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Pagel of 2 <br />Raymond von Flue [EH] <br />From: Raymond von Flue [EH1 <br />Sent: Thursday, February 18, 2010 4:04 PM <br />To: 'Meyer, Gregory P' <br />Subject: RE: Tank Assessments (Hydrostatic & Seismic Analysis requirements) <br />Attachments: tip -5 modified.doc <br />Mr. Meyer, <br />Is the Aboveground Storage Tank for used oil located in a saturated or seismic zone? If so it needs to be anchored. If not please include a discussion in the <br />assessment. In the original submittal for Holt, it is not addressed. There is no connection between LQG's and Hydrostatic & Seismic Ananlysis requirements. If you <br />are a LQG then you must do a complete HW tank assessment. Upon reviewing the TIP 5 worksheet that I have attached, the only difference between existing and new <br />non-RCRA HW tanks is that for existing the assessment is valid for one year and five years for new tanks. I hope this helps. <br />Raymond von Flue <br />Senior Registered Environmental Health Specialist <br />San Joaquin County <br />Environmental Health Department <br />600 E. Main St. <br />Stockton CA 95202 <br />Voice: (209) 468-9848 <br />Fax: (209) 468-3433 <br />rt{(tK 6PM`� <br />Ingwith - ( —mit—t - IcamrrurkLqunding mating Snlulinne <br />This email and any attachments may contain private, confidential, and privileged material for the sole use of the intended recipient. Any <br />review, copying, or distribution of this email (or any attachments) by other than the intended recipient is strictly prohibited. If you are not <br />the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any <br />attachments. <br />From: Meyer, Gregory P[mailto:Gregory.Meyer@hdrinc.com] <br />Sent: Thursday, February 18, 2010 2:22 PM <br />To: Raymond von Flue [EH] <br />Subject: Tank Assessments (Hydrostatic & Seismic Analysis requirements) <br />Mr. von Flue, <br />It was nice to speak with you this afternoon. Found your email on the EHD website... just had a follow-up question related the relationship between a LQG (of <br />waste oil) and Tank Assessment requirements (i.e., the Model tank assessment). I'm still trying to convince myself of the connection between LQGs and the <br />Hydrostatic & Seismic Analysis requirements. See CCR snapshot below with a highlighted statement. That's one of the only references I find to the subject <br />assessment, but it seems to allow for exemptions (i.e. not placed in a saturated or seismic fault zone). Can you provide any other regulatory citation linking <br />LQGs with this requirement for existing tanks? It probably falls under that concept you mentioned of "all exemptions having passed" for new vs. existing <br />tanks. Also, can you point me to "sunset" details for these exemptions?. <br />Thanks, <br />Greg <br />2/18/2010 <br />