1 / 65

12th Annual California Unified Program Conference

02/04/2010. 12th Annual California Unified Program Conference. 2. Evaluations. Please complete evaluations. There are two:- One for the overall conference, and- One for this course We modify the hazardous waste track based on your input. Would you like more of this? Any other Topics

katarina
Download Presentation

12th Annual California Unified Program Conference

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

    1. 02/04/2010 12th Annual California Unified Program Conference 1 12th Annual California Unified Program Conference

    2. 02/04/2010 12th Annual California Unified Program Conference 2 Evaluations Please complete evaluations. There are two: - One for the overall conference, and - One for this course We modify the hazardous waste track based on your input. Would you like more of this? Any other Topics? LDRs Closure Costs Advanced Waste Classification Waste Counting This course and the conference are modified in response to your comments/requests. Your input is important!

    3. 02/04/2010 12th Annual California Unified Program Conference 3 Michael Vizzier Keith Waara Leon Wirschem County of San Diego CUPA Michael.Vizzier@sdcounty.ca.gov Keith.Waara@sdcounty.ca.gov Leon.Wirschem@sdcounty.ca.gov

    4. 02/04/2010 12th Annual California Unified Program Conference 4 Objectives/Plan Use US EPA’s Office of Solid Waste (OSW) and DTSC’s guidance documents to analyze advanced issues. Examine scenarios and discuss varying interpretations. Three topic areas: Part I: Advanced waste and treatment tier determination. Part II: Waste determination: Analysis Knowledge of Process Part III: Hazardous Waste Tank System Standards We’ll start with the laws and regulations then progress through guidance documents and scenarios.

    5. 02/04/2010 12th Annual California Unified Program Conference 5 Part I References and Point of Generation Is it Waste? Is it a Hazardous Waste?

    6. 02/04/2010 12th Annual California Unified Program Conference 6 Is it a Waste? §66261.2 Definition of Waste §66261.2(a) "Waste" means any discarded material of any form (liquid, semi-solid, solid or gaseous) that is not excluded by §66261.4(a) or §66261.4(e) or that is not excluded by H&SC §25143.2(b) or H&SC§ 25143.2(d). (b) A discarded material is (1) relinquished, or (2) recycled, or (3) considered inherently waste-like. Of course there are other exceptions…

    7. 02/04/2010 12th Annual California Unified Program Conference 7 Don’t forget the table… Is it a (solid) Waste? Point to reclamation column. Need to know what the terms mean.Point to reclamation column. Need to know what the terms mean.

    8. 02/04/2010 12th Annual California Unified Program Conference 8 EPA Solid Waste Flowchart http://www.epa.gov/epawaste/hazard/dsw/tool.htm#t=instructions

    9. 02/04/2010 12th Annual California Unified Program Conference 9 Is it a Hazardous Waste? §66261.3 Definition of Hazardous Waste §66261.3 (a) A waste as defined in §66261.2 is a hazardous waste if: (1) it is not excluded from classification as a waste or a hazardous waste under H&SC §25143.2(b) or §25143.2(d) or §66261.4; and (2) it meets any of the following criteria: (A) it exhibits any of the characteristics of hazardous waste identified in article 3 (B) it is listed in article 4 H&SC 25124 excludes coolant, lubricants, cutting fluids processed and used in connected manufacturing equipment…

    10. 02/04/2010 12th Annual California Unified Program Conference 10 A Hazardous Waste is: Declared – Generator decides to manage it as a hazardous waste Characteristic – A representative sample exhibits a hazardous characteristic (RCRA D001 to D043 + California Corrosive, Reactive and Toxic) (22 CCR, Ch. 11, Art. 3) Listed (22 CCR, Ch. 11, Art. 4) F listed (Non-Specific Sources) K listed (Specific Sources) P Listed (Acutely Hazardous Off-Spec, Spills) U listed (Hazardous Off-spec, Spills) M listed (Ch. 11, Art. 4.1 mercury containing products) Mixtures of solid and hazardous waste Residues derived from a hazardous waste

    11. 02/04/2010 12th Annual California Unified Program Conference 11 EXAMPLE Waste listed as hazardous due to: Benzene D018 – Benzene concentration ? 0.5 mg/l TCLP (D list pertains to characteristic wastes) F037 – Petroleum refinery primary separation sludge F038 – Petroleum refinery secondary separation sludge K085 – Distillation bottoms from the production of chlorobenzenes P028 – Benzene (chloromethyl)- (commercial chemical product) U019 – Benzene (commercial chemical product)

