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From: Florido,Elianna <br /> To: Karen Petrvna <br /> Cc: Bill Boscacci;Subbarao Nagulapaty <br /> Subject: RE:Conference Call with SJCEHD Inspector Elianna Florida,REHS re: RCRA Large Quantity Hazardous Waste <br /> Generator Inspection Report,dated 6/21/2019,for the O-I Facility at 14700 W.Schulte Rd,Tracy <br /> Date: Tuesday,July 23,2019 2:43:41 PM <br /> Attachments: image009.pnng <br /> imaae010.Dna <br /> image011.pnng <br /> imaae012.Dna <br /> image013.pnng <br /> HW Tank Assess Guidance.Ddf <br /> Hi Karen, <br /> Thank you for your email. I agree with your understanding of items 1, 2, and 4 listed in your email. <br /> Below I address/clarify items 3, 5, and 6 listed in your email: <br /> 3. Upon further review of item #503, it was brought to my attention that my supervisor, Elena <br /> Manzo, had noted additional information missing from the two 1,000-gal. used oil tank assessments <br /> prior to me writing the inspection report. In addition to the tank tightness testing for each tank, the <br /> following information is not included in the tank assessments: <br /> a. A certification statement that the tanks have sufficient structural integrity, and are <br /> acceptable for transferring waste (a note was provided on page 9 of 14 stating that <br /> "structural angles"that are conveying skimmer hoses are not securely mounted and <br /> minor product leakage was observed on the top of each tank). <br /> b. Tank dimensions on the tank drawings. <br /> c. A statement addressing if ancillary equipment is supported and protected against <br /> physical damage and excessive stress due to settlement,vibration, expansion or <br /> contraction. <br /> Please ensure that the tank assessments for the two 1,000-gal. used oil tanks and the 1,550-gallon <br /> oily water tank meet all of the requirements cited under 22 CCR 66265.192. <br /> 5. Based on the APSA inspection, which was conducted by Lydia Baker and Cesar Ruvalcaba on <br /> the same days as the Hazardous Waste inspection, it appears that the secondary <br /> containment for the three tanks is adequate. If you have further questions regarding the <br /> secondary containment for these tanks, please contact Lydia Baker at (209)468-8257. <br /> 6. Our agency relies on DTSC's interpretation that a qualified engineer is one whose license <br /> (Title or Practice) allows that individual to engage in the work of assessing whether or not a <br /> tank system meets the operating requirements specified in the applicable regulations. <br /> Further, the individual with the appropriate license must also have expertise within the area <br /> they are practicing (Cal. Code Regs, title 16, division 5, §415 [Practice within area of <br /> competence]) (See attached DTSC's tank assessment guidance document). <br /> Please don't hesitate to contact me if you have any further questions or concerns. <br /> Thank you, <br />