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c <br /> D M <br /> S Chemical Data Management Systems <br /> May 8, 2009 <br /> Dennis Bour <br /> Thule Towing Systems <br /> 1313 S. Stockton Street <br /> Lodi, CA 95240 <br /> Dear Dennis: <br /> This letter is to address the status of whether or not Thule is required to apply for a Tiered Permit <br /> for the cleaning treatment process. <br /> The California Health and Safety Code (Health & Saf. Code), chapter 6.5 and California Code of <br /> Regulations, title 22, chapter 45, section 67450 et seq. (Cal. Code Regs., tit. 22, ch. 45, §67450) <br /> does require business to apply for a Tiered Permit when treating hazardous waste. The waste <br /> streams that Thule is treating are generated at tanks: Stage 2 #1,2; Stage 4#1,2; Stage 5, #1, 2; and <br /> Stage 7, #1, 2. To determine the hazardous nature of each of these tanks samples were obtained <br /> from each tank and analyzed for metal and pH. The results for the testing confirmed that the <br /> solution in the rinse tanks are not hazardous and Thule is not treating hazardous waste. Therefore, <br /> there is no requirement to obtain a Tiered Permit for treatment process. <br /> I have attached a summary of the test results and the test results for your files. Please call me if you <br /> have any questions on this issue. <br /> Regards, <br /> James N. Carro <br /> Attachments: Summary Waste Test Results <br /> TestAmerica Test Results. <br /> Specializing in Environmental and Safety Compliance <br /> 6515 Trinity Court,Suite 201 O Dublin, CA 94568 O (925) 551.7300 O FAX (925) 829-3886 <br /> 2501 Cherry Avenue,Suite 170 O Signal Hill,CA 90755 O (562) 988-0800 O FAX (562)988.0848 <br /> http://w .cdms.com info@cdms.com <br />