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EAkTHCONO 5.0 CONCLUSIONS AND RECOMMENDATIONS The following is a summary of the findings for the Hazardous Waste Tank System and the associated piping and ancillary equipment: • The hazardous waste tanks are compliant with the regulations identified in 22 CCR 66265. However, based on manufacturer specifications, permeation of the tank contents into polyethylene may occur depending on each chemical. Ethylene glycol(antifreeze)does not attack or permeate high density crosslinkable polyethylene (XLPE) resins up to 100° F. Petroleum hydrocarbons (such as fuel oil, diesel, etc) does not attack high density crosslinkable polyethylene resins; however, they will be absorbed into the wall of the tank and permeation and loss will occur. It is not recommended for polyethylene tanks containing used oil to be stored at room temperatures above 100° F. In addition, the manufacture states that the general life expectancy of the crosslink polyethylene tanks is 10+years with 15 to 20 years being common depending on chemical, concentration, temperature, installation and piping, and venting. The serial numbers on the used oil tanks and the waste antifreeze tanks indicate manufacture dates of 1995 or earlier(with the exception of 02 with an approximate manufacture date of 2009). In addition, the tanks appeared to be in good condition; however, several of the tanks appeared to have discoloration due to possible permeation of the tank contents overtime. Based on the fact that the tanks are at the upper end of their life expectancy it is recommended that replacement of tanks be evaluated on a case-by-case basis. 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. • Secondary containment associated with the hazardous waste tank system is compliantwith the regulations identified in 22 CCR 66265. It is in good condition with no apparent leaks or other damage. The containment volume is sufficient to contain the volume of the largest tank and longest piping run within each compartment. The XLPE materials of construction are compatible with the materials stored subject to the exceptions specified above for the tanks. The secondary containment should continue to be periodically inspected by site personnel for evidence of leaks and/or damage. • 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 and waste antifreeze tank systems. All piping is adequately supported and protected against physical damage or stress. The piping should continue to be periodically inspected by site personnel for leaks and/or damage and repaired as necessary. • The ancillary equipment associated with the hazardous waste tank system is compliant with the regulations identified in 22 CCR 66265. The gravity piping from open funnels to each waste tank acts as atmospheric vents preventing the development of vacuum or pressure. However, emergency vents are not present on any of the waste tanks. EarthCon contacted the engineering department at Poly Processing, the tank manufacturer, to discuss emergency venting of the tanks at the Site. The tanks are rated for usage under atmospheric conditions and the manufacturer does not recommend the use of commercially available emergency vents because the activation pressure exceeds the recommended working pressure of the tank. The manufacturer recommends utilizing the current Hazardous Waste Tank Assessment Stockton,CA Auto Parts Group—Pick-N-Pull 7 Project No.211283