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RECEIVED BY SJCEHD (EF) on 5/18/2020 <br /> 1 <br /> May 18, 2020 Reference No. 11189093-2019.5 <br /> Ms. Elianna Florido Sent via Email to EFlorido@sjgov.org <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: Owens-Brockway Glass Container Inc.—Tracy, California <br /> Engineering Assessment and Certification of Integrity of Plant#22 Used Oil and Oily Water <br /> Hazardous Waste Tank Systems <br /> 1. Introduction <br /> As a supporting document to the Used Oil Tanks for the Forming Buildings System Integrity Report, <br /> prepared by HMT Inspection and dated August 16, 2018 as well as the Engineering Assessment and <br /> Certification of Integrity of Pant#22 Used Oil Tank System letter report, dated January 29, 2020, and the <br /> Engineering Assessment and Certification of Integrity of the 1,550-Gallon Polyethylene Waste Tank <br /> System report, dated February 26, 2020 and both prepared by GHD Services, Inc. (GHD), this letter report <br /> documents additional tightness testing of the two 1,000-gallon used oil steel (used oil) and one 1,550- <br /> gallon oily water waste polyethylene (poly)tank systems for Owens-Brockway Glass Container Inc. (0-1) <br /> in Tracy, California. <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 /> On April 22, 2020, in response to the above-listed reports by GHD, the San Joaquin County <br /> Environmental Health Department (SJCEHD) emailed GHD and 0-1 asking how it could be demonstrated <br /> "the tightness testing performed covers both of the tank systems entirely, since it appears that the tanks <br /> were only partially filled with their respective wastes when tested?" <br /> On May 7, 2020, in response to SJCEHD's inquiry, GHD emailed SJCEHD with new protocols for testing <br /> all three hazardous waste tank systems with the tanks completely full. And on May 12, 2020, SJCEHD <br /> emailed GHD and 0-1 there was no objection to the planned testing method but certification from a <br /> professional engineer that the entire tanks are tight was required. <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 />