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Backus, Garrett <br /> From: Backus, Garrett <br /> Sent: Tuesday, April 14, 2020 3:09 PM <br /> To: Muro, Claudia <br /> Subject: RE: Lubezone Tank Assessment <br /> Attachments: tank assessment regs.docx; strandberg tank assessment - lubezone.pdf, BPELSG <br /> Opinion on DTSC Tank Assessment Report.pdf <br /> Claudia, <br /> Here are deficiencies I found in the tank assessment for Lubezone. Highlighted regulations with the sections they did <br /> not address are attached. There are a few typos in the assessment I highlighted. <br /> 1. The assessment must be certified and stamped by a Civil Engineer, especially the seismic calculations. See the <br /> attached BPELSG opinion. <br /> 2. T22 CCR 66265.192(k) (10) - Tank, piping and pumps must be tested for tightness and be in compliance with <br /> local requirements. Our agency requires tightness testing of the entire tank capacity, piping and pumps. <br /> 3. T22 CCR 66265.192(k)(7)—no evaluation of the tank, piping, pump secondary containment including adequate <br /> size,tightness, leak detection. Which parts can be inspected daily in lieu of secondary containment? Which <br /> parts cannot be inspected daily and need secondary containment? <br /> 4. Lodi PD is not accurate and they should correct. <br /> Garrett Backus, Ld. Sr. REHS, CUPA programs <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> (209)468-2986 gbackus(a)sigov.org <br /> https://www.sogov.org/department/envhealth/ <br /> SAN JO QUlM <br /> rnemm-v <br /> 4"MM Via kw <br /> 1 <br />