Laserfiche WebLink
2 <br />Mr. Backus, although the facility’s hazardous waste generation rates qualify them for a SQG generator status, should the <br />facility exceed the LQG threshold in the future, then the facility will need to comply with LQG requirements. Therefore, our <br />client’s facility would like to complete the used oil tank certification. <br /> <br />In reviewing hazardous waste storage tank requirements applicable to LQGs in Title 22 of the California Code of <br />Regulations, Division 4.5, Chapter 15, Article 10 on Tank Systems, we believe that the used oil tank system meets all <br />requirements that would apply to a LQG facility except that the used oil transfer piping includes several threaded <br />connections that may not be considered to be provided with secondary containment meeting the requirements of 22 CCR <br />66265.193(f). <br /> <br />What would the process and costs be to request an evaluation by you (CUPA) whether threaded connections on the <br />client’s used-oil piping (primary containment) coupled with daily inspections would qualify as alternative ancillary <br />equipment secondary containment under 22 CCR 66265.193(m)? <br /> <br />Thank you. <br /> <br />Caitlin Santinelli <br /> <br />From: Backus, Garrett [EHD] <gbackus@sjgov.org> <br />Sent: Thursday, November 18, 2021 1:46 PM <br />To: Santinelli, Caitlin/ATL <Caitlin.Santinelli@jacobs.com> <br />Cc: Manzo, Elena K. [EHD] <emanzo@sjgov.org>; Nissim, Melissa [EHD] <mnissim@sjgov.org> <br />Subject: [EXTERNAL] RE: CUPA approval of alternative piping containment method <br /> <br />So the facility is not required to conduct an AST re-certification assessment/report every 5 years per 22 CCR <br />66265.192(h)? <br /> <br />Not required if the site is not a large quantity hazardous waste generator . <br /> <br />Garrett Backus, Ld. Sr. REHS, CUPA programs <br />San Joaquin County Environmental Health Department <br />1868 E Hazelton Ave, Stockton, CA 95205 <br />Desk: (209) 468-2986 Cell: (209) 616-3030 <br />Email: gbackus@sjgov.org <br /> <br />Free CUPA training classes signup: https://www.sjgov.org/department/envhealth/ <br /> <br /> <br />From: Santinelli, Caitlin/ATL <Caitlin.Santinelli@jacobs.com> <br />Sent: Thursday, November 18, 2021 10:03 AM <br />To: Backus, Garrett [EHD] <gbackus@sjgov.org> <br />Cc: Manzo, Elena K. [EHD] <emanzo@sjgov.org>; Nissim, Melissa [EHD] <mnissim@sjgov.org> <br />Subject: RE: CUPA approval of alternative piping containment method <br /> <br />CAUTION: This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the <br />sender and know the content is safe. <br /> <br />Yes, this is the USPS facility. <br /> <br />So the facility is not required to conduct an AST re-certification assessment/report every 5 years per 22 CCR <br />66265.192(h)? <br /> <br />Caitlin Santinelli <br /> <br />From: Backus, Garrett [EHD] <gbackus@sjgov.org> <br />Sent: Thursday, November 18, 2021 12:42 PM <br />To: Santinelli, Caitlin/ATL <Caitlin.Santinelli@jacobs.com>