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A V. SIEBAL R J. HART IRI R R F:.E CODING CLERICAL INITIALS <br /> E i i DATE MAILED <br /> II � I <br /> U X255-3569 iEi255-3615 IV1 IVI iV1 I I I I R. MASTERS <br /> T / Y <br /> I"� J„/ !I� �eI SII IEI <br /> !RI �y�I�i WW1 � t(L ! IVi lyl i i i I <br /> December 23 , 1992 <br /> John R. Keil, Manager_ <br /> Environmental Affairs Ia <br /> Libby-Owens-Ford Co. <br /> Post Office Box 799 JAN 13 1993 <br /> Toledo, Ohio 43695-0799 <br /> 6N41RONitiU-rtiTAl: NFRkTt <br /> LIBBEY-OWENS-FORD (LOF) CO. PERMff' ' <br /> LATHROP CHROMATE WATER TREATMENT PROJECT <br /> Dear Mr. Keil: <br /> I want to commend your timeliness in recognizing that <br /> California's new law, AB 1772 , Tiered Permitting, might have had <br /> an impact on your plans to treat waste water prior to disposal. <br /> In our discussions, you stated plans to treat about 550, 000 <br /> gallons of waste water containing 350 mg/liter of sodium <br /> dichromate, one time only, and disposal of this water to <br /> Manteca's publically owned treatment works (POTW) . Any resulting <br /> hazardous sludges would be properly disposed of at a permitted <br /> Class 1 facility. Your description of the treatment process is <br /> described in Appendix A and B of this letter and was contained in <br /> your letter dated November 18 , 1992 . <br /> The key questions and responses are the following: <br /> Question 1 - Is a permit or variance necessary for storage of the <br /> waste water prior to treatment and disposal? <br /> Answer: No Federal or State permit is needed unless storage of <br /> the waste water exceeds 90 days, from the date it is determined <br /> by the generator that the water is a waste. Your option, if the <br /> 90 day period will be exceeded, is to apply for a Federal EPA <br /> variance or a permit as you deem appropriate. <br /> No federal permit would be needed under RCRA for the treatment of <br /> the waste water, and State permit requirements for treatment are <br /> contained in the answer to question 2 . <br /> Question 2 - Since this is a one time only treatment, would IAF <br /> need to apply under Tiered Permitting or could a permitted <br /> transportable treatment unit (TTU) exclude the necessity of IAF <br /> applying under Tiered Permitting? <br /> Answer: You indicated a preference to have a permitted TTU treat <br /> this one time only wastestream, and under the scenario provided <br /> in your November 18, 1992 , letter, you would not have to apply <br /> under Tiered Permitting. <br />