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Alaniz, John <br /> From: Alaniz, John <br /> Sent: Friday, May 15, 2020 4:01 PM <br /> To: 'Jim Berg' <br /> Cc: Kevin Poirier; Stan Shaw; 'Benjamin Mika' <br /> Subject: RE: Delta Truck Center HSC 25201 Violation <br /> Jim, <br /> I have reviewed the documents you have emailed me. I view your system as two parts. In the first part, used oil is <br /> skimmed off the top of the water. The used oil is then collected in a drum and properly disposed of. In the second part, <br /> the left over wastewater is boiled in a "burner" and the generated sludge is hauled off site as a hazardous waste. <br /> In reviewing the regulations, it does not look like 10a, b or c apply since the oil skimming process is prior to the regulated <br /> treatment part that I have concern with. Skimming the oil off of the water is an allowable treatment without a permit. <br /> The California Health and Safety Code (HSC) 2520.14 (a)(1) states that one of the conditions is: "...the used oil is properly <br /> transported to an authorized oil recycler." The water is not being heated to recover an oil fraction for recycling. As a <br /> result,this regulation would not apply to the second part of the treatment. <br /> Thank You, <br /> John Alaniz <br /> REHS <br /> San Joaquin County <br /> Environmental Health Department <br /> 1868 E Hazelton Avenue <br /> Stockton, California 95205 <br /> Phone: (209)468-3147 <br /> Fax: (209) 468-3433 <br /> Please note, my email address has changed to jalanizl@sjgov.org. <br /> From:Jim Berg [mailto:JBerg@deltatruck.com] <br /> Sent: Friday, May 15, 2020 11:50 AM <br /> To:Alaniz,John <jalanizl@sjgov.org> <br /> Cc: Kevin Poirier<kpoirier@deltatruck.com>; Stan Shaw<SShaw@deltatruck.com>; 'Benjamin Mika' <br /> <bmika@kpaonline.com> <br /> Subject: Delta Truck Center HSC 25201 Violation <br /> John, <br /> Regarding the HSC 25201 violation in relation to the flow chart you provided we believe that (10c) is a more <br /> accurate description of the treatment of our steam bay waste water using a Fixed Treatment Unit as outlined in HSC <br /> 25201.14. additional information was gathered from the fact sheet provided by the Department of Toxic Substances <br /> control as it relates to (FTU's) operating under(CEL), please review and advise if this classification would pertain to our <br /> facility, additionally we have sent our samples out to be tested for all of the items you requested to a ELAP certified lab <br /> 1 <br />