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if T.Iff1 <br /> r 25� <br /> From: Walker, Ruthanne M. <RMWalker@marathonpetroleum.com> <br /> Sent:Tuesday,January 2, 2024 3:58 PM <br /> To:Jose Hernandez<iernandez@americanintegrated.com> <br /> Cc: leu Lamyuen JR<ilamyuenir@americanintegrated.com>; Kevin Murphy<kmurphy@americanintegrated.com> <br /> Subject: FW: Non-haz Oily Debris Profiles for L&S Terminals <br /> Happy New Year,Jose! <br /> I am interested in getting updated sampling of petroleum contaminated absorbent/rags/debris to prove that it is non- <br /> hazardous and not non-RCRA. Attached is 2017 data from Vinvale that proved that and Benzene was non detect and <br /> non-detect TCLP benzene results. As additional rationale for likely classifying this wastestream as non-haz at the 6 CA <br /> refined product terminals I support, there is a petroleum debris exclusion in CA the California Health &Safety Code <br /> attached that states that if the solid material passes BZ TCLP (which it should) and has no free liquids,then it is non-haz <br /> but should still be shipped to a Class II or I landfill. So,the cost may not be affected but the taxes are as well as large vs <br /> small quantity generator status. Anyway, it's something I'd like to discuss and pursue more sampling data. <br /> Is there a reason that in the last couple years the debris/rag/absorbent profiles at my six sites have been getting shipped <br /> non-RCRA? I don't know the basis for the change other than perhaps E. Hynes/T2 classifies them that way (likely due to <br /> them having a wider variety of maintenance activities and crude oil, intermediate petroleum streams)? Or was it <br /> perhaps Crosby&Overton wouldn't agree to profile that way? <br /> If possible, I'd like to obtain updated sampling results of the absorbents/debris at the triwall box at Vinvale,the routine <br /> drum at Stockton, and at Carson Products (when it starts up soon as solely a jet fuel facility). Also, if you happen to be at <br /> Wilmington, Colton, and San Diego, then go ahead and grab a sample of the debris when there in upcoming months. <br /> Thank you! <br /> Ruthanne <br /> From: Walker, Ruthanne M. <br /> Sent:Wednesday,April 12, 2023 12:42 PM <br /> To: leu Lamyuen JR<ilamyuenir@americanintegrated.com>; Kevin Murphy(kmurphy@americanintegrated.com) <br /> <kmurphy@americanintegrated.com> <br /> Subject: Non-haz Oily Debris Profiles for L&S Terminals <br /> Hello....I wanted to resurrect a discussion we started earlier in the year. I've noticed that the routine terminal generated <br /> petroleum debris/absorbents/rags have been profiled as non-RCRA hazardous waste rather than non-haz as in the <br /> past. I recognize that tank project absorbents/debris are often heavily soiled/saturated and need to go as non-RCRA, <br /> but I'd like for you to look back at analytical you have specifically from my sites that indicates that it is non-RCRA. Also, <br /> did we ever resample the routine oily debris up at Stockton to confirm it is non-RCRA? Attached is some historical lab <br /> data that I have plus a unique petroleum debris exclusion that CA regulations have, assuming it has no free liquids and <br /> therefore not ignitable....which I would consider to mean as long as it isn't dripping/saturated and wet on bottom of <br /> drum/container. <br /> Let's rethink whether the red/yellow labels and profiles that have been going out lately are appropriate. If you have <br /> newer analytical, I'd appreciate receiving copies. Thanks so much and look forward to the lunch tomorrow at La <br /> Palma. Been a long time since we've gotten together. <br /> 3 <br />