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Also, there is a variance provision for existing tanks under § 66265.193, Containment and Detection of Releases, that was brought up by a colleague, but I have determined that that only applies to secondary containment requirements and you mentioned that this tank does have secondary containment, correct? § 6626o.io. Definitions: "New tank system" or "new tank component" means a tank system or component that will be used for the transfer, storage or treatment of hazardous waste and for which installation (as defined under "Existing tank system" in this section) has commenced after the dates indicated below; except, however, for purposes of sections 66264.193(g) and 66265.193(g), a new tank system is one for which construction commences after the dates indicated below: (See also "Existing tank system.") (a) July 14, 1986, for tanks containing RCRA hazardous wastes, unless: (1) the owner or operator is a conditionally exempt small quantity generator as defined in 40 CFR section 261.5, or a 100 to 1,000 kg per month generator as defined in 40 CFR section 265.201, or (2) the owner or operator is not subject to regulation in 40 CFR part 264 or part 265 pursuant to an exemption in 40 CFR section 264.1 or section 265.1; (b) July 1, 1991 for: (1) tanks containing only non-RCRA hazardous wastes, and (2) tanks containing RCRA hazardous wastes, if: (A) the owner or operator is a conditionally exempt small quantity generator or a 100 to 1,000 kg per month generator, or (B) the owner or operator is not subject to regulation in 40 CFR part 264 or part 265 pursuant to an exemption in 40 CFR section 264.1 or section 265.1, but the owner or operator is subject to the standards of article 10 of chapter 14 or article 10 of chapter 15 of this division. All new tanks shall be tested for tightness prior to being placed in use using tank system integrity or leak tests. According to this, it does not necessarily have to have a vacuum test performed for tank assessment. It does not specify the types of integrity testing in§ 66264.192 for new tanks, but in § 66264.191 for existing tanks it states that integrity tests other than pressure tests may be used {results of a leak test, internal inspection, or other tank system integrity examination performed (i.e., ultrasonic, internal examination, volumetric tank test, pipeline pressure test} It does say that these requirements must be in compliance with all local requirements though. One option would be to contact the CUPA and ask if system integrity tests such as the above would be sufficient. Everything I keep reading leads me back to the system integrity "or" leak test. If the CUPA is still insisting on a vacuum test, have you guys contacted the manufacturer to see if there is any way to obtain a sealed cover for the 16" opening? If any more info funnels in from other units that I have inquired to, I will let you know. Thank you, ra