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OWENS•BROCKWAY <br /> GLASS CONTAINERS 01 <br /> a unit of Owens-Illinois <br /> October 27 , 1988 <br /> go5gaVE0 <br /> APR 21 1989 <br /> Mr . Jaime Favila <br /> Environmental Health Division ENVI^pi,!¢vENTi\LI;EALTH <br /> San Joaquin Local Health District PERMIIISERVICES <br /> 1601 East Hazelton Ave . , P.O. #2009 <br /> Stockton, CA 95201 <br /> OI TRACY UNDERGROUND STORAGE TANK DELISTING REQUEST <br /> Dear Mr . Favila: <br /> This letter will document my phone comments of 10/27 , pursuant to <br /> our May, 1988 phone discussions and your 6/2/88 letter , a copy of <br /> which was received 9/1 . <br /> First, it appears that the two recirculating process quench water <br /> sumps would be excluded from this program by Section 25281 (u) ( 5 ) <br /> of the State ' s Chapter 6 .7 Underground Storage of Hazard <br /> Substances Act which specifically defines "underground storage. <br /> tanks" to not include "structures such as sumps, separators , . . . <br /> separation sumps , lined and unlined pits, sumps and lagoons . " <br /> Additionally, section 2511 ( 1 ) of the State ' s wastewater <br /> regulations appears to specifically exempt "oil-water separators <br /> designed, constructed, and operated according to American <br /> Petroleum Institute (API ) specifications" from the provisions of <br /> that program. These quench water sumps (A/B & C) were covered by <br /> OI ' s 6/14/84 registrations ; however the State ' s program evidently <br /> did not intend to regulate this type process since the "hazardous <br /> substance" definition on the registration forms targeted <br /> "gasoline , fuel oil , solvents, pesticides , herbicides , <br /> fumigants , hazardous wastes" , and generally items posing <br /> substantive risks . Comments by State representatives <br /> subsequently verified that such recirculating process cooling <br /> water systems ( sumps ) were not to be regulated by this program. <br /> Our process quench water does not seem to be a hazardous waste , <br /> as might be implied by the language of your 6/2 letter , thus the <br /> criteria set forth at that time appeared to be inappropriate . <br /> This material does not appear to be a hazardous substance either <br /> since only minor concentrations of process oils are picked up and <br /> carried by this process water before being skimmed off and <br /> collected for recycle . Therefore , we respectfully submit that <br /> these recirculating cullet quench water sumps should not be of <br /> concern to the State' s underground storage tank program, and we <br /> hereby withdraw the registration previously submitted for these s <br /> units with a request that they be delisted accordingly. <br /> to <br /> One SeaGate Toledo. Ohio 43666 (419)247-5000 Glass Recycles <br /> c - <br />