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DEC 2 12003 <br /> Department of Toxic Substances.C4F OEALTH <br /> Vv, At,.vul <br /> Edwin F. Lowry, Director CES <br /> Terry Tamminen 8800 Cal Center Drive Arnold Schwarzenegger <br /> Agency secretary Sacramento, California 95826-3200 Governor <br /> Cal/EPA <br /> December 23 , 2003 Certified Mail No.: 7001 0320 0000 9689 7231 <br /> Mr. Xiaosong Wang, Ph.D. <br /> QEHS Manager <br /> Pilkington North America Inc. <br /> 500 East Lousie Avenue <br /> Lathrop, California 95330 <br /> Dear Mr. Wang: <br /> The Department of Toxic Substances Control (DTSC) inspected the Pilkington North <br /> America, Inc. (PNAI) facility located at 500 East Louise Avenue in Lathrop, California on <br /> November 19 and 20, 2003. During that inspection, DTSC determined that PNAI is <br /> operating a tank system used for separating water from used oil. <br /> PNAI indicated that the tank system comprising the oil-water separator was installed in <br /> approximately 1963. Used oil is a non-RCRA waste (i.e., is not regulated as a <br /> hazardous waste under the federal Resource Conservation and Recovery Act). After <br /> further investigation, DTSC has determined that PNAI was required to provide <br /> secondary containment for the tank system within two years of July 1, 1991 or by the <br /> time the tank has reached fifteen years of age which ever is later, pursuant to California <br /> Code of Regulations (Cal. Code of Regs.), title 22, section 66265.193. While the tank <br /> system owned and operated by PNAI appears to be equipped with secondary <br /> containment, it is not clear if that secondary containment meets all applicable <br /> requirements specified in Cal. Code of Regs., title 22, section 66265.193. The following <br /> requirements are listed in Cal. Code of Regs., title 22, section 66265.193: <br /> • The secondary containment must be placed on a foundation or base capable of <br /> providing support to the secondary containment system and resistance to <br /> pressure gradients above and below the system and capable of preventing <br /> failure due to settlement, compression, or uplift pursuant to paragraph (c)(2) in <br /> section 66265.193. <br /> • The secondary containment must be sloped or otherwise designed to drain and <br /> remove liquids resulting from leaks, spills or precipitation pursuant to paragraph <br /> (c)(4) in section 66265.193. <br /> e Printea on Recycled Paper <br />