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COMBINED ENVIRONMENTAL AUDIT PACKAGE FOR USED OIL PROCESSING FACILITIES AT:
17300 HWY 72
ARVADA, CO 80007
20 LUCERO ROAD
BELEN, NM 87002
209 S. 57TH AVE
PHOENIX, AZ 85043
Page 92 - Supervisor Halogen Test Procedure

SUPERVISOR HALOGEN TEST PROCEDURE
Mesa Oil employees understand that it is our policy to treat all used oil as hazardous until we can prove that it is not. We believe this to be the EPA's interpretation of the used oil regulations, and therefore we and our customer would be breaking the law if we do not follow this procedure. We cannot handle the used oil until we have proven through an acceptable test method that the oil is not contaminated by hazardous waste. Supervisors are responsible for training their drivers on Mesa Oil's testing procedures as outlined in our training manual.

Since our customers are relying on us to remove used oil from their storage tanks so that they can continue to change oil in vehicles or equipment, a contaminated tank can pose an immediate storage problem. If our customer has a problem, then we have a problem. This becomes a service problem, not a sales and marketing problem. The intent of this procedure is to continue the process of testing the oil to prove that it is not hazardous. Because the next step of testing involves an outside lab and service to our customer may be delayed, a supervisor must become involved. The supervisor must follow this procedure step by step.

1. If a Driver runs a Chlor-d-tect 1000 test on an oil sample and the test shows a positive result (meaning the oil may contain over 1,000 parts per million of chlorine) they are instructed to notify their supervisor immediately. When the driver calls, you should go over the sampling and testing procedures, to be sure they were performed correctly. You may authorize a second Chlor-d-tect at no additional cost to the customer.

2. If the second test is negative then we have proven the used oil is not hazard and the driver can proceed with service. The Chlor-d-tect test will give false positives, however it will not give false negatives. For example: Water will give a positive reading or letting the sample sit to long will give a positive reading.

3. If the second test is positive, our driver must now note this on the manifest and contact you again. You must discuss the situation with the customer. The most important point to make with the customer is: The Clor-D-Tect test does not prove that the oil is contaminated with a hazardous waste. All this test can due is prove that the oil is not contaminated.

4. We will now offer our customer the following option which is the next step towards proving that the oil is not mixed with hazardous waste. The supervisor will offer to have the Mesa Oil driver take a sample in a Mesa Oil "lab sample bottle" and handle the shipping of the sample to a certified lab for analysis. If the customer does not want this option, which must be offered by the dispatcher, then the dispatcher will instruct the driver to complete the manifest with the Chlor-d-tect charge entered and write "customer refused Halogen lab analysis on the comment line. If the customer agrees, the dispatcher will continue this procedure.

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