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Florido, Elianna [EHD] From: Sent: To: Subject: Attachments: Abraham, David <David_Abraham@pepboys.com> Wednesday, April 22, 2020 3:31 PM Florido, Elianna RE: Pep Boys #711 - 2020 Haz Waste Inspection 711 Tank Certification Report Revised 4.22.2020.pdf Elianna, I have spoken with our Professional Engineering Firm, at Salmon & Schroeder, Inc. The President there is John Schroeder. He has corrected the wording on the Certification Statement and I have attached the revised assessment above. However, he and his team, after much conversation and review, are of the opinion that the tightness testing is for New Tanks only. I will provide his email to me regarding the law and requirements. He completes assessments throughout the state, not only for Pepboys, but for many other companies as well. According to Mr. Schroeder, no inspector has ever required tightness testing on older tanks. Thanks, Dave Been in long conversations with my whole team on this matter this morning. If you review the subject report, and all our reports, but on page 7 of the subject report we say: Title 22, 66265.192(d) -- All new tanks and ancillary equipment shall be tested for tightness prior to being placed in use. The tank meets UL 142 Standard. This standard requires that the tank must be hydrostatically tested to 25 psi at the factory. Now, we also supply manufacturers literature in the appendices that state explicitly that the tanks are UL 142. Thus the manufacture's literature constitutes certification by the manufacturer that the unit passed the tightness test. Further a "hydrostatic test at 25 psi" translates to "holds water." Thus, in essence the tank is continually under such test, if it failed the test it would leak. And thus when we certify it is not leaking, we are certifying that it is tight. So, it is our stance this requirement is covered in the report as it stands. President/Principal Salmon & Schroeder, Inc. 818-249-9228 Mobile: 818-414-5143