    12. 02/04/2010 12th Annual California Unified Program Conference 12 Mixture Rule A mixture of a solid waste & a characteristic (Art. 3 or Subpart C) hazardous waste is hazardous only if the resulting mixture exhibits a hazardous characteristic (commingled waste still requires HW management, see treatment definition H&SC 25123.5). A mixture of a solid waste & a listed (Art. 4 or Subpart D) hazardous waste that is listed only for ignitability, corrosivity or reactivity (I,C,R) is hazardous only if the resulting mixture exhibits a hazardous characteristic (see also H&SC 25123.5). A mixture of a solid waste & a listed (Art. 4 or Subpart D) hazardous waste that is listed only for toxicity remains listed as a hazardous waste.

    13. 02/04/2010 12th Annual California Unified Program Conference 13 Derived from Rule (Treatment Residue) Residues from treating, storing or disposing a characteristic waste are hazardous only if they exhibit a characteristic of hazardous waste. Residues from treating, storing or disposing a listed waste, that is listed solely for ignitability, corrosive or reactive (I,C,R), are hazardous only if they exhibit a characteristic of hazardous waste. Residues from treating, storing or disposing a listed waste, which is listed for toxicity, remain a listed hazardous waste.

    14. 02/04/2010 12th Annual California Unified Program Conference 14 RCRA vs. non-RCRA RCRA - A waste, not exempt, that is Listed or Characteristic. Non-RCRA - includes additional wastes for the following reasons: Is it a solid waste? In CA, more materials defined as a waste (recyclable materials) Is it exempt? Fewer exemptions in CA regulations.* Is it listed? California listed waste codes, CA has additional wastes (contaminated petroleum debris, latex paints…) Is it characteristic? More broad definitions of corrosivity & toxicity CA Toxicity: tougher extraction test methods, metals such as nickel, copper, zinc, etc.; corrosive solids, LD50 oral and dermal, LC50 inhalation, aquatic toxicity, carcinogenicity and more… * Many statutory requirements are in the law and not found in the regulations.

    15. 02/04/2010 12th Annual California Unified Program Conference 15 Who Makes a Waste Determination? The Generator

    16. 02/04/2010 12th Annual California Unified Program Conference 16 What’s a Generator? 22 CCR §66260.10 Generator: “any person, by site, whose act or process produces hazardous waste identified or listed in Chapter 11 or whose act first causes a hazardous waste to become subject to regulation.”

    17. 02/04/2010 12th Annual California Unified Program Conference 17 What’s a Person? 22 CCR §66260.10 Person: “an individual, trust, firm, joint stock company, federal agency, corporation (including a government corporation), partnership, association, state, municipality, commission, political subdivision of a state, or any interstate body.” Person also includes: “any city, county, district, commission, the State or any department, agency or political subdivision thereof, any interstate body, and the Federal Government or any department or agency thereof to the extent permitted by law.”

    18. 02/04/2010 12th Annual California Unified Program Conference 18 What’s A Site? 22 CCR §66260.10 The term, "by site," refers to where a hazardous waste is generated. The regulations do not explicitly define the term “site.” But the regulations do define onsite. "Onsite" means the same or geographically contiguous property which may be divided by public or private right-of-way, provided the entrance and exit between the properties is at a crossroads intersection, and access is by crossing as opposed to going along, the right-of-way. Non-contiguous properties owned by the same person but connected by a right-of-way which that person controls and to which the public does not have access, is also considered onsite property.

    19. 02/04/2010 12th Annual California Unified Program Conference 19 Whose Act or Process? A generator is defined as the person whose act or process first causes a hazardous waste to become subject to regulation. Sometimes the generator of a waste may not necessarily be the person who actually produced the waste. For example, if a cleaning service removes residues from a product storage tank excluded under §261.4(c), the person removing the residues is the first person to cause the waste to become subject to regulation, not the owner of the tank. In this case the cleaning service and the owner are co-generators.

    20. 02/04/2010 12th Annual California Unified Program Conference 20 More on Co-Generators The person removing the waste from the unit is not the owner or operator of the unit, but may be considered a generator. The owner or operator of the unit may also be considered a generator since the act of operating the unit led to the generation of the hazardous waste. In other words, both the remover of the waste and the owner or operator of the tank are considered to be co-generators. When one or more persons meet the definition of generator, all persons are jointly and severally liable for compliance with the generator regulations. The parties may through a mutual decision have one party assume the duties of generator, but in the event that a violation occurs, all persons meeting the definition of generator could be held liable for the improper management of the waste (45 FR 72026; October 30, 1980).

