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The following is an itemized list of RCRA hazardous waste violations that have not
<br />been addressed for PNP Stockton #80 as of May 19, 2021.
<br />Open violations from October 103 2019 inspection
<br />Violation #503 -Hazardous waste tank assessment is incomplete.
<br />OBSERVATION: This facility has hazardous waste tanks with incomplete tank assessments. Tank tightness
<br />testing results are not included in the tank assessment for the four used oil tanks, four used antifreeze tanks and the
<br />used oil customer drop-off tank. The certification attestations are also signed by Charina Gaspay (Regional
<br />Environmental Manager) of PNP and not by the engineer.
<br />REGULATION GUIDANCE: Title 22 California Code of Regulations section 66265.192(a)
<br />Owners or operators of new tank systems or components shall ensure that the foundation, structural support,
<br />seams, connections, and pressure controls (if applicable) are adequately designed and that the tank system has
<br />sufficient structural strength, compatibility with the waste(s) to be transferred, stored or treated, and corrosion
<br />protection so that it will not collapse, rupture, or fail. The owner or operator shall obtain a written assessment
<br />reviewed and certified by an independent, qualified, professional engineer, registered in California in accordance
<br />with section 66270.11(d) attesting that the system has sufficient structural integrity, is acceptable for the
<br />transferring, storing and treating of hazardous waste, and that the tanks and containment system are suitably
<br />designed to achieve the requirements of this article. This assessment shall be obtained prior to placing the tank
<br />system in service, and shall be kept on file at the facility. This assessment shall also include, at a minimum, the
<br />following information:
<br />(1) design standard(s) according to which the tank(s) and ancillary equipment are or will be constructed;
<br />(2) hazardous characteristics of the waste(s) to be handled;
<br />(3) for new tank systems or components in which the external shell of a metal tank or any external metal component
<br />of the tank system is or will be in contact with the soil or with water, a determination by a corrosion expert of:
<br />(A) factors affecting the potential for corrosion, including but not limited to:
<br />1. soil moisture content;
<br />2, soil pH;
<br />3. soil sulfides level;
<br />4. soil resistivity;
<br />5, structure to soil potential;
<br />6, influence of nearby underground metal structures (e.g., piping);
<br />7, stray electric current; and,
<br />8. existing corrosion -protection measures (e.g., coating, cathodic protection), and
<br />(B) the type and degree of external corrosion protection that are needed to ensure the integrity of the tank system
<br />during the use of the tank system or component, consisting of one or more of the following:
<br />1, corrosion -resistant materials of construction such as special alloys or fiberglass -reinforced plastic;
<br />2, corrosion -resistant coating (such as epoxy or fiberglass) with cathodic protection (e.g., impressed current or
<br />sacrificial anodes); and
<br />3. electrical isolation devices such as insulating joints and flanges;
<br />(4) for underground tank system components that are likely to be affected by vehicular traffic, a determination of
<br />design or operational measures that will protect the tank system against potential damage; and
<br />(5) design considerations to ensure that:
<br />(A) tank foundations will maintain the load of a full tank;
<br />(B) tank systems will be anchored to prevent flotation or dislodgement where the tank system is placed in a
<br />saturated zone, or is located within a seismic fault zone; and
<br />(C) tank systems will withstand the effects of frost heave.
<br />Title 22 California Code of Regulations section 66270.11
<br />(d) Certification. I certify under penalty of law that this document and all attachments were prepared under my
<br />direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and
<br />evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those
<br />persons directly responsible for gathering the information, the information submitted is, to be the best of my
<br />knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting
<br />false information, including the possibility of fine and imprisonment for knowing violations.
<br />Title 22 California Code of Regulations section 66265.192(k)
<br />The tank system assessment shall include all of the following information:
<br />(1) tank configuration (i.e., horizontal, vertical), material of construction, and gross capacity (in gallons);
<br />(2) design standard(s), if available, according to which the tank and ancillary equipment were or will be constructed
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