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RECOVED <br /> SEP 0 8 2004 <br /> ENVIRONMENT HEALTH <br /> sof"thleen® pERMITISERVICES <br /> September 2,2004 <br /> San Joaquin County <br /> Environmental Health Department <br /> Attention: Michelle Le, Senior REHS <br /> 304 E.Weber Ave <br /> Third Floor <br /> Stockton CA 95202 <br /> Dear Ms Le: <br /> I am in receipt of your E-mail dated August 26, 2004 pertaining to Oil Water Separator waste collected <br /> by Safety-Kleen from Cherokee Freight lines. To expedite your review of Safety-Kleen responses to <br /> your questions, both your questions and Safety-Kleen responses are detailed below: <br /> 1. SJCEHD Question: <br /> When was the determination made to change the oil/water separator waste disposal method for the <br /> above referenced sites from the California Hazardous Waste Uniform Manifest system to the non- <br /> hazardous record system? <br /> Response: <br /> Before I respond to the specifics of this request it is important for you to understand that it is and has <br /> been an industry wide practice of collecting automotive Oil Water Separator Waste as a non-hazardous <br /> material in California. Companies involved in providing automotive Oil Water Separator Waste Services <br /> typically transport this material with the use of a Bill of Lading as opposed to the California Hazardous <br /> Waste Uniform Manifest System. Historically, Safety-Kleen has taken a very conservative position in <br /> the characterization of this material in California and has classified the material as a non-RCRA, <br /> California Hazardous Waste that was transported on a California Hazardous Waste Manifest. <br /> Over the past two years Safety-Kleen has had numerous requests from it's automotive customers to <br /> reclassify their separator waste as non—hazardous. In response to this request in J anuary of 2004 <br /> Safety-Kleen randomly selected and performed analytical testing of 31 automotive customers that used <br /> Safety-Kleen's Oil Water Separator Waste collection program. A statistical evaluation of the testing <br /> results was performed which compared this data to the STLC and TTLC metals regulatory limits. Of the <br /> total population of 31 samples tested only one sample contained one element (copper) that slightly <br /> exceeded the STLC regulatory limit. Based on these analytical results (that statistically demonstrated <br /> the material to be non-hazardous) SafetyXleen characterized the Oil Water Separator Waste from <br /> automotive customers as non-hazardous. Accordingly, in late January Safety-Kleen the Oil Water <br /> Separator Waste for automotive customers was changed to a classification to non-hazardous. <br /> It is important to note that Safety-Kleen makes a distinction between automotive and non-automotive <br /> customers. Automotive customers are those business that service the automotive industry and include <br /> auto and truck repair services. Conversely a non-automotive customer would include businesses <br /> involved in manufacturing. Safety-Kleen has provided Oil Water Separator Services to thousands of <br /> automotive and non-automotive businesses throughout the country. Over the years and through the <br /> evaluation of thousands of analytical results it has been proven that the chemistry from automotive <br /> customers who use the same or similar products will produce a consistent waste stream. Safety-Kleen <br /> requires additional information and analysis from non-automotive customers who may use chemistry <br /> that is not consistent with the materials used in the automotive industry. <br /> SAFETY•KLEEN CORP. <br /> 6000 88th STREET SACRAMENTO, CA 95828 916/386.4999 <br />