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Sep 15 03 O3: 46p Ri Sharpe 7C0 ?9--1096 Re:[Fwd: Request for Interpretation,Vent Lintoncrete Island] P and vapors. This is a major regulatory interpretation. Has this interpretation been made before? Is it only applicable to the amended l/l/03 Law? The terms "ground" and "surface" in this interpretation evolve as critical words without specific definition as to the applicablity to the law, In the Law, "soils" is a specified media that is to be protected and monitored along with "groundwater" and "backfill". ?ire concrete and asphalt currently protected and monitored at the "surface" or " below the surface" from hazardous liquids and vapors? What regulatory event happens when fuel is dispensed into the UST or motor vehicle and fuel spills onto the surface and leeches,through surface cracks, into the concrete or asphalt media? Is that an unauthorized release? Is the concrete or asphalt subject to remediation and/or removal? We contacted Tracer Re„earch to determine if their ELD technology has been approved by the State for detection of liquids or vapors in concrete and asphalt media. We were told verbally that their ELD technology was not independently evaluated for detection of liquids and vapors within concrete or asphalt media. Tracer stated that their current ELD technology is not effective for detection of hazardous liquids or vapors released into concrete and asphalt media. I am proposing to put this critical interpretation matter on the agenda at the Working Meeting, March 17. I doubt that our industry has considered concrete and asphalt media in their monitoring and startup test designs. Our industry must be informed immediately that concrete and asphalt are media to be protected and monitored just like groundwater, soils and backfill- 1 will be forwarding this interpretation to the industry attendees so they will have at least a few days to consider this interpretation. Sincerely, Rick Sharpe Laura Chaddock wrote. > Rick - > I've discussed this with others in my office and the SWRCB's response > to your questions are consistent with my previous email. Vent lines > which are beneath the concrete are considered "beneath the surface" and > are therefore subject to the piping requirements outlined in Section > 25290.1 of the Health and Safety Code. You can also refer to Section > 25290.1(k) which states "those portions of vent lines, vapor recovery > lines, and fill pipes that are beneath the surface of the ground are > pipe". You'll notice that the law says "beneath the surface". The 2 of 3 4/11/2003 10:51 AM