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Sep 15 03 03: 45p R Sharpe 760-'"?9- 1096 <br /> P. 2 <br /> Re:[Fwd: Request for lnterpretatian,Vent tin ncrete Island] <br /> Subject: Re: [Fwd: Request for Interpretation, Vent Line in Concrete Island) ! � <br /> Date: Thu, 10 Apr 2003 14:56:33 -0700 <br /> From: "Laura Chaddock" <chaddocl@?a cwp.swrch.ca.gov> <br /> To: <tanktech@pEasteel.com> <br /> Rick - Thank you for your patience! <br /> As we discussed earlier, the intent of AB 2481 was to regulate the <br /> piping in question if it was beneath the surface (where vapors from the <br /> operating UST system could enter the backfill) . <br /> As you know, Section 25290.1 of the Health and safety Code reads "any <br /> system installed to meet the requirements of this section, those <br /> Portions of the vent lines vapor recovery lines, and fill pipes that are <br /> beneath the surface of the ground are pipe. . . ." I did some research on <br /> this, what i found was the words "beneath the surface of the ground" <br /> were proposed by a lobby (during the legislative process) to <br /> specifically identify that the SWRCB was not to regulate the aboveground <br /> portions of the vent risers and PV valves regulated by CARE. We agreed <br /> to this language because it was not our intent to duplicate what GARB <br /> was already regulating aboveground. It was not our intent to exclude <br /> the piping in question. <br /> Although our intent is clear, I do not think we have the authority to <br /> prevent the installation of the vent piping in question. We suggest <br /> that you pursue approval from CARD and the Office of State Fire Marshal <br /> for the design and construction, they might have input/concerns <br /> regarding the vent in the canopy column (since this is a new design) . <br /> Please note: Our research (which drove the requirements for AB 2481) <br /> identifies single-walled vent lines as a source of vapor releases. <br /> Concrete is not impervious, and these vapors can enter the backfill. We <br /> will likely seek a legislative fix (this year) to take care of this <br /> potential vapor release pathway. <br /> Please contact me if you have further questions. <br /> -y~~-~-ry# <br /> Laura Chaddock �~� <br /> Division of Water Quality <br /> State Water Resources Control Board <br /> PO Box 944212 <br /> Sacramento, CA 94244 <br /> Phone: (916) 341-5870 <br /> Fax: (916) 341-5808 <br /> E-mail: chaddocl@swrcb.ca.gov <br /> -------------------------- <br /> >>> Rick Sharpe <tanktech$plasteel.com> 03/12/03 12:24PM >>> <br /> Laura, <br /> The State's informal iriterpretation below means that the State <br /> legislative "intent" was that concrete and asphalt must also be <br /> protected and monitored for unauthorized releases of hazardous liquids <br /> 1 of 3 <br /> 4111/2003 10:51 AM <br />