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LEC-31-1990 11:33 FROM IE OIL SEATTLE, WR TO 1209464013E F.02 <br /> v .1 <br /> . =!'ONE 285•Ya00 <br /> CABLE ADDRESS: TIMOIL <br /> -AXI <br /> SEATTLE 'E 208-287.8038 <br /> TACOMA V <br /> IORTLAND <br /> STOCREN 0KTON '2 'O <br /> LOS ANGD , 2 ° TIME O I L C O <br /> LOS ANGELES 9�' "e • <br /> 8 4 <br /> V° 2737 WEST COMMODORE WAY SEATTLE, WA 98199-1233 <br /> nA00uCT: i�M P.O. BOX 24447 SEATTLE, WA 98124.0447 <br /> fiuE TEB�F° F <br /> December 31, 1990 <br /> Ms. Kasey Foley <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> PO Box 2009 <br /> Stockton, CA 95201 <br /> RE: Environmental Health Permit for 3015 Navy Drive, Stockton, CA <br /> Dear Ms. Foley: <br /> As we discussed on the telephone on December 28, 1990, it appears that we have <br /> differing opinions regarding the classification of waste water at the subject <br /> terminal. On November 27, 1990 I returned the County's Environmental Health <br /> Permit billing statement with the explanation that we had generated less than <br /> 5 tons of hazardous waste in 1990 so no fee was due. I understand from our <br /> conversation that you have inspected our terminal and have prepared an <br /> inspection report. I further understand that you have calculated that our <br /> terminal generated 73 tons of hazardous waste based on the assumption that the <br /> water in our oil/water separator and groundwater cleanup holding tank (Tank <br /> 609) is a hazardous waste. <br /> It has been our interpretation that since the water is being discharged to a <br /> publically-owned treatment works (POTW) , it is not a "solid waste" under the <br /> Recource Conservation and Recovery Act and is, therefore, categorically exempt <br /> from designation as a "hazardous waste" (40 GFR 261.4(a) (1) (ii) ) . We have a <br /> permit from the City of Stockton for this discharge and have installed pre- <br /> treatment equipment to meet their discharge standards. <br /> To resolve this issue, I would like the opportunity to review your inspection <br /> report. It would also be helpful if you could explain to me, in writing, the <br /> basis for your determination that the water in question is a hazardous waste. <br /> Sincerely, <br /> Fred Proby <br /> Environmental specialist <br /> FLP\deo <br /> TOTAL F.02 <br />