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Backus, Garrett [EHD] <br /> From: Backus, Garrett [EHD] <br /> Sent: Monday, June 22, 2020 9:28 AM <br /> To: Pete Earnest <br /> Cc: Brent Shonka; Rogerio Noce; Ricky Carlson; Carey Macconnell; Luke Allen <br /> Subject: RE: SATCO HW& HM Inspection June 16, 2020 Follow-up <br /> Attachments: Onsite-Tiered-Perm itting-Flowchart_10-30-2017.pdf <br /> Hi Pete, <br /> You'll need to determine the pH of the wash-down water that you generate based on your routine operations. Twice a <br /> day measurements seems like an adequate way of determining pH for the normal routine waste stream. <br /> If you find pH above 2.0 then no hazardous waste treatment permit is required by my department. <br /> If you find pH 2.0 or less than a treatment permit is required with my department. I've attached a flow chart used to <br /> determine which treatment permit is required. Inorganic acid wastes which are pH adjusted are on pg 14 as pathway <br /> 8a. The permit is Conditionally Exempt (CE), Conditionally Authorized (CA) or Permit by Rule (PBR) depending on the <br /> acid concentration and volume. Reporting is done on the California Environmental Reporting System (CERS). You can go <br /> here and search "treatment" to find fact sheets on treatment: https://dtsc.ca.gov/publications-index/managing-waste- <br /> publications/ <br /> Non-routine spills of sulfuric acid into the rail/truck sumps at the loading stations that are neutralized by your waste <br /> water treatment system do not require a treatment permit with my department if they are handled and neutralized <br /> immediately. This immediate response exception for emergency response is found in Title 22 California Code of <br /> Regulations section 66265.1(e)(11). <br /> We can get together for a conference call this week if you'd like to discuss the spill reporting requirements. We have <br /> 8:30 am Pacific time available tomorrow,June 23. <br /> Thank you, <br /> Garrett Backus, Ld. Sr. RENS, CUPA programs <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> (209)468-2986 gbackus(@sigov.org <br /> https://www.sogov.org/department/envhealth/ <br /> sin JOAQUIM <br /> From: Pete Earnest<pearnest@satcoinc.net> <br /> Sent:Thursday,June 18, 2020 4:46 PM <br /> To: Backus, Garrett<gbackus@sjgov.org> <br /> Cc: Brent Shonka <bshonka@satcoinc.net>; Rogerio Noce<rnoce@satcoinc.net>; Ricky Carlson <br /> <RickyLCarlson@gmail.com>; Carey Macconnell <cmacconn@voyagerlt.com>; Luke Allen <lallen@satcoinc.net> <br /> Subject: SATCO HW& HM Inspection June 16, 2020 Follow-up <br /> 1 <br />