    21. 02/04/2010 12th Annual California Unified Program Conference 21 Point of Generation The point where a material becomes a waste is also the point where: Waste determination is made; samples are taken. Treatment tier determination is made Container & tank standards are required RCRA Land Disposal Restrictions apply

    22. 02/04/2010 12th Annual California Unified Program Conference 22 Point of Waste Origination 22 CCR §66260.10 “Point of waste origination” (1) When the facility owner or operator is the generator of the hazardous waste, the point of waste origination means the point where a solid waste produced by a system, process, or waste management unit is determined to be a hazardous waste as defined in this division…

    23. 02/04/2010 12th Annual California Unified Program Conference 23 Point of Waste Origination Defined per 22 CCR §66260.10 (Continued) [NOTE: In this case, this term is being used in a manner similar to the use of the term "point of generation" in air standards established for waste management operations under authority of the Clean Air Act in 40 CFR parts 60 , 61 and 63.]

    24. 02/04/2010 12th Annual California Unified Program Conference 24 Point of Waste Generation 40 CFR part 61 Point of waste generation means the location where the waste stream exits the process unit component or storage tank prior to handling or treatment in an operation that is not an integral part of the production process, or in the case of waste management units that generate new wastes after treatment, the location where the waste stream exits the waste management unit component.

    25. 02/04/2010 12th Annual California Unified Program Conference 25 Some Points of Generation Waste exits a non-waste unit or piece of equipment (e.g. radiator, parts washer). Waste exits a manufacturing process unit. Material is spent and a decision to discard or recycle is made. Decision is made to discard a P or U listed chemical. Treatment residue exits a treatment unit. Residue exits a recycling unit.

    26. 02/04/2010 12th Annual California Unified Program Conference 26 What is the Point of Generation? …hazardous waste identification must be made at the point where the waste is first generated. The point of generation is usually defined as the point at which a generator first determines that a material is no longer useful (or the point at which the generator decides to discard the material). http://www.epa.gov/waste/hazard/tsd/ldr/ldr-sum.pdf

    27. 02/04/2010 12th Annual California Unified Program Conference 27 Under 40 CFR 261.4(c): Hazardous waste is not generated from product or raw material tanks…and pipelines, manufacturing process units, or associated non-waste-treatment-manufacturing units until it exits the unit; or if The HW remains in unit > 90 days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials. http://www.epa.gov/waste/hazard/tsd/ldr/ldr-sum.pdf   What is the Point of Generation?

    28. 02/04/2010 12th Annual California Unified Program Conference 28 Manufacturing Process Units (MPU) Process units including distillation columns, flotation units, discharge trays (faxback 11935). Tanks or tank like units that are designed and operated to hold product or raw materials in storage or transport or during manufacturing (faxback 11935). Waste in pipelines associated with MPUs not regulated until removed or 90 days after piping removed from service (faxback 13790). What’s a faxback?

    29. 02/04/2010 12th Annual California Unified Program Conference 29 Points of Generation (POG) Tanks A, B & C

    30. 02/04/2010 12th Annual California Unified Program Conference 30 Commingling Tanks A, B & C

    31. 02/04/2010 12th Annual California Unified Program Conference 31 Points of Generation (POG) Tanks A + B = C

    32. 02/04/2010 12th Annual California Unified Program Conference 32 OSW Answer (faxback 13395) Question: A D002 acidic waste and a D002 basic waste from two different manufacturing process are individually piped to a collecting pipe. The two wastes neutralize each other in the collecting pipe and the result is a non-hazardous waste. Is there a point of generation? Answer: Each of the corrosive wastes has a point of generation upstream of the collecting pipe.

    33. 02/04/2010 12th Annual California Unified Program Conference 33 What is RCRA Online? It used to be a FAXBACK, an automated document fax system, hence the name.

    34. 02/04/2010 12th Annual California Unified Program Conference 34 RCRA Online Now it’s RCRA Online. http://www.epa.gov/epawaste/inforesources/online/index.htm Select Advanced Search http://yosemite.epa.gov/osw/rcra.nsf/advanced+search?OpenForm Type the “faxback” number in the RCRA online number field. Click on the Document name to view the entire document. Like this….

