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Backus, Garrett [EHD] From: Backus, Garrett [EHD] Sent: Monday, April 11, 2022 8:18 AM To: Joseph Jenkins Cc: Sarah F White;William_Geary@unifirst.com Subject: RE: Stockton wastewater and sludge data - Unifirst Stockton Hi Joseph, Thank you for the information provided, please let me know when the CERS business activities questions for hazardous waste generator and treatment are changed to "yes". Garrett Backus, Ld. Sr. REHS, CUPA programs San Joaquin County Environmental Health Department 1868 E Hazelton Ave, Stockton, CA 95205 Desk: (209)468-2986 Cell: (209)616-3030 Email: gbackus .s]gov.org Free CUPA training classes signup: https://www.slgov.org/department/envhealth/ From:Joseph Jenkins<JJenkins@eecenvironmental.com> Sent: Friday, April 8, 2022 2:42 PM To: Backus, Garrett [EHD] <gbackus@sjgov.org> Cc:Sarah F White<Sarah_White@unifirst.com>; William_Geary@unifirst.com Subject: RE: Stockton wastewater and sludge data - Unifirst Stockton 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. Garrett, We have reviewed the comments provided on the facility's January 16, 2022 CERS submittal and in the March 7, 2022 email and wanted to circle back with a response to those comments. We also reviewed the additional questions in your email from Monday morning, and we will provide answers to those questions in a separate response after we have gathered the necessary information. The comments made on our January 16, 2022 CERS submittal requested clarification on the selection of"no" for the hazardous waste generator and hazardous waste treatment business activity categories. The facility does periodically generate and ship hazardous waste, and it operates as a conditionally exempt commercial laundry, so it should have checked "yes" for both of these hazardous waste activity categories. We will be revising those entries in CERS now. The March 7, 2022 email states that the "site launders textiles soiled with used oil," and "therefore a hazardous waste treatment permit is required." As explained in published DTSC guidance,whether textiles soiled with used oil constitute hazardous waste depends on whether they contain free flowing used oil. More specifically, "if the [textiles] do not contain free flowing used oil they do not meet the definition of used oil and thus may not be hazardous waste if the generator has determined the rags do not exhibit a characteristic of a hazardous waste. In this instance,the rags are nonhazardous and thus not subject to Hazardous Waste Control Laws, including the exemption in section 25144.6 of Health and Safety Code." See https://dtsc.ca.gov/managing-textile-materials-soiled-with-hazardous-waste/. I