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• Mr. Michael Kith December 29, 1997 Page 2 typographical error; the results for heptachlor and heptachlor epoxide are reversed. This observation is based on the fact that the reported concentration for heptachlor epoxide is below its method detection limit. Neither heptachlor nor heptachlor epoxide are used at the facility. The detection of trace levels of these compounds is attributed to local crop dusting). In December of 1997, the OWS influents from each of the facility's three platforms (McDonald Island, Turner Cut, and Whiskey Slough) were sampled and analyzed for Title 22 metals, pesticides and PCBs, benzene, toluene, ethylbenzene, xylene, flash point, reactivity, pH, 96 -hour LC 50 bioassay, and glycol. Samples were collected in accordance with DTSC's Permit by Rule Fact Sheet titled "Oil/Water Separators at Vehicle Repair Facilities" dated 6/29/92. No constituents were detected at or above hazardous waste regulatory thresholds and the samples passed the 96 -hour LC50 bioassay test. Copies of the analytical results are attached. Based on the analytical results from the February 1992 and December 1997 sampling events and our knowledge of the wastestream, we conclude that the OWS influent is non -hazardous and that a hazardous waste treatment permit is not required to operate the oil/water separators at McDonald Island. Also included with this letter, per your request, is a procedure for ensuring that hazardous substances are not discharged to the OWS. Issue #2 Failed to properly label containers of hazardous waste. Information on a used oil tank hazardous waste label had faded and was illegible. Response #2 This issue was corrected at the time of the inspection, as stated on the inspection form. Issue #3 Failed to determine if a waste (triethylene glycol) is a hazardous waste. (In our telephone conversation on 12/16/97, you indicated that this finding was