    35. 02/04/2010 12th Annual California Unified Program Conference 35

    36. 02/04/2010 12th Annual California Unified Program Conference 36

    37. 02/04/2010 12th Annual California Unified Program Conference 37

    38. 02/04/2010 12th Annual California Unified Program Conference 38

    39. 02/04/2010 12th Annual California Unified Program Conference 39

    40. 02/04/2010 12th Annual California Unified Program Conference 40 References 22 CCR 6626x.xxx mirrors 40 CFR 26x.xxx There are exceptions (where is §66261.5?) 40 CFR 261.5 is CESQG: California does not use this concept (exceptions: LDRs, photochemical waste) If the 22 CCR section reads exactly the same as the 40 CFR section, then the OSW guidance is probably good. OSW, EPA, FaxBack, Federal Registers: All are good source documents, even for California.

    41. 02/04/2010 12th Annual California Unified Program Conference 41 California has additional requirements, however RCRA Online provides valuable guidance, policies and definitions. In addition to federal guidance, you should check your Title 22 CCR and the California Health & Safety Code!

    42. 02/04/2010 12th Annual California Unified Program Conference 42 Check DTSC’s web page first: http://www.dtsc.ca.gov/ Laws, Regulations and Policies http://www.dtsc.ca.gov/LawsRegsPolicies/index.cfm Publications & Forms Index http://www.dtsc.ca.gov/PublicationsForms/index.cfm More References

    43. 02/04/2010 12th Annual California Unified Program Conference 43

    44. 02/04/2010 12th Annual California Unified Program Conference 44

    45. 02/04/2010 12th Annual California Unified Program Conference 45

    46. 02/04/2010 12th Annual California Unified Program Conference 46

    47. 02/04/2010 12th Annual California Unified Program Conference 47

    48. 02/04/2010 12th Annual California Unified Program Conference 48 Treatment Tier Determination Where do you make a waste determination prior to entering a tiered permitting flow chart?

    49. 02/04/2010 12th Annual California Unified Program Conference 49 A decision is made to discard the material in tanks A, B & C, then consolidate the waste in tank D.

    50. 02/04/2010 12th Annual California Unified Program Conference 50 “Treatment” does not include: H&SC §25123.5 (b)(2)(C) (C) Combining two or more waste streams that are not incompatible into a single tank or container if both of the following conditions apply: (i) The waste streams are being combined solely for the purpose of consolidated accumulation or storage or consolidated offsite shipment, and they are not being combined to meet a fuel specification or to otherwise be chemically or physically prepared to be treated, burned for energy value, or incinerated. (ii) The combined waste stream is managed in compliance with the most stringent of the regulatory requirements applicable to each individual waste stream.

    51. 02/04/2010 12th Annual California Unified Program Conference 51 A decision is made to discard the materials in tanks A, B & C, then treat it in tank D.

    52. 02/04/2010 12th Annual California Unified Program Conference 52 Because? (CA) 25200.3 (b) Any treatment performed pursuant to this section shall comply with all of the following, except as to generators, who are treating hazardous waste pursuant to paragraph (11) of subdivision (a), who shall also comply with any additional conditions of the specified certification if those conditions are different from those set forth in this subdivision: (1) The total volume of hazardous waste treated in the unit in any calendar month

    53. 02/04/2010 12th Annual California Unified Program Conference 53 Because? (CE) §25201.5. Generators, hazardous waste facility permit exemptions (a) Notwithstanding any other provision of law, a hazardous waste facilities permit is not required for a generator who treats hazardous waste of a total weight of not more than 500 pounds, or a total volume of not more than 55 gallons, in any calendar month, if both of the following conditions are met:

    54. 02/04/2010 12th Annual California Unified Program Conference 54 Caution H&SC 25200.3 (d) “Notwithstanding any other provision of law, the following activities are ineligible for conditional authorization: (2) Commingling of hazardous waste with any hazardous waste that exceeds the concentration limits or pH limits specified in subdivision (a), or diluting hazardous waste in order to meet the concentration limits or pH limits specified in subdivision (a).”

    55. 02/04/2010 12th Annual California Unified Program Conference 55 A decision is made to discard the material in tanks A, B & C, then treat it in tank D.

    56. 02/04/2010 12th Annual California Unified Program Conference 56 NO: §66268.3. Dilution Prohibited as a Substitute for Treatment (a) No generator, transporter, handler, or owner or operator of a treatment, storage, or disposal facility shall in any way dilute a restricted waste or the residual from treatment of a restricted waste as a substitute for adequate treatment to achieve compliance with article 4 or article 11 of this chapter, to circumvent the effective date of a prohibition in article 3 or article 10 of this chapter, to otherwise avoid a prohibition in article 3 or article 10 of this chapter, or to circumvent a land disposal prohibition imposed by RCRA section 3004 (42 U.S.C. § 6924).

