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r <br />Mr. Eric Trevena <br />San Joaquin County Public <br />Health Services <br />December 29, 1993 <br />Item #1: The drums stored in the center drum room are stored pursuant to the <br />criteria set forth in 22 CCR Section 66262.34(e) and the time/volume <br />limits thereunder have not expired. This provision, commonly <br />referred to as the "satellite storage" rule, allows the accumulation of <br />up to 55 gallons per waste stream for up to one year as long as <br />certain conditions are met: <br />- The waste stream is stored at or near the point of generation <br />[Section 66262.34(e) (1)] <br />- The waste is stored in containers other than tanks <br />[Section 66262.34(3) (1) (a)] <br />- The generator does not hold the waste on site for more than <br />one year [Section 66262.34(e) (1) (b) <br />- The date of accumulation is clearly marked <br />[Section 6626234(e) (1) (c)] <br />Since the waste is stored near the point of generation, and the other criteria are <br />clearly met, the satellite rule applies to the storage of these drums and the 90 day limit <br />is not applicable until such time as the 55 gallon limit is reached or the expiration of one <br />year from the initial accumulation start date. Application of this rule is important to <br />facilitate reasonably sized shipments of hazardous wastes from this facility. <br />Item #2: The accumulation start date has been added to this drum. <br />Item #3: A hazardous waste label has been attached to this drum of waste oil. <br />For your information, this oil drum is also a satellite storage area, <br />and the drum stored in this area immediately prior to the current <br />drum was disposed on October 18, 1993. <br />K <br />