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Am ENVIRONEERING INC. <br />Process Engineering, Water Reuse, and Accident Prevention <br />July 22, 2008 <br />Mr. Ray Von Flue <br />Environmental Health Department <br />San Joaquin County <br />600 E. Main Street <br />Stockton, CA 95202-2708 <br />Dear Mr. Von Flue: <br />Re: California Tank Lines, Inc. <br />Tank and Secondary Containment Assessment <br />JULR E C LE � Y IPF DD <br />2 3 2008 <br />ENVIRONNIEN i HEALTH <br />PERNIIT/SERVICES <br />This is to request an exemption from the requirement to prepare a Tank and <br />Secondary Containment Assessment for the wastewater tanks at California Tank <br />Line's (CTL) S. Eldorado Street terminal. <br />As you know, CTL operates a wastewater pretreatment system to treat wastewater <br />from it's Truck/Trailer Wash Rack, under a CA (conditionally authorized) permit. <br />The tanks in question contain rinse and wash water from washing trailers in the <br />wash rack. These rinses and wash water will contain very minute quantities of <br />materials handled in the trailer before washing. The City of Stockton Municipal <br />Utilities Department (MUD) has provided a list of "approved materials" which <br />may be washed out at the wash rack. Thus the rinse and wash water will contain <br />only those materials approved by the City for processing in the Municipal <br />Wastewater Treatment Plant. Treatment by CTL in the pretreatment plant <br />includes removal of oil and grease, and solids removal (before the storage tanks), <br />and neutralization prior to disposal to the sewer. Please note that both <br />neutralization and phase separation are exempt treatment activities under some <br />conditions. In addition, it is highly likely that the wastewater in the wastewater <br />storage tanks would be classified non -hazardous by the criteria listed in Title 22, <br />para. 66696, most, if not all, of the time. <br />In any case, CTL has provided cross linked polyethylene storage tanks to store the <br />wastewater (unaffected by the wastewater), and concrete or cement block walls <br />for secondary containment. All tanks are anchored to the concrete slab. However, <br />CTL is currently designing changes to the treatment system to recycle a <br />significant quantity of water and to improve solids removal. These changes may <br />affect the tank and piping layout, which could affect the assessment, making it <br />impossible to stamp and sign at present. <br />P. O. Box 2498, Danville, CA 94526 • (925) 838-1763 Fax (925) 838-9621 <br />