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Page 1 of 1 16 From: Sangeeta Lewis [lewisengineering@sbcglobal.net] Sent: Wednesday, July 07, 2010 4:40 PM To: Muniappa Naidu [EH] Cc: 'Ramirez, Ruben'; 'Basso, Kevin'; 'Litchfield, Don' Subject: RE: used oil Hi Muniappa, This is what I sent last Friday afternoon. Regards, Sangeeta From: Sangeeta Lewis [mailto:lewisengineering@sbcglobal.net] Sent: Friday, July 02, 2010 3:03 PM To: 'mnaidu@sjcehd.com' Cc: 'Ramirez, Ruben' Subject: used oil Hi Muni, I put a call in to DTSC reg assistance number and left a message. Unfortunately, it might be a furlough day so I may not get a call back until after the long weekend. In any case, I read through the regs and I see the sections where it discusses that the used oil can be recycled onsite to meet the requirements for not being managed as a haz waste, however, I think there is a clause that also allows the used oil not to be managed as a haz waste if it meets the standards listed in Health and Safety Code Section 25250.1(a)(3)(B). I got to that point as follows: Section 25143.2 (b)(1) or (2) states that recyclable material that is managed in accordance with Section 25143.9 (Forward meets this mgmt requirement) and is or will be recycled by use or reuse as an ingredient in an industrial process or use or reuse as a substitute for a commercial product shall be excluded from classification as a waste, except as otherwise provided in subdivisions (e), (f), and (g). Section 25143.2(e) lists several recyclable materials that are considered hazardous waste including Item (7) which is used oil. As far as the other exceptions under Section 25143.2, item (f) requires anyone requesting a recycling exclusion to provide info on the operator and maintain records. Item (g) is essentially an exception for RCRA haz waste and extremely haz waste. So, even though Section 25143.2(e)(7) says used oil is considered haz waste, section 25143.2(e)(7)(A) allows a few exceptions for used oil being considered haz waste including Section 25250.1(b). Section 25250.1(b) lists two conditions that allow the used oil not to be considered haz waste and either condition (1) or (2) can be met. Section 25250.1(b)(1) has several subsections of additional requirements which Forward should be able to meet for the used oil to not be considered haz waste. One of the additional requirements, Section 25250.1(b)(1)(A), requires the used oil to meet the purity standards in Section 25250.1 (a)(3)(B). I don't have the test data for the Forward used oil but I can get it. My guess is that if the used oil is accepted by the used oil recycler and transporter then it likely meets the standards of Section 25250.1(a)(3)(B). Can you please take a look at these sections of the regs and see if Forward can qualify for a recycling exemption for the used oil? Have a great Fourth of July weekend! Thanks for your help, Sangeeta 7/14/2010