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Baker, Lydia [ EHD] From : Phillips, Edward P < Edward . Phillips@BNSF . com > Sent: Friday, December 11 , 2020 12 : 59 PM To: Baker, Lydia [ EHD] Cc : Brady, Derek; william . bevard@aecom .com; Watson, Evelyn B; Julia Kiberd Subject: RE : Inspection Report Attachments : CHSC 25250 . 19 (AB 2928) . pdf; CHSC 25250 . 1 . pdf CAUTION : This email is originated from outside of the organization . Do not click links or open attachments unless you recognize the sender and know the content is safe . Hi Lydia , We' re looking into the MDL issue and will get back to you on that . With regard to the log issue , with all due respect we do not believe that either section you cited below requires it from generators of highly controlled used oil . The CUPA Conference presentation you shared is incorrect; the authors reached out to me as the progenerator of the bill to get my input prior to them presenting and I told them that the log was not required of generators of HCUO for the reasons stated below, but for some reason they included it anyway . I believe it was included simply as an oversight on their part . When I attended their presentation , I made the point to the participants in the room that their statement that a log was required was incorrect . CHSC Section 25250 . 19 ( c ) applies to recyclers of used oil , generators who are claiming their used oil is exempt under 25250 . 1 ( b ) ( 1 ) and generators who recycle their own oil on -site . We are none of those; we accumulate our oil as generators of HCUO and send it to a facility for recycling as exempted under 25250 . 19 ( b ) ( 3 ), not 25250 . 1 ( b ) ( 1 ) . I specifically asked this of DTSC back in 2012 when we attempted to claim that our used oil was exempt under 25250 . 1 ( b ) ( 1 ) . DTSC told me back then that 25250 . 1 ( b ) ( 1 ) was only for generators who recycle their own oil , not for generators who send their oil off-site, and that we could not at that time claim our used oil was exempt because we didn 't actually recycle it . This is why, after being told we didn 't qualify for claiming the exemption under 25250 . 1 ( b ) ( 1 ) and after being turned down for a variance request, we pursued changing the law during the time period 2015 - 2018 . CHSC Section 25250 . 18 ( a ) applies to transporters, not generators . Since we don 't transport our oil , that code section does not apply to us either . I sincerely hope that this answers your questions regarding the issue of the log . Please feel free to contact me should you have any more questions or wish to discuss this further . Sincerely, Eddie From : Baker, Lydia [ EHD ] [ mailto : lbaker@sjgov . org] Sent : Friday, December 11, 2020 10 : 51 AM To : Phillips, Edward P < Edward . Phillips@BNSF . com > Cc : Brady, Derek < Derek . Brady@BNSF . com >; will iam . bevard@aecom . com ; Watson , Evelyn B < Evelyn . Watson@BNSF . com > Subject : RE : Inspection Report i