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9th Annual California Unified Program Conference

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Title: 9th Annual California Unified Program Conference


1
9th Annual California Unified Program Conference
Advanced Hazardous Waste Inspector Training
2
Evaluations
  • The are two evaluations one for the overall
    conference and one for this course, please
    complete them.
  • We modify the hazardous waste track based on your
    input. Would you like more of this? or other
    topics,
  • LDRs
  • Closure costs
  • Advanced Waste classification
  • Waste counting
  • This course and the conference is modified in
    response to your comments/requests.

3
John Misleh Michael Vizzier
  • San Diego County CUPA
  • john.misleh_at_sdcounty.ca.gov
  • michael.vizzier_at_sdcounty.ca.gov

4
Objective
  • Use US EPA Office of Solid Waste (OSW) and DTSC
    guidance documents to analyze advanced issues.
  • Examine scenarios and discuss varying
    interpretations.
  • Three topic areas
  • Part I Point of generation
  • Part II Waste Analysis
  • Part III Is it a Container or is it a Tank?
  • Well start with the laws and regulations then
    progress through guidance documents and scenarios.

5
Part I,Point of Generation
  • Is it Waste?
  • Is it a Hazardous Waste?

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 HSC
    25143.2(b) or HSC 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
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 HSC 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

8
A Hazardous Waste is
  • Declared Generator decides to manage as a
    hazardous waste
  • Characteristic A representative sample exhibits
    a hazardous characteristic (RCRA D001 to D043
    California corrosive, reactive, 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 hazardous waste
  • Residues derived from a hazardous waste

9
Example of waste listed as hazardous due to
Benzene
  • D018 Benzene concentration ? 0.5 mg/l TCLP
  • 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)

10
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.
  • 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.
  • A mixture of a solid waste a listed (Art. 4 or
    Subpart D) hazardous waste that is listed only
    for toxicity remain listed as a hazardous waste.

11
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.

12
Who Makes a Waste Determination?
  • The
  • Generator

13
Whats A Generator? 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.

14
Whats A Person? 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."

15
Whats A Site? 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. Noncontiguous 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.

16
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 case the cleaning service and the owner are
    co-generators.

17
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.
  • In cases where 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).

18
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

19
Point of Waste OriginationDefined per 22 CCR
66260.10
  • "Point of waste origination" (22 CCR) means as
    follows
  • (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.

20
Point of Waste Origination Defined 22 CCR
(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.

21
Point of Waste Generation Defined per 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.
    (40 CFR Part 61)

22
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.

23
8.2 What Is the Point of Generation?
  • According to RCRA and Sate law, when a waste is
    generated, you must identify whether the waste is
    hazardous
  • 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).
  • www.epa.gov/OSWRCRA/hazwaste/ ldr/ldr-sum.pdf 

24
8.2 What Is the Point of Generation?
  • However, under 40 CFR 261.4(c), hazardous waste
    is not generated from product or raw material
    tanksand pipelines, manufacturing process units,
    or associated non-waste-treatment-manufacturing
    units until it exits the unit or the HW remains
    in unit gt 90 days after the unit ceases to be
    operated for manufacturing, or for storage or
    transportation of product or raw materials.
  • www.epa.gov/OSWRCRA/hazwaste/ ldr/ldr-sum.pdf 

25
Points of Generation(POG) Tanks A, B C
The Points Of Generation are
Process A
Process B
Process C
Waste A
A B
ABCD
Tanks A, B C contain material used in different
processes the piping is used exclusively to
transfer the liquid when it is no longer useful.
Where is(are) the point(s) of generation?
D
26
Commingling Tanks A, B C
The Points of Generation are also
the Sampling points
Process A
Process B
Process C
Waste A
A B
ABCD
Tanks A, B C contain material. The waste is
commingled in the piping.
What and where do you sample for a waste
determination?
D
27
Point of Generation (POG)Tanks A B C
Non-hazardous Waste C Is discharged to POTW
Acidic Material A
D002 Waste
Basic Material B
Waste A
A B
AB C
C
Tanks A B contain material the piping is used
to mix transfer the liquid when it is no longer
useful.
Where is (are) the point(s) of generation?
28
OSW Answer (faxback 13395)
  • Q. 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?
  • A. Each of the corrosive wastes has a point of
    generation upstream of the collecting pipe.

