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-2 - vehicle is washed. Occasionally, the engine and under-the-hood parts are also washed. Only biodegradable detergents are used. b. Based on the DTSC August 19, 1993 guidance RG Document #11, revision 1 (attached), and our best engineering judgment, the car and engine wash water are not hazardous. Our reasons for claiming that the engine wash water is not hazardous are detailed below: Per your referenced guidance, the elements that cause the engine wash water to turn hazardous are the degreasing chemicals and the contaminants on the motor vehicle parts such as heavy metals from leaking motor oil. These elements are not present in our wash water because firstly, we do not use solvents or degreasing chemicals -just biodegradable detergents; and secondly, we clean the engines to sustain reliability - not improve reliability, and to conform with USPS preventive maintenance directives - not to facilitate maintenance. We wash dust and debris off the engines and not caked oil residues. Our preventive vehicle maintenance procedures and frequent engine inspections do not allow oil leaks to occur. Also, a majority of the vehicles and engines washed are in delivery service. Our delivery vehicles log an average of 2500 miles/year. Therefore, there is no potential for oil buildup on under-the-hood parts. Then if minor amounts occur, our at-a- minimum annual engine wash requirements minimize its presence in the wash water. In the unlikely event that a significant oil leak or buildup is observed, our parts degreasing facilities would be utilized and not the car wash. C. Work room floor mop water: The work room floor is mopped to render it safe and clean. In the process, engine fluids, vehicle wheel dust, and vehicle drip water (if raining) are picked up. This waste stream is not hazardous because a biodegradable detergent is used to mop the floors, the vehicle drip water is rain and residual road dust, and the amounts of engine fluids or vehicle wheel