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PUBLIC. HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue,Third Floor • Stockton, CA 95202 Lir;aR� <br /> 209/468-3420 <br /> July 6,2001 <br /> Donald W.Rognon <br /> Director of Environmental Management <br /> Flying J Inc. <br /> 4185 Harrison Blvd., Suite 320 <br /> Ogden,UT 84403 <br /> Re: 1501 N.Jack Tone Road,Ripon <br /> This letter is being sent in response to your letter dated June 1, 2001. You have requested permission from the San <br /> Joaquin County Environmental Health Division(EHD), the Certified Unified Program Agency (CUPA), to dispose <br /> of the wastewater from your underground storage tank dispenser pans to the oil-water separator on the property. <br /> That oil-water separator is currently permitted through the City of Ripon and is not permitted to accept hazardous <br /> waste. <br /> The California Health and Safety Code (HSC) Section 25291(e) describes the requirements a facility has for <br /> analyzing liquid in the secondary containment for the presence of a hazardous substance. Title 23 of the California <br /> Code of Regulations (CCR) Section 2635(c)((6) describes the method of analysis for the proper disposal of liquid <br /> from secondary containment. <br /> You have only taken one sample from one diesel dispenser pan to make the determination that the liquid does not <br /> contain a hazardous substance. Dispenser pans are designed as a secondary containment system to collect releases <br /> from the primary dispenser piping and prevent the releases from entering the environment. Therefore the liquid in <br /> each dispenser pan may be have a different composition each time it is tested due to releases from the primary <br /> containment. The samples taken from under the dispensers can never be considered a homogenous wastestream. <br /> The requirements suggest that you would have to analyze the waste each time you planned to dispose of this waste <br /> into the oil-water separator. If the sample results indicate that free product is present, the liquid must be handled as <br /> a hazardous waste and the release must be investigated and reported. If the results indicate that free product is not <br /> present, only liquids that are approved by the City of Ripon may be discharged to the oil-water separator. The City <br /> of Ripon must comply with the requirements established by the Regional Water Quality Control Board. <br /> If you choose to begin this disposal practice you must provide the following information to the EHD: <br /> • Written documentation that indicates the City of Ripon is informed of the practice and will accept it. <br /> • An updated underground storage tank monitoring and response plan that indicates this management <br /> practice. <br /> If you have any further questions,please contact Alison Youngblood,REHS,at 209-468-9848. <br /> �' y CIS <br /> Alison Youngblood,REHS <br /> Environmental Health Division <br /> A Division of San Joaquin County Health Care Services <br />