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Therefore, this operator knowledge has been used to contend that no hazardous waste is now, or has been stored in the transmix tank. The material routinely stored in the transmix tank is periodically transported off-site to a permitted, product reclaiming or recycling facility where the useable product is recovered and the resulting waste stream is treated. Tesoro made the decision to collect "worst case" liquid samples to respond to San Joaquin County's alleged violation of not determining if a waste is hazardous. Worst- case samples would, by definition,be collected from sources as close to a gasoline source as possible and from one that would present minimal potential for dilution. Therefore, Tesoro chose to sample liquids retained in the four rack sumps following gasoline truck loading at the terminal. Tesoro collected 4 discrete samples of petroleum-impacted, rack, sump-drain influent at the points of generation from each of the four rack sumps on August 7, 2000. The samples were analyzed for the hazardous waste constituent benzene as part total BTEX concentration determination using EPA Method 8020. The raw data appear as Appendix I, and results are tabulated as Table 1. Analytical results yielded a total benzene concentration range of from non-detect (ND) to 230 ppb (0 — 230 ppb) from the four samples. Therefore, rack water was determined to be a non-hazardous liquid. These results are consistent with the historical use of operator knowledge. Petroleum-impacted rack water collected at the facility is transported off-site to a permitted petroleum reclamation/recycling facility for product recovery. Violation No. 2: (45.) Contingency Plan Incomplete—lacks description of local arrangements 66265.52 (CCR) Response No. 2: Appendix II provides copies of correspondence to local police and fire departments as well as a local hospital that accompanied transmittal of copies of the Stockton Terminal Hazardous Waste Contingency Plan (HWCP) to those entities in February 1995. The Tesoro Stockton Terminal only is a large quantity generator (LQG) during months when petroleum storage tanks are cleaned and tank bottom sludge is removed for off-site disposal. Tanks were cleaned in 1995, hence the HWCP was forwarded to the appropriate local and State entities. Terminal operations and personnel have been consistently maintained as described in the 1995 HWCP since that time. The Stockton Terminal was in conditionally exempt, small quantity generator (CESQG) status at the time of the inspection, as no site work was in progress or had occurred in July, or at any other time within the last year, or more, that would have generated any waste and re-established the LQG status of the Terminal. Therefore, a HWCP was not required per the regulations at the time of the inspection. However, in the interest of being prepared for the next time Tesoro may again fall under LQG status, please refer to Appendix III, which provides an updated and amended copy of the Terminal Spill 2