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C <br /> D M <br /> S Chemical Data Management Systems <br /> May 8, 2009 <br /> Dennis Bour <br /> Thule Towing Systems G°3C�(���1(�� <br /> 1313 S. Stockton Street I�C�C v E <br /> Lodi, CA 95240 <br /> MAY 1 5 2009 <br /> Dear Dennis: ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> This letter is to address the status of whether or not Thule is required to apply for a Tiered Permit <br /> for the cleaning treatment process. <br /> The California Health and Safety Code (Health & Saf. Code), chapter 6.5 and California Code of <br /> Regulations, title 22, chapter 45, section 67450 et seq. (Cal. Code Regs., tit. 22, ch. 45, §67450) <br /> does require business to apply for a Tiered Permit when treating hazardous waste. The waste <br /> streams that Thule is treating are generated at tanks: Stage 2 #1,2; Stage 4 #1,2; Stage 5, #1, 2; and <br /> Stage 7, #1, 2. To determine the hazardous nature of each of these tanks samples were obtained <br /> from each tank and analyzed for metal and pH. The results for the testing confirmed that the <br /> solution in the rinse tanks are not hazardous and Thule is not treating hazardous waste. Therefore, <br /> there is no requirement to obtain a Tiered Permit for treatment process. <br /> I have attached a summary of the test results and the test results for your files. Please call me if you <br /> have any questions on this issue. <br /> Regards, <br /> James N. Carro <br /> Attachments: Summary Waste Test Results <br /> TestAmerica Test Results. <br /> Specializing in Environmental and Safety Compliance <br /> 6515 Trinity Court, Suite 201 s% Dublin, CA 94568 ri (925) 551.7300 4- FAX (925) 829.3886 <br /> 2501 Cherry Avenue, Suite 170 4• Signal Hill, CA 90755 ee (562) 988.0800 + FAX (562) 988.0848 <br /> http://www.cdms.com info®cdms.com <br />