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Hazardous Waste Tank Assessment January 21, 2022 Central Valley Waste Services Project No. 1246 Lodi, CA Page 3 equipment meeting 22 CCR §66265.192(j) {22 CCR §66265.192(k)(7)} The steel secondary tank provides at least 110% of the volume of the primary tank. • Hazardous characteristics of the waste(s) that have or will be handled {22 CCR §66265.192(k)(8)} Used motor oil is classified as non-RCRA, California-regulated hazardous waste. The used oil is generated during routine maintenance of site vehicles. The Unified Fire Code classifies used oil as a Class IIIB combustible liquid. Site personnel maintain caution that only used oil is pumped to the AST. Therefore, it is unlikely that used oil in the AST would exceed ignitable characteristics of a hazardous waste. Used oil may contain heavy metals that exceed the toxicity characteristics of hazardous waste. Used oil is not considered corrosive and is compatible with the steel primary tank. • Prior to placing the new tank system or component in use, inspect the system for (a) weld cracks or breaks, (b) scrapes of protective coating, (c) corrosion, any structural damage or inadequate construction or installation {22 CCR §66265.192(k)(9)}: The tank is approximately 20 years old. Present condition is level and dry. There is no evidence of weld cracks or breaks, scrapes of protective coatings, corrosion, or any structural damage or inadequate construction or installation. • The results of tank tightness test prior to prior to being placed into use {22 CCR §66265.192(k)(10)} The AST was pressure tested at the factory to UL 142 specifications (3 psi). Tightness testing at this time is not required. • The estimated remaining service life of the tank system {22 CCR §66265.192(k)(11)} According to the literature on steel tanks, if there is adequate design, competent construction, along with regular maintenance and qualified inspections, a steel tank can last for more than 100 years. One of the key variables for corrosion in a steel tank is the presence of corrosives (e.g., acid) and the presence of water (e.g., condensate) in direct contact with the inside of the tank for long periods of time. Since this tank contains used oil (non-corrosive) and is pumped out regularly, it is unlikely that water will remain in contact with the steel substrate for long periods. Tanks of this type typically have a 30-year warranty. The tank should be replaced when the steel substrate is compromised because of corrosion. Typically, the condition of the inside of the primary tank is determined by visual inspection in combination with the use of ultrasonic testing (UT), which measures tank thickness. Due to the lack of access, the measurement of the primary tank thickness on a double wall tank is not possible using UT. We estimate that the remaining service life of this tank is approximately 10 years. However, the service life may be extended if a certified professional determines there is minimal risk from corrosion. Per 22CCR §66265.192(h)(1), this tank will be re-assessed by an engineer within 5 years of the date of this report. • Tank foundation will maintain the load of a full tank {22 CCR §66265.192(a)(5)(A)}: The dead load weight of the full tank is estimated to be 9,000 pounds. The tank is set on a reinforced concrete pad that is at least 6-inches thick. The foundation will maintain the load of this tank.