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8 February, 2000 <br />County of San Joaquin <br />Environmental Health Dept. <br />P.O. Box 3888 <br />Stockton, CA 95201-0388 <br />Attn: Ms. Donna Herin, Director <br />Re: Request for Exemption from Engineering Certification <br />Pep Boys #710 at 845 East Charter Way, Stockton, CA 95206 <br />Ms. Herin: <br />It is our understanding that your agency implements the State of California's hazardous waste <br />management program requirements for generators. As a generator of hazardous waste, our Pep Boys <br />facility located at 845 East Charter Way, Stockton, CA 95206 generates waste oil and antifreeze from <br />the servicing of automobiles. <br />In accordance with state hazardous waste regulations, Pep Boys #710 manages these wastes as non- <br />RCRA hazardous wastes. Waste oil is accumulated in one 500 gallon above ground storage tank (AST) <br />and both waste antifreeze and oily waste water (from shop floor washing) are accumulated in two 280 <br />gallon ASTs. All three ASTs are equipped with secondary containment and all wastes are shipped <br />offsite for recycling. <br />California Code of Regulations Title 22, (22 CCR) section 66265.1920) states that aboveground non- <br />RCRA tank systems with secondary containment, whose design and installation have been approved by <br />a local agency or agencies, may, at the discretion of the Certified Unified Program Agency (CUPA), <br />be exempt from the engineering assessment specified in 22 CCR, 66265.192, provided the following <br />criteria are met: <br />• The tank system must have secondary containment capable of containing 100 percent of the <br />contents of the tank and ancillary piping volume. <br />• If the tank system is exposed to precipitation, the secondary containment system must have <br />sufficient capacity, in addition to that required in subsection 0)(1) of this section, to contain run-on <br />and infiltration from a 25 -year, 24-hour rainfall event. <br />• Tank system secondary containment shall be provided with a leak detection system that is designed <br />and operated so that it will detect either the failure of the primary and secondary containment <br />structure or any release of hazardous waste or accumulated liquid in the secondary containment <br />system within 24 hours, or at the earliest practicable time if the existing detection technology or <br />site conditions will not allow detection of a release within 24 hours. <br />3111 West Allegheny Avenue • Philadelphia, Pennsylvania 19132 • (215) 229-9000 <br />