Laserfiche WebLink
Florido, Elianna <br /> From: Florido, Elianna <br /> Sent: Tuesday, July 23, 2019 2:43 PM <br /> To: 'Karen Petryna' <br /> Cc: 'Bill Boscacci'; 'Subbarao.Nagulapaty@ghd.com' <br /> Subject: RE: Conference Call with SJCEHD Inspector Elianna Florida, REHS re: RCRA Large <br /> Quantity Hazardous Waste Generator Inspection Report, dated 6/21/2019, for the 0-1 <br /> Facility at 14700 W. Schulte Rd, Tracy <br /> Attachments: HW_Tank_Assess_Guidance.pdf <br /> Hi Karen, <br /> Thank you for your email. I agree with your understanding of items 1, 2, and 4 listed in your email. Below I <br /> address/clarify items 3, 5, and 6 listed in your email: <br /> 3. Upon further review of item#503, it was brought to my attention that my supervisor, Elena Manzo, had noted <br /> additional information missing from the two 1,000-gal. used oil tank assessments prior to me writing the inspection <br /> report. In addition to the tank tightness testing for each tank,the following information is not included in the tank <br /> assessments: <br /> a. A certification statement that the tanks have sufficient structural integrity, and are acceptable for <br /> transferring waste (a note was provided on page 9 of 14 stating that"structural angles" that are conveying <br /> skimmer hoses are not securely mounted and minor product leakage was observed on the top of each tank). <br /> b. Tank dimensions on the tank drawings. <br /> c. A statement addressing if ancillary equipment is supported and protected against physical damage and <br /> excessive stress due to settlement,vibration, expansion or contraction. <br /> Please ensure that the tank assessments for the two 1,000-gal. used oil tanks and the 1,550-gallon oily water tank meet <br /> all of the requirements cited under 22 CCR 66265.192. <br /> 5. Based on the APSA inspection, which was conducted by Lydia Baker and Cesar Ruvalcaba on the same days as <br /> the Hazardous Waste inspection, it appears that the secondary containment for the three tanks is adequate. If <br /> you have further questions regarding the secondary containment for these tanks, please contact Lydia Baker at <br /> (209)468-8257. <br /> 6. Our agency relies on DTSC's interpretation that a qualified engineer is one whose license (Title or Practice) <br /> allows that individual to engage in the work of assessing whether or not a tank system meets the operating <br /> requirements specified in the applicable regulations. Further,the individual with the appropriate license must <br /> also have expertise within the area they are practicing(Cal. Code Regs, title 16, division 5, §415 [Practice within <br /> area of competence]) (See attached DTSC's tank assessment guidance document). <br /> Please don't hesitate to contact me if you have any further questions or concerns. <br /> Thank you, <br /> Elianna Florido, REHS <br /> San Joaquin County Environmental Health Department <br /> Registered Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br />