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penetrant inspection are also included. These technical assessments are required to be <br /> reviewed by an independent, qualified, California-registered professional engineer, who <br /> has certified the tank systems to be adequately designed and compatible with the stored <br /> waste that they will not collapse, rupture, or fail, and that they meet the requirements of <br /> 40 CFR 264.191 and 22 CCR 66264,Article 10, Tank Systems. <br /> According to Business and Professions Code § 6731, "Civil engineering defined," the <br /> practice of civil engineering includes, among other things, activities in connection with <br /> drainage, flood control, foundations, grading, framed and homogeneous structures. The <br /> certification of the hazardous waste tank includes items that involve foundation, <br /> underlying soil, structural support, connection, seismic analysis or evaluation, building <br /> structure evaluation, and hydrographic (flood control) analysis. According to the <br /> Business and Professions Code, these items fall within the licensed practice of Civil <br /> Engineering. So the 22 CCR § 66264.191 tank assessment would need to have <br /> certification of those items signed off by a licensed Civil Engineer. Since none of the <br /> other items required by 22 CCR § 66264.191 require sign off by a licensed engineer, a <br /> licensed Civil Engineer is qualified to certify and sign off on the entire tank assessment. <br /> This assumes that the certifying Civil Engineer would either have expertise on the other <br /> items, such as corrosion and leak control, or would include those with such expertise in <br /> the analyses preceding certification. No Professional Engineer licensed in any branch <br /> other than Civil Engineering is qualified to certify and sign off on the entire tank <br /> assessment. <br /> The Board's laws and regulations protect the practice of civil engineering and require licensure <br /> for all civil engineering projects located in California pursuant to California Business and <br /> Professions Code Section 6731. There are no exemptions to licensure that would be applicable <br /> to these types of reports. As you were advised, our consultant's opinion only applies to the <br /> information that he reviewed and should only be applied to this particular report or to reports that <br /> contain elements that he has identified as requiring a civil engineering license. <br /> Sinc ly, <br /> y Inger ` <br /> Enfor ment Analys <br />