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Toather additional information on the number of HLTs which have e leaked fluid into the environment and the danger that these leaks pose, the SWRCB also surveyed staff at the 21 Local Oversight Program (LOP) agenmes, which are under contract with the SWRCS to oversee cleanup of leaks from petroleum USTs. These LOP agencies are a subset of the LIAs, with the it exception of the Santa Clara Valley Water District However, staff at these j 21 Local Oversight Program (LOP) agencies are usually different from the jl staff who oversee the leak prevention side of the UST program. To obtain a more complete picture of the extent of the problem that HLTs might pose, their responses to the same survey questions were solicited. i h SWRCB staff anticipated that the survey results would provide limited � li information on the threat that HLT leaks might pose to the environment and particularly to water supplies. To supplement this survey data, staff conducted a review of scientific literature pertaining to: 1) the composition of hydraulic fluid commonly used in most HLTs in California, 2) the toxicity of typical HLT fluids, and 3) the environmental fate of these typical HLT fluids. There was a dearth of data, most likely the result of the U.S. Environmental Protection Agency's decision to exempt HLTs from the federal regulatory universe, and hydraulic fluid manufacturers' reluctance to divulge �I trade secret information on the composition of their products. I' 'I �I II. SURVEY OF LOCAL REGULATORY AGENCIES DIR AND THE HLT INDUSTRY r i� 11 Ih A. REGULATORY AGENCY SURVEY RESULTS The intent in contacting the LIA and LOP staffs was to find out how many leaks from HLTs they were aware of and whether any of these f leaks had posed an environmental and, especially, a water supply risk. Staff contacted the DIR, elevator manufacturers, and an industry trade association to get a more complete count of the number of HLTs in California. Staff believed that SWRCB data on the HLT population was incomplete, as the UST regulatory program was not applied on a statewide basis to HLTs until August 9, 1991 On that date, the SWRCB's revised regulations included HLTs over 110 gallons capacity under the definition of an UST (Sec. 2621, Ch. 16, 23 CCR). This capacity limit essentially excludes HLTs that power lifts at automotive i _ 2 _