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Y <br /> November 2, 2010 <br /> Mr. Garrett Backus <br /> Sr. REHS, CUPA Program <br /> San Joaquin County, Environmental Health Department <br /> 600 East Main Street <br /> Stockton, CA. 95202-0138 <br /> Subject: Three Stage Oil Water Separator <br /> Stockton unified School District <br /> 1932 El Pinal Drive, Stockton, California <br /> Dear Mr. Backus: <br /> This letter is in response to the `Notice to Abate Immediately' (correspondence) from San <br /> Joaquin County, Environmental Health Department (EHD) dated October 13, 2010 that <br /> describes a three compartment sump with a sealed drain used to store liquid oily waste <br /> until removed for disposal by a hazardous waste hauler. Furthermore, the letter states that <br /> the collection sump is considered by the EHD to be an underground storage tank (UST) <br /> as defined by California Health& Safety Code H&S Code 25281(y)(1). <br /> The October 13, 2010 EHD correspondence describes the finding as a violation of the <br /> H&S Code 25284(a)(1) and the corrective action as immediately stop storing oily waste <br /> in the unpermitted UST, and remove the oily waste and dispose of as specified in Title 22 <br /> California Code of Regulations. A copy of October 13, 2010 EHD correspondence is <br /> enclosed as reference. <br /> The three compartment sump referred to by EHD does not have a sealed drain and is not <br /> used to store liquid oily waste. The `collection sump' considered by EHD as an UST is <br /> actually a functioning three-stage oil water separator that discharges water to the sewer <br /> system. The sludge is removed from the three-stage oil water separator periodically and <br /> disposed of as a liquid (oil water sludge) Non RCRA Hazardous Waste Code #223. The <br /> oil water sludge removed from the oil water separator is not regulated as a hazardous <br /> waste by U.S. DOT, U.S. EPA or by the State of California. Approximately 400-500 <br /> gallons (50% oily water & 50% sludge) is removed approximately once a year by a <br /> hazardous waste hauler and transported to the disposal site under the Bill of <br /> Laden/Manifest system. <br /> The contents of the three-stage oil water separator were most recently removed on <br /> October 10, 2010, and a copy of the Bill of Laden/Manifest is enclosed as reference. The <br /> operation of the three-stage oil water separator was functionally tested on October 20, <br /> 2010. The testing was performed by a Stockton Unified School District plumber <br />