.org <br /> January 29, 2020 Reference No. 11189093-2019.5 <br /> Ms. Elianna Florido <br /> Registered Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton, California 95205 <br /> Dear Ms Florido: <br /> Re: Owen-Brockway Glass Containers, Inc. —Tracy <br /> Engineering Assessment and Certification of Integrity of Plant#22 Used Oil Tank System <br /> 1. Introduction <br /> As a supporting document to the Used Oil Tanks for the Forming Buildings System Integrity Report, dated <br /> August 16, 2018, this letter report addresses that report's lacking documentation and certification listed in <br /> the RCRA Large Quantity Hazardous Waste Generator Inspection Report by the San Joaquin County <br /> Environmental Health Department(SJCEHD), dated June 05, 2019 and amended June 21, 2019 and <br /> further clarified in an email from SJCEHD, dated July 23, 2019 (Attachments 1 and 2). <br /> 1.1 Background <br /> Per California Code of Regulations (CCR) 66265.192, tank systems used for the transfer, storage or <br /> treatment of hazardous waste at facilities that qualify as Resource Conservation and Recovery Act <br /> (RCRA) and non-RCRA Large Quantity Generators and operated under a tiered permit shall obtain a <br /> written assessment reviewed and certified by an independent, qualified, professional engineer, registered <br /> in California. <br /> The hazardous waste tank system containing two 1,000-gallon, double-walled, steel used oil tanks <br /> (referred to herein as Tanks C and D, as identified in the Owens-Brockway Glass Container Inc. Plant#22 <br /> Spill Prevention, Control, and Countermeasure Plan, dated July 18, 2019, but also known as Tanks A-B <br /> and C), which are shown on Attachment 3, were assessed in the Used Oil Tanks for the Forming <br /> Buildings System Integrity Report(System Integrity Report), prepared by HMT Inspection. However, the <br /> System Integrity Report did not adequately address four required elements. <br /> 2. Tank System Assessment Requirements <br /> For the tank system comprised of Tanks C and D and their ancillary equipment(Tank System), <br /> information about tank tightness testing, certification of the tanks' structural integrity, tank dimensions on <br /> the tank drawings, and a statement addressing ancillary equipment support are addressed in the following <br /> subsections. <br /> GHD ISD 9001 <br /> 30 River Park Place West Suite 220 Fresno California 93720 USA <br /> T 559 326 5900 F 559 326 5905 W www.ghd.com E.4ln F[RiHG n[S10R <br />