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July 19, 2019 <br /> Owens- Brockway Glass Container Inc. <br /> Response to San Joaquin County Environmental Health Department' s <br /> June 5, 2019 RCRA Large Quantity Hazardous Generator Inspection Report <br /> 1 . tank configuration (i. e ., horizontal, vertical), material of construction, and gross capacity (in <br /> gallons); <br /> 2. design standard(s), if available, according to which the tank and ancillary equipment were or <br /> will be constructed <br /> and all of the following information : <br /> A . material of construction; <br /> B . material thickness and the method used to determine the thickness; <br /> C. description of tank system piping (material, diameter); <br /> D. description of any internal and external pumps; and <br /> E. sketch or drawing of tank including dimensions . <br /> 3 . documented age of the tank system (if tank was previously used), if available, (otherwise, an <br /> estimate of the <br /> age); <br /> 4. description and evaluation of any leak detection equipment; <br /> 5 . description and evaluation of any corrosion protection equipment, devices, or material; <br /> 6. description and evaluation of any spill prevention or overfill equipment; <br /> 7. description and evaluation of secondary containment for the tank system including applicable <br /> secondary containment for ancillary equipment as required in subsection 66265 . 193 (f); <br /> 8. hazardous characteristics of the wastes that have been or will be handled. <br /> 9 . prior to placing a new tank system or component in use, an independent, qualified installation <br /> inspector or an independent, qualified, professional engineer, registered in California, either of <br /> whom is trained and experienced in the proper installation of tank systems, shall inspect the <br /> system or component for the presence of any of the following items and document in writing the <br /> results of the inspection : <br /> A . weld cracks or breaks; <br /> B. scrapes of protective coatings; <br /> C. corrosion, <br /> D. any structural damage or inadequate construction or installation such as cracks, <br /> punctures, damaged fittings . All discrepancies shall be documented in the assessment and <br /> remedied before the tank system is placed in use. <br /> 10. all new tanks and ancillary equipment shall be tested for tightness prior to being placed in use . <br /> The results of the test(s) shall be documented in this assessment. Tank system integrity or leak <br /> test requirements must be in compliance with all local requirements. Prior to conducting a tank <br /> system integrity test or leak test, contact local agency staff for local requirements . <br /> 11 . estimated remaining service life of the tank system based on findings of sections (1) through <br /> (10) . <br /> Immediately amend the tank system assessment to include all required information and submit a <br /> copy of the amendments to the EHD. <br /> This is a repeat violation, Class 11. <br /> Response to Items #502 and 503 . <br /> We have contacted a Professional Engineer registered in California to perform tank integrity <br /> 9 <br />