29
FAXBACK?
  • Whats a FAXBACK?
  • It used to be an automated document fax system,
    hence the name.

30
RCRA Online
  • Now its RCRA online.
  • http//www.epa.gov/rcraonline/
  • Select Advanced Search
  • http//yosemite.epa.gov/osw/rcra.nsf/advancedsear
    ch?OpenForm
  • Type the faxback number in the RCRA online
    number field.
  • Click on the Document name to view the entire
    document.
  • Like this.

31
(No Transcript)
32
Type the faxback Number in here.
33
(No Transcript)
34
(No Transcript)
35
(No Transcript)
36
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 CRF section the OSW guidance is probably
    good.
  • OSW, EPA, Faxbacks, Federal Registers All are
    good source document even for California

37
http//www.dtsc.ca.gov/
  • Check DTSCs web page first, http//www.dtsc.ca.go
    v/
  • Publications Index
  • http//www.dtsc.ca.gov/database/Publications/pub_i
    ndex.cfm
  • Forms Index
  • http//www.dtsc.ca.gov/database/Publications/forms
    _index.cfm
  • DTSCs Hazardous Waste and Recycling Letters
  • http//www.dtsc.ca.gov/PublicationsForms/CSERFS/in
    dex.html
  • Some are out of date, the laws change.

38
(No Transcript)
39
http//www.dtsc.ca.gov/HazardousWaste/CSERFS/index
.cfm
40
9 Files found out of 848 files searched
41
Treatment Tier Determination
  • Where do you make a waste determination prior to
    entering a tiered permitting flow chart?

At the Point of Generation
42
A decision is made to discard the material in
tanks A, B C, then consolidate the waste in
tank D.
Process B
Process A
Process C
Points of generation
Waste Accumulation Tank. Waste D
Process B waste is non-hazardous. Processes A
C wastes are hazardous. Is this hazardous waste
treatment?
No, it is not treatment if the wastes are
combined solely for the purpose of consolidated
accumulation.
43
HSC 25123.4 (b) (1) "Treatment" does not
include
  • (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.

44
A decision is made to discard the material in
tanks A, B C, then treat it in tank D.
Process A
Process B
Process C
Points of generation
Treatment tank. Waste D
Process B waste is non-hazardous. Processes A
C wastes are hazardous. Waste D is hazardous.
Which waste(s) are used to determine the
treatment tier?
Wastes A, C D. Treatment Tier is based on the
hazardous waste characteristics (A C) and the
volume of waste treated (D).
45
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

46
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

47
Caution
  • HSC 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).

48
A decision is made to discard the material in
tanks A, B C, then treat it in tank D.
Process A
Process B
Process C
Points of generation
Treatment tank. Waste D
Process B waste is non-hazardous. Processes A
C wastes are hazardous. Waste D is
non-hazardous. Is the addition of waste B
permissible dilution?
No, if waste B is added to dilute hazardous
characteristics.
Yes, if waste B is added for efficient treatment.
49
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).

50
YES DilutionRef EPA 530-R-01-007 (revised
August 2001)
  • 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.

51
A decision is made to discard the material in
tanks A, B C, then treat it in tank D.
Process C
Process B
Process A
Points of generation
Waste Accumulation Tank. Waste D
Process B waste is non-hazardous. Processes A
C wastes are hazardous. Waste D isnt hazardous,
the addition of B reduced the hazardous
constituents below the hazardous waste threshold.
Is a treatment authorization required?
Yes, authorization is required. Waste A C are
hazardous waste. Dilution is treatment.
Additional treatment might be required to meet
LDR standards.
52
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.

53
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.

54
LDR Treatment Standards Example D006 Sludge
w/Cadmium
  • HAZARDOUS WASTE THRESHOLD
  • D006 Cadmium concentration ? 1.0 mg/l TCLP or
    STLC
  • Ni concentration ? 20 mg/l STLC
  • LDR TREATMENT STANDARDS
  • D006 waste water treatment standard 0.69 mg/l
    TCLP, notification on-file is the only
    requirement if discharged to POTW
  • D006 non-waste water treatment standard 0.11 mg/l
    (66268.40 66268.48)
  • Ni waste water treatment standard 3.98 mg/l
    (66268.48)
  • Ni non-waste water treatment standard 0.11 mg/l
    TCLP (66268.48)

