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Our gasometers are large bellows that travel up and down within a metal sleeve. Between the metal sleeve and the bellows is a layer of oil. We have an external barrel attached to the sleeve that ensure the oil level doesn't leak over the sides of the sleeve. Around the gasometer is a large concrete containment to prevent the spread of any incidental spill of oil from the gasometer. When the gasometer is not in use, we have metal shields that go over the containment to minimize the amount of storm water that would collect there. When we are operating and the shields are off, we can collect storm water. We monitor the storm water level and then pump the containment dry into drums (as you saw). The drums are labeled and placed in our designated hazardous waste area. As you could see from our previous manifests, we would have all of this oily water(water with a slight oil sheen) would all be hauled off by a licensed hazwaste handler. After attending my recent HazWaste Management class, the instructor and class consensus was to use absorbents to greatly reduce the amount of water being removed from our site. Since the source of this was storm water and not a process,this was presented as a best course of action for us. We have just started this month) with the process you saw. First,we take a barrel, and visually verify that it is oily water (clear oily sheen/layer with water underneath, similar to what you observed on site).They then pump the oily water into the PIG absorbent filter(https://www.newpig.com/pig-pour-through-oily-water- filter/p/FLT521?searchTerm=pig+oil+filter).Then the filtered storm water goes into a new (not previously used hazardous waste container) container where we test the water with these oil test strips (https://www.newpig.com/oil- detection-test-paper/p/GEN180)to ensure that there is no trace of oil left. We document this on the form (attached)to track what we are doing with the storm water. After the storm water is tested and clear of oil, we pump the water into our retention basin where all of our site storm water goes.As mentioned during your visit, we have perimeter berms and all of our storm drains feed into the retention basin. That is our process as of now. If you have any questions, please feel free to ask. Thanks again for your time and info today.Take care! Bill Johnson Vice President of Administration Valimet, Inc. 431 Sperry Road Stockton, Ca 95206 Office: (209) 444-1600 Direct: (209) 444-1617 Web: www.valimet.com V A L CONFIDENTIALITY NOTE: The information contained in this e-mail message and any attachments are legally privileged and confidential information intended only for the use of the individuals or entities named in the distribution area of this message. If the reader of the message is not the intended recipient,you are hereby notified that any dissemination,distribution or printing of this message is prohibited. If you have received this e-mail in error, please notify Valimet, Inc. immediately by returning the message to the sender. DISCLAIMER: This e-mail may contain information which is controlled as"Technical Data"under ITAR(22 CFR 120.10)and/or the EAR(Sec.734.2)and may not be forwarded or disclosed to any Foreign Person,as defined at 22 CFR 120.16,without the prior written consent of Valimet, Inc.and the United States Department of State or the United States Department of Commerce. 4