COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

Becky Sundilson From: Jeff Bennett Sent: Friday, April 05, 2019 8:49 AM To: Becky Sundilson Subject: FW: Hazardous Waste Tank Question Jeffrey D. Bennett Principal Hydrogeologist CA PG 6027, CA CHG 400, AZ RG 34764, NV CEM 1784 Earth Con Consultants CA, Inc. 1500 South Sunkist Street, Suite D Anaheim, CA 92806 Office: (714) 500-5454 Mobile: (714) 743-0482 FAX: (714) 960-2462 Statement of Confidentiality: This email and any attachments transmitted with it are confidential and intended solely for the use of the individual or entity to which they are addressed. The information contained in this email is highly confidential and may be subject to legally enforceable privileges. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, reliance, copying, distribution, dissemination or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this communication in error, please notify Earth Consulting Group, Inc. immediately by replying to this email. Please delete all copies of this message and any attachments immediately. From: Lawler, Samantha@DTSC <Samantha.Lawler@dtsc.ca.gov> Sent: Friday, March 01, 2019 2:21 PM To: Jeff Bennett <jbennett@earthcon.com> Subject: RE: Hazardous Waste Tank Question Good afternoon Jeff, I have been reaching out to several units within DTSC trying to find a resolution to your clients tank assessment issue. This week, one of my colleagues brought up the California Aboveground Petroleum Storage Act (APSA). https://Ieginfo.legislature.ca.gov/faces/codes displayText.xhtml?lawCode=HSC&division=20.&title=&part=&c hapter=6.67.&article I have been reading through trying to determine if your client is regulated under this act. If so, I have not yet found any pressure testing requirements. This Act is Implemented and enforced by the CUPA's, not DTSC. On page 11 of the attached FAQ sheet it covers who is subject to the requirements of ASPA. Since the tank is only 385g, the second scenario does not apply, but I do not have enough information on the facility to know if the first applies or not (Are they subject to oil pollution prevention regulations specified in Part 112 (commencing with Section 112.1) of Subchapter D of Chapter I of Title 40?). In your email, you stated that the CUPA was basing their requirements on 22CCR §66265.192(k)(10). This regulation pertains to new above ground storage tanks, not existing. You stated that "The facility does not have record of the age of the tank'; so apparently the CUPA has determined that the tank construction commenced after July 14, 1986 if it is holding RCRA HW or after July 1, 1991 if it is holding non-RCRA HW. As such, new tanks have to have more rigorous tank integrity testing, so you may want to have the age of it assessed again if it is an older tank.