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TESORO <br /> ^�����\VV/n�D Tesoro Petroleum Companies,Inc. <br /> ��Ju�! 3450 South 344th Way,Suite 100 <br /> Auburn,Wa.98001-5931 <br /> 253 896 8700 <br /> AUG 2 4 2000 253 896 8887 Fax <br /> August 24, 2000 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Public Health Services <br /> San Joaquin County <br /> Environmental Health Division <br /> 304 East Weber Avenue Third Floor <br /> Stockton, CA 95202 <br /> Attn: Mr. Steve Sasson, R.E.H.S., RDI <br /> RE: Tesoro Petroleum Stockton Terminal Inspection Response <br /> Tesoro Petroleum (Tesoro) hereby provides our formal response to alleged deficiencies <br /> and violations identified during an on-site inspection of our operations conducted on July <br /> 24, 2000 by San Joaquin County Environmental Health Division. The responses are <br /> presented below in the order provided in the inspection report (attached as Attachment 1) <br /> to facilitate expedient review. <br /> Violation No. 1: (10.) Failure to determine if a waste is a hazardous <br /> waste 66262.11 (CCR) <br /> Response No. 1: <br /> Tesoro operates the Stockton Terminal loading rack under vapor-tight conditions for <br /> gasoline loading. Gasoline tanker trucks must pass vapor tightness tests annually to gain <br /> approval to load at the facility. Therefore, spills or drips of gasoline from fueling tanker <br /> trucks are minimal. For this reason, even small quantities of dripped gasoline are rarely <br /> conveyed into the rack sumps and ultimately to the transmix tank. <br /> Diesel loading at the terminal occurs across the same rack as gasoline. Diesel loading <br /> does not require vapor-tight controls and represents a much higher proportion of the <br /> terminal's throughput. Therefore, small diesel drips and spills are more likely to occur at <br /> the rack and be conveyed to the sump drains than gasoline drips at the rack. <br /> These two sets of circumstances lead to Tesoro's formulation of a body of knowledge, or <br /> "operator knowledge"that the transmix tank routinely holds a significantly larger volume <br /> of washdown water, rainwater and skimmed diesel, as opposed to gasoline components. <br /> 1 <br />