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�--. ARCO Products Comi " <br /> 1055 West Seventli-oireel �f <br /> Post Office Box 2570 " <br /> Los Angeles,3 486 065 90051.0570 ENVIRONMENTAL HEALTH <br /> Telephone 213 466 0652 PFRMIT SFRVICE <br /> B. W. Spencer <br /> Manager 94 DEC 19 PM 1: 50 <br /> Environmental, Health & Safety <br /> December 14, 1994 VIA CERTIFIED MAIL <br /> P 681 110 036 <br /> Mr. Mike Horner <br /> Department of Toxic Substances Control <br /> Onsite Hazardous Waste Treatment Unit <br /> 400 P Street, 4th Floor <br /> Sacramento, CA 95812-0806 <br /> Subj: Request to Cease to Operate Under Permit by Rule at Three ARCO <br /> Products Company Facilities: <br /> Stockton Terminal 2700 West Washington Street <br /> CAD 000 633 032 Stockton, CA 95203 <br /> Vinvale Terminal 8601 S. Garfield Avenue <br /> CAD 081782 583 South Gate, CA 90280 <br /> Sacramento Terminal 1701 South River Road <br /> CAD 062 949 938 West Sacramento, CA 95691 <br /> Dear Mr. Horner: <br /> ARCO Products Company (APC) is writing this letter to inform the DTSC that effective <br /> December 31, 1994, we will cease to operate the onsite wastewater treatment systems <br /> located at the facilities listed above under the Permit by Rule (PBR) tiered permitting <br /> program. Treatment of oily wastewater will continue to take place after this date, but the <br /> activity is clearly exempt from hazardous waste requirements altogether under a new <br /> statute and therefore exempt from Permit by Rule. This letter provides an explanation <br /> for this exemption and describes why the facilities originally filed for PBR in March, <br /> 1993. <br /> The three subject ARCO facilities filed DTSC Form 1772 under the Permit by Rule <br /> (PBR) tier in 1993 for the onsite treatment of non-RCRA oily wastewater. ARCO does <br /> not believe PBR was required. At one point, however, DTSC suggested that the <br /> exclusion under H&SC Section 25143.2(d)(2)(C) for oily waste and the conditional <br /> exemption under Section 25201.5(c)(8) for "oiVwater mixtures" did not include gasoline- <br /> bearing waters. <br /> 1 <br /> AMco PmWns comean,is a Division o,AdanYcpienooldConw^V <br />