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OLE,A,P\THCON associated tank tightness testing data is not available. After discussions with SJCEHD on how to properly meet this requirement for tanks that do not have available integrity testing at the time of installation, EarthCon reached out to the DTSC, on behalf of Pick -n -Pull, regarding requirements for tank testing. Through a series of phone calls and emails from January through March 2019, DTSC clarified that tanks are required to have integrity or leak testing and that Title 22 California Code of Regulations (CCR) § 66265 provides a number of ways in which that can be accomplished, including visual inspections. Since testing records are not available for when the existing tanks were installed, it is recommended that leak testing can be achieved by visual inspection. The tanks should be inspected daily for leaks and/or damage by site personnel using the inspection form provided in Appendix E or an equivalent Pick -n -Pull document. In the event that a tank is replaced in the future, tank integrity testing should be done at the time of installation. • Tank clips and/or bolts were not observed. However, installation of tank clips and/or seismic cables are not recommended. After discussions with a representative from Poly Processing (manufacturer), and as evaluated by our Civil P.E., it was concluded that significant movement of these types of tanks are unlikely given their stable construction. The tanks height and width ratios make them unlikely to tip over during a seismic event. • Secondary containments associated with the hazardous waste tank system are compliant with the regulations identified in 22 CCR 66265. They are in good condition with no apparent leaks or other damage. The containment volumes are sufficient to contain the volume of the largest tank and longest piping run within each compartment. The construction material type (XLPE or HDPE) of the secondary containment are compatible with the materials stored, subject to the exceptions specified above for 01-04 and Al -A4. There are no recommended corrective actions regarding secondary containment at this time. Secondary containments should continue to be inspected daily by site personnel for evidence of leaks and/or damage site personnel using the inspection form provided in Appendix E or an equivalent Pick -n -Pull document. Any debris, parts, or equipment observed within the containments during inspections should be removed immediately. • The piping associated with the hazardous waste tank system is compliant with the regulations identified in 22 CCR 66265. It is in good condition with no leaks or other damage and is compatible with the service for the used oil, waste antifreeze, and waste gasoline/diesel drain systems. The piping is adequately supported and protected against Hazardous Waste Tank Assessment Stockton, CA Schnitzer Steel — Pick -n -Pull 9 Project No. 04.20160002