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r SKF <br /> 21 August 2002 <br /> Dennis H. Catanyag <br /> San Joaquin County <br /> ' Environmental Health Department <br /> Page 3 <br /> 1 <br /> and 2). The turbine is the primary piece of process equipment at the facility responsible <br /> ' for converting steam energy to electricity. POSDEF personnel are reluctant to attempt <br /> excavating the tank because digging near the support column may result in differential <br /> settlement that could cause the turbine to vibrate or become misalign. In-place closure of <br /> the tank is proposed to avoid these potential situations that would be disastrous to <br /> POSDEF's operations. <br /> INABILITY TO PERFORM FURTHER SAMPLING <br /> To allow in-place closure of an underground storage tank, EHD typically requires that <br /> soil samples beneath each end of a tank be collected from slant borings. As shown on <br /> ' Figure 4, the 1,000-gallon used oil underground storage tank at the POSDEF facility is <br /> located with a berm that is congested with aboveground piping. Available space is <br /> insufficient to maneuver drilling equipment near the tank. Further, the existence of pea <br /> ' gravel around the tank suggests it is not feasible to complete slant borings with a hand <br /> auger into native soil beneath the tank because the gravel will likely cause the borings to <br /> collapse. The inability to keep the boring open is probably the reason why Wright was <br /> only able to collect samples of pea gravel for laboratory analysis. <br /> Although POSDEF agrees it would be desirable to obtain samples of native soil beneath <br /> ' the tank, collection of such samples is not imperative to demonstrate the tank has not <br /> leaked. The evaluation of tank integrity and characterization of environmental conditions <br /> completed in 1998 when the tank was last used confirm that a significant release of oil <br /> ' from the tank did not occur. <br /> ' PROPOSED ACTIONS TO COMPLETE IN-PLACE CLOSURE OF TANK <br /> Upon receiving EHD concurrence that the 1,000-gallon used oil underground storage <br /> ' tank can be closed in-place without further sampling, POSDEF will submit the necessary <br /> paperwork to secure official permission to close the tank in-place. Such paperwork will <br /> include EHD's standard application forms entitled Closure In Place and Application for <br /> Permit to Close Underground Storage Tanks Storing Hazardous Materials. After the <br /> applications have been approved, POSDEF will retain a contractor to fill the tank with a <br /> solid, inert material that meets with the approval of EHD. POSDEF will submit required <br /> I documentation to EHD pertaining to the actual in-place closure of the tank. This <br /> documentation will include the underground storage tank tracking record sheet, tank <br /> closure certification form, and hazardous waste manifests, as appropriate. <br />