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FROM:KDNICA FAX TO: 1510 420 5e% NOU 1, 1%9 11:S4AM P.04 <br /> Epe <br /> rAuEgmiA. <br /> TATE WATER RESOURCES CONTROL BOARD <br /> DIVISION OF CLEAN WATER PROGRAMS <br /> Wold 7 STREET.SUITE 130 <br /> .o.IBM 944212ra <br /> ACRAMENTO.CA 94244.2120 <br /> (9161227-4332 <br /> aceln**(916)227.4349 <br /> APR 1 9 <br /> Mr. Philip Smith <br /> President <br /> Phil-Tite Enterprises <br /> 3732 Electro Way <br /> Redding, CA 96002 <br /> Dear Mr. Smith, <br /> INDEPENDENT TESTING ORGANIZATION FOLLOW-UP INSPECTIONS <br /> This letter is written in response to your letter dated April 17, 1995. In it you raise the question: <br /> "Are we required to have our [independent) testing organization conduct follow-up inspections <br /> for our Underdispenser Containment Boxes and Shear Valve Anchoring Device?" Each of the <br /> two components perform separate functions and therefore must be answered separately. <br /> With respect to Underdispenser Containment Boxes, the answer is no as long as this component is <br /> designed and constructed as a secondary containment component. An Underdispenser <br /> Containment Box is understood to be designed and constructed as a secondary containment <br /> component. That is, it does not routinely come into contact with hazardous substances like <br /> primary components do nor is it dcsign0.ap4 constructed as an integral part of a primary <br /> containment comparient. Based on this understanding,it falls under the requirements given in <br /> subsection 263 1(d) ()f the (.'alifornia Code of Regulations(CCR). This section states, in part: "A <br /> secondary containment system which is not an integral part of primary.containment shall be <br /> designed and constructed according to an VMYS-ODy ii_stat register <br /> r0fcssjQp31 ".nnneel or accordi. <br /> _to aonk1jijecomiggoi indust[y Bode 2r rn Mgg"n <br /> standard..." <br /> Subsection 263 1(d) does not specify that an independent eating which does require <br /> formal periodic.component production inspections, review the design and construction. It does <br /> require that a state registered professional engineer or an independent third party review the <br /> design and construction of all secondary containment components. From Subsection 2611 CCR: <br /> "Anindeperident third party'means independent testing organizations, consulting firms, test <br /> jab()yajories, lot-for*profit research organizations and educational institutions with no financial <br /> interest in the 1-nattCTIq under consideration." From this definition, an independent testing <br /> organization meets the definition of an independent third party and can review the design and <br /> construction for secondary containment components like yours. The production, however, is not <br /> required to be periodically inspected. <br /> The second component, the Shear Valve Anchoring Device, does not appear to be a primary or a <br /> secondary containment component. Therefore, it does not have to conform to the requirements <br />