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In order to make sure that the textiles handled by Unifirst across the nation do not contain free flowing fluid that could <br /> include solvents and/or used oil, Unifirst has developed and implemented a company-wide policy and procedure as <br /> presented in the attached SOP. All Unifirst facilities are required to follow the SOP to make sure that textiles received <br /> from customers do not contain free flowing fluid (see Section 6.1) and that safety measures are followed for the <br /> protection of employees. As is the case with all Unifirst facilities,the Stockton facility does not pick up or transport <br /> soiled shop towels with free flowing liquids. Because the towels handled by the facility do not contain free flowing oil <br /> and do not exhibit any characteristic of hazardous waste they are therefore not a hazardous waste. <br /> The March 7, 2022 email also questioned whether the waste determination was complete for the sludge generated by <br /> the facility's laundering activities. In particular,the email indicated that"[s]ludge waste of this type should also be <br /> tested for acute aquatic toxicity per Title 22 California Code of Regulations section 66261.24(a)(6)to determine if it's a <br /> non-RCRA hazardous waste." While testing is one option for completing waste characterization,the facility has coupled <br /> the testing that it has performed along with its generator knowledge of the processes used and materials involved, as <br /> authorized pursuant to 66262.11(b)(2), to determine that the sludge is non-hazardous. <br /> We assume that this email provides the clarifications sought with respect to our January 16, 2022 CERS submittal. As <br /> noted above, we will be correcting the entries for the hazardous waste generator and treatment business activity <br /> categories. Please let us know if you have any questions once you have reviewed that updated submittal. We will be <br /> providing a separate response to the questions that you emailed Monday morning as soon as possible. <br /> Thank you, <br /> Joseph Jenkins <br /> Project Regulatory Specialist <br /> EEC Environmental <br /> One City Boulevard West I Suite 1800 1 Orange, CA 92868 <br /> O(714)667-2300 1 C (562)447-4109 <br /> lienkins()eecenvironmental.com I www.eecenvironmental.com <br /> From: Backus, Garrett [EHD] <gbackus@slgov.org> <br /> Sent: Monday, April 4, 2022 9:05 AM <br /> To:Joseph Jenkins<JJenkins@eecenvironmental.com> <br /> Cc: Sarah F White<Sarah White@unifirst.com>; William Geary@unifirst.com <br /> Subject: RE: Stockton wastewater and sludge data - Unifirst Stockton <br /> Hi Joseph, <br /> I just saw your voicemail from March 24 regarding Alpine meats oily terry cloth wipers. You stated that the oily wipes <br /> from Alpine are taken to Mexico for processing. Please explain how that works: <br /> 1. Are the wipes laundered and returned to the facility or are they disposed of? <br /> 2. What type of shipping papers are used to haul the soiled wipes to Mexico? Can you provide a few of the recent <br /> shipping papers? <br /> 3. How does the site segregate out the soiled wipes being hauled to Mexico vs ones being processed in <br /> Stockton? The invoices show the wipes going to the Hunter St address in Stockton. <br /> Please see the attached invoice from another facility, Stockton Auto Dismantlers,for soiled oily wipers being hauled to <br /> Hunter St in Stockton for laundering. How are wipers from this client handled? <br /> Has the sludge waste been tested for acute aquatic toxicity? <br /> Thank you, <br /> 2 <br />