COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

Baker, Lydia [EHD] From: Mohamed Ibrahim <mibrahim@schn.com> Sent: Thursday, July 8, 2021 7:11 AM To: Baker, Lydia [EHD] Cc: Linda Shaffer Subject: RE: PNP -3927 Clark Drive Attachments: DTSC correspondence.pdf CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Lydia, My apologies for the delay as I am new to the role and needed to review with the consultant that prepared the report the background and history. Please see the following responses from the consultant: -Can you please provide the specific code section in 22 CCR 66265 that allows daily inspections as a method of tank tightness testing? Response: There is not a specific section that says that; however, 22 CCR 66265.1930(3) does state: (c) To meet the requirements of subsection (b) of this section, secondary containment systems shall be at a minimum: (3) provided with a leak detection system that is designed and operated so that it will detect the failure of either the primary and secondary containment structure or any release of hazardous waste or accumulated liquid in the secondary containment system within 24 hours, or at the earliest practicable time if the existing detection technology or site conditions will not allow detection of a release within 24 hours This section can be interpreted to say that daily operational inspections would be adequate to detect a leak, therefore, an inspection that does not identify a leak would demonstrate that the tank integrity was intact. -Can you provide the name of who you spoke with at DTSC? Response: Samantha Lawler Environmental Scientist/Regulatory Assistance Officer Industry Assistance, Training, and Outreach Unit Hazardous Waste Management Program Phone: (916) 324-0092 Samantha. Lawler@dtsc. ca. gov -Can you provide written documentation (you included emails in your response) that DTSC said daily inspections are allowed as tank tightness testing? Response: As presented in the attached documentation, the DTSCsaid that alternate forms of inspection could satisfy the requirement but that it was ultimately up to the CUPA to determine compliance with applicable local requirements. I hope that these responses to the above referenced items satisfy the inquiries of the County, and please advise should you have any further questions regarding these matters.