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Please note that Stockton Terminal remains within the 2220 SM HW Gen <5 tons/yr category. At <br /> the time of the inspection, two roll-offs(and later several drums)were on-site and being managed <br /> as"Hazardous Waste." This is the conservative approach that Shell Oil Products US has taken <br /> for all its waste-streams: to manage the material as a Hazardous Waste until it is determined <br /> otherwise. <br /> This approach is in keeping with RCRA's regulations in that a Listed Waste becomes hazardous <br /> at the moment it is determined to be Listed, while a Characteristic Waste becomes hazardous at <br /> the moment it exhibits the characteristic. For the drilling mud generated, if it was <br /> Characteristically Hazardous, it would have been Hazardous once removed from the <br /> ground. Hazardous Waste labels were applied and the Facility Response Plan (FRP)/HMBP <br /> Consolidated Contingency Plan were enacted. On 10/24/2014—analytical regarding the soil was <br /> obtained and demonstrated that the mud was neither RCRA Hazardous nor California NOW <br /> RCRA Hazardous. Shell has removed the Hazardous Waste labels on applicable bins and drums <br /> and replaced with"Non-Hazardous" labels. Lesser emergency response requirements are now <br /> enacted through the FRP and HMBP. <br /> As the waste was never a Hazardous Waste, the requirements of 40 CFR 265 and HSC 266265 <br /> do not apply and cannot be retroactively applied if there were deficiencies. The requirements of <br /> 40 CFR 262 and HSC 66262 do apply as Stockton Terminal is a Small Quantity Generator <br /> (SQG). <br /> At the CUPA's request, the HMBP Consolidated Contingency Plan has been revised to identify <br /> the Emergency Contacts as"Emergency Coordinators." The FRP does specify the <br /> responsibilities of the Emergency Contacts. These responsibilities are the same as those listed in <br /> 40 CFR 262. As the Federal requirements state that the individual who has these responsibilities <br /> is the Emergency Coordinator, the identification of those individuals meets the <br /> requirements. There is no requirement that state the exact words"Emergency Coordinator" be <br /> utilized. Only that an individual who has the responsibilities be identified. <br /> 605 — Corrected during inspection as noted in the inspection report. The two roll-off bins <br /> indicated were labeled correctly during the inspection as indicated in the inspection report. <br /> Sincerely, <br /> Siv� � *(/ (O� <br /> Miguel Torres, Terminal Manager <br /> 3515 Navy Drive <br /> Stockton, CA 95203 <br /> (209)466 6941 <br /> Enclosures: CERS pages updated, including the Consolidated Contingency Plan <br /> Return to Compliance Certification <br /> JVD <br /> OCT 2 9 2014 <br /> ENVIRONMrvNTAL HEALTH <br /> DEPARTMENT <br />