    57. 02/04/2010 12th Annual California Unified Program Conference 57 YES: Dilution Ref: EPA 530-R-01-007 (revised August 2001) http://www.epa.gov/waste/hazard/tsd/ldr/ldr-sum.pdf Wastes that are aggregated or mixed as a part of a legitimate treatment process, and are subsequently diluted as a result, are not considered to be impermissibly diluted under LDR.

    58. 02/04/2010 12th Annual California Unified Program Conference 58

    59. 02/04/2010 12th Annual California Unified Program Conference 59 Treatment is… 25123.5(a) “Treatment" means any method, technique, or process which is not otherwise excluded from the definition of treatment by this chapter and which is designed to change the physical, chemical, or biological character or composition of any hazardous waste or any material contained therein, or which removes or reduces its harmful properties or characteristics for any purpose.

    60. 02/04/2010 12th Annual California Unified Program Conference 60 Land Disposal Restrictions (LDRs) LDRs were established to keep landfills from becoming superfund sites. The dilution prohibition is in chapter 18 (LDRs). But deactivation (DEACT) is a form of treatment permitted under LDRs that can be achieved by dilution. The dilution reduce the toxics concentration below hazardous thresholds, then water could evaporate in non-hazardous waste surface impoundments and the resultant sludge could be hazardous and leach, so stringent treatment standards were mandated by the courts.

    61. 02/04/2010 12th Annual California Unified Program Conference 61

    62. 02/04/2010 12th Annual California Unified Program Conference 62 Treatment Tier Determination Treatment Units in Series

    63. 02/04/2010 12th Annual California Unified Program Conference 63 Treatment Trick Question

    64. 02/04/2010 12th Annual California Unified Program Conference 64 Is the Sodium Fluoride subject to LDRs?

    65. 02/04/2010 12th Annual California Unified Program Conference 65 Treatment Standard Determination -Waste Mixture-

    66. 02/04/2010 12th Annual California Unified Program Conference 66 Treatment Standard Determination -Characteristic Waste-

    67. 02/04/2010 12th Annual California Unified Program Conference 67 Sludge D006: Cadmium concentration ? 1.0 mg/l TCLP Ni concentration ? 20 mg/l STLC, 2000 mg/kg TTLC TREATMENT STANDARDS D006 waste water treatment standard 0.69 mg/l TCLP, but one notification on-file only requirement if discharged to CWA facility (§§66268.40 & 66268.48) D006 non-waste water treatment standard 0.11 mg/l (§§66268.40 & 66268.48) Ni waste water treatment standard 20 mg/l WET (§66268.107)

    68. 02/04/2010 12th Annual California Unified Program Conference 68 Waste Water No Land Disposal, No LDR 22 CCR §66268.7 requires that the facility must place a one time notification in its files indicating that it is exempt from LDRs per §66261.4(a)(1), and (3) identifying the disposition of the waste. [Note: The underlying hazardous constituents do not have to be identified or treated in characteristic waste when these waste are de-characterized and managed in wastewater treatment systems regulated under the CWA.]

    69. 02/04/2010 12th Annual California Unified Program Conference 69

    70. 02/04/2010 12th Annual California Unified Program Conference 70 F006 Sludge Constituent Waste Water Non-waste Water Cadmium 0.69 mg/l 0.11 mg/l TCLP Chromium 2.77 0.60 mg/l TCLP (total) Cyanides 1.2 590.0 (total) Cyanides 0.86 30 (amenable) Lead 0.69 0.75 mg/l TCLP Nickel 3.98 11.0 mg/l TCLP Silver NA 0.14 mg/l TCLP

    71. 02/04/2010 12th Annual California Unified Program Conference 71 Commingling (diluting) Hazardous Waste

    72. 02/04/2010 12th Annual California Unified Program Conference 72 Commingling Ref:EPA 530-R-01-007 (revised August 2001) Where a waste stream will eventually be commingled with other waste streams, the Agency generally requires waste identification and LDR determination to be made at the point the waste is generated, prior to the commingling, even if the commingling occurs within a pipe (except in a totally enclosed treatment system). One exception to this rule is that the point of generation for tank cleanouts occurs at the end of the rinseouts in the receiving rinsate tank, even though the first rinse is likely to be of higher concentration than the other rinses.

