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ARCO Products Company <br /> 1055 West Seventh Street <br /> Post Office Box 2570 <br /> Los Angeles, California 90051-0570 1 " <br /> Telephone 213 486 0652 <br /> B. W. Spencer <br /> Manager <br /> Environmental, Health & Safety <br /> March 31 , 1994 VIA CERTIFIED MAIL <br /> San Joaquin County <br /> Environmental Health Division <br /> 445 N. San Joaquin Avenue <br /> P.O. Box 2009 <br /> Stockton, CA 95201 <br /> Subject: 1994 Permit by Rule Annual Renewals <br /> ARCO Products Company, Stockton Terminal <br /> Enclosed are the 1994 Permit by Rule renewal forms for ARCO Products <br /> Company Stockton Terminal (CAD 000 633 032). <br /> There have been no changes to treatment activities at the site since the initial <br /> notification made a year ago and therefore the data printed on the renewal forms <br /> is still correct. Two copies of the renewal forms have also been sent to the <br /> Department of Toxic Substances Control, Onsite Hazardous Waste Treatment <br /> Unit. <br /> ARCO reserves the right to withdraw from the Permit by Rule Tier and AB 1772 <br /> Tiered Permitting altogether at any time during the year because we are <br /> currently examining if the separation of oily waters at the subject facilities does <br /> not involve any waste, qualifies as Excluded Recyclable Material per CA H&SC <br /> 25143.2(e)(3), or is Conditionally Exempt from AB 1772 Tiered Permitting per <br /> CA H&SC 25201 .5. We do not agree with the DTSC's current interpretation that <br /> gasoline, diesel, and other hydrocarbon fuels mixed with water are "aqueous <br /> wastes with organics" (and therefore subject to the Permit by Rule tier) rather <br /> than "oil" mixed with water. For tiered permitting purposes, we would ask that <br /> the agency consider utilizing the definition contained in the Government Code, <br /> Section 8670.3Q) which defines oil as "any kind of petroleum, liquid <br /> hydrocarbons, or petroleum products of any fraction or residues therefrom, <br /> including, but not limited to, crude oil, bunker fuel, gasoline, diesel fuel, aviation <br /> fuel, oil sludge, oil refuse, oil mixed with waste, and liquid distillates from <br /> unprocessed natural gas". <br /> ARCO Pmtlucls Company is s Olvlslon of AIIan1laRlcARelUCompany <br />