    73. 02/04/2010 12th Annual California Unified Program Conference 73 Is this Dilution Permitted? “Aggregation for Centralized Treatment” is generally acceptable dilution provided that the type of treatment will remove or destroy the contaminants. You can’t aggregate to dilute, but you can aggregate for efficient treatment. Wastes that are aggregated or mixed as a part of a legitimate treatment process, and are subsequently diluted as a result, are not considered to be impermissibly diluted under LDR.

    74. 02/04/2010 12th Annual California Unified Program Conference 74 (C) Combining two or more waste streams that are not incompatible into a single tank or container if both of the following conditions apply: (i) The waste streams are being combined solely for the purpose of consolidated accumulation or storage or consolidated offsite shipment, and they are not being combined to meet a fuel specification or to otherwise be chemically or physically prepared to be treated, burned for energy value, or incinerated. (ii) The combined waste stream is managed in compliance with the most stringent of the regulatory requirements applicable to each individual waste stream. So it’s not treatment, but do LDRs apply?

    75. 02/04/2010 12th Annual California Unified Program Conference 75 Do LDRs Apply? These wastes are subject to land disposal restrictions. Removing the characteristic of corrosivity by combining these wastes can satisfy the treatment requirement of deactivation set out in 40 CFR 268.42, (now 268.40) Table 2. Dilution may not be appropriate if there are other requirements for the waste matrices. (FAXBACK 13395) Combining waste acid and a waste caustic to remove the characteristic of corrosivity is regulated treatment in California.*

    76. 02/04/2010 12th Annual California Unified Program Conference 76 Recycling & LDRs A generator that recycles onsite is still subject to LDRs. (FAXBACK 13280)

    77. 02/04/2010 12th Annual California Unified Program Conference 77 Point of Generation Tanks

    78. 02/04/2010 12th Annual California Unified Program Conference 78 Hazardous Waste Determination and Point of Generation (POG)

    79. 02/04/2010 12th Annual California Unified Program Conference 79

    80. 02/04/2010 12th Annual California Unified Program Conference 80 Hazardous Waste Determination and Point of Generation (POG)

    81. 02/04/2010 12th Annual California Unified Program Conference 81 POG in a Tank §66261.4(c) Exclusion

    82. 02/04/2010 12th Annual California Unified Program Conference 82 POG in a Tank Hazardous Waste is exempt if generated in: A product or raw materials storage tank A product or raw material transport vehicle or vessel In a product or raw material pipeline In a manufacturing process unit or an associated non-waste treatment-manufacturing unit It is exempt until it: Exits the unit, or Remains in non-operational unit for more than 90 days, or When the unit is a surface impoundment

    83. 02/04/2010 12th Annual California Unified Program Conference 83 POG in a Tank RCRA ONLINE 11420 12865 11102 11588 14152

    84. 02/04/2010 12th Annual California Unified Program Conference 84

    85. 02/04/2010 12th Annual California Unified Program Conference 85 Hazardous Waste Photo Bank Points of Generation for Hazardous Waste

    86. 02/04/2010 12th Annual California Unified Program Conference 86 Point of Generation The following slides depict points of generation where hazardous waste is being produced. Do you agree?

    87. 02/04/2010 12th Annual California Unified Program Conference 87

    88. 02/04/2010 12th Annual California Unified Program Conference 88

    89. 02/04/2010 12th Annual California Unified Program Conference 89

    90. 02/04/2010 12th Annual California Unified Program Conference 90

    91. 02/04/2010 12th Annual California Unified Program Conference 91

    92. 02/04/2010 12th Annual California Unified Program Conference 92

    93. 02/04/2010 12th Annual California Unified Program Conference 93 Floor of Plating Shop Point of Generation?

    94. 02/04/2010 12th Annual California Unified Program Conference 94 Floor of Plating Shop Point of Generation?

    95. 02/04/2010 12th Annual California Unified Program Conference 95

    96. 02/04/2010 12th Annual California Unified Program Conference 96 -Waste Determination -Treatment Tier -Land Disposal Restrictions They are all based on: The Point of Generation

    97. 02/04/2010 12th Annual California Unified Program Conference 97 Resources RCRA Online Database DTSC Website Title 22, Health & Safety Code CalCUPA.net website

    98. 02/04/2010 12th Annual California Unified Program Conference 98 Ten minute Break

More Related