55
Treatment Tier Determination Treatment Units in
Series
Process Tank
Process Tank outflow (Waste A) Non-hazardous
Settling Tank
Settling Tank sludge outflow (Waste B),
hazardous waste.
Sludge. Hazardous Waste
Waste B. Must have hazardous waste to have
hazardous waste treatment.
Heated Drying Tank
Q Which waste is used to determine treatment
tier, A or B?
Non-hazardous waste water to sewer
56
Treatment Trick Question
NO. Fluoride salts are a Non-RCRA hazardous
Waste.
HF
NaOH
D002 Waste
waste HF
HFNaOH
H2ONaF
The D002 waste from tanks A B are neutralized
in the collection piping. Is it OK to discharge
the new waste (water sodium fluoride) to sewer?
57
Is the Sodium Fluoride subject to LDRs?
No. The non-RCRA Wastes that are subject to Land
Disposal Restrictions are listed in 66268.29.
Fluoride salts are not listed.
But, if the fluorine was from a P056 listed waste
LDRs would apply!
58
Treatment Standard Determination-Waste Mixture-
Non-Haz Waste A
Non-Haz Waste B
Hazardous Waste C
Treatment tank
Hazardous Waste D
Wastes A B are non-hazardous. Wastes C D are
hazardous. Waste D is dried and disposed of in a
class I landfill. Which waste(s) do you evaluate
to meet LDRs?
Waste C and D. The treatment standard is based
on the waste at point of generation.
59
Treatment Standard Determination-Characteristic
Waste-
Process Tank
Process Tank outflow (waste A). Non-RCRA, Ni gt
20 mg/l STLC
Settling Tank
Settling tank sludge outflow (waste B), RCRA,
D006 (Cd) and Non-RCRA Ni.
Sludge, Hazardous Waste
Heated Drying Tank
Which wastes are subject to LDR standards?
All. The process waste (A) which goes out as
wastewater (C) requires a notification to file.
The outflow (B) which goes out as sludge is
subject to RCRA Calif. LDRs.
Pre-treated Waste water (Waste C) to POTW.
60
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)

61
Waste waterNo 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.

62
Treatment Standard Determination -Listed Waste-
Process Tank
Process Tank outflow (waste A). RCRA F006
Settling Tank
Settling tank sludge outflow (waste B), RCRA F006
Sludge. Hazardous waste
Heated Drying Tank
Which wastes are subject to LDRs?
Process outfall (A) sludge (B) require LDRs.
Wastewater to POTW requires notice to file.
Pre-treated Waste water to POTW
63
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

64
Commingling (diluting) Hazardous Waste
The waste from tank A is hazardous. The wastes
from tanks B C are not Hazardous
Haz A
Not B
Not C
Hazardous
?
Is this dilution permitted?
Is this treatment?
Non-hazardous
D
Do LDRs apply?
65
Commingling RefEPA 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.

66
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 cant 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.

67
Is it Treatment?
  • HSC 25123.4 (b) (1)Treatment does not include
  • (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.

68
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 a waste caustic to remove
    the characteristic of corrosivity is regulated
    treatment in California.

69
Recycling LDRs
  • A generator that recycles onsite is still subject
    to LDRs. (FAXBACK 13280)

70
Short Break
  • Take 5
  • John Misleh, next speaker.

71
Point of Generation
  • Tanks
  • Containers

72
Hazardous Waste Determination Point of
Generation (POG)
Process Tank 1
Process Tank outflow (waste A). Non-hazardous
Process Tank 2
Settling tank sludge outflow (waste C) hazardous
waste.
B
Sludge (waste B) hazardous waste.
A The outflow from the Process Tank - Waste C
is hazardous and is the POG.
Heated Drying Tank
Q Where is the point of generation? A or B or C?
Non-hazardous waste water to sewer.
73
Hazardous Waste Determination Point of
Generation (POG)
Process Tank
Process Tank outflow (waste A). Non-hazardous
Settling Tank
Settling tank sludge outflow (waste C),
hazardous waste.
B
Sludge (waste B) hazardous waste.
A The settling tank - Waste B is hazardous and
is the POG.
Heated Drying Tank
Q Where is the point of generation? B or C?
Non-hazardous waste water to sewer.
74
Hazardous Waste Determination Point of
Generation (POG)
Waste Tank input Non-hazardous waste.
A The settling tank sludge is hazardous, the POG
is in the tank.
Settling Tank
A
Sludge is Hazardous
Q Where is the point of generation?
75
POG in a Tank66261.4(c) Exclusion
  • A hazardous waste which is generated in a product
    or raw material storage tank is not subject to
    regulation under this division until it exits the
    unit in which it was generated unless the
    hazardous waste remains in the unit more than 90
    days after the unit ceases to be operated.
  • The exemption in this subsection applies only to
    the hazardous waste generated in the above-named
    tanks, not to the tanks themselves. The tanks
    remain subject to the requirements of chapter 32
    if the tank is a hazardous waste pursuant to
    article 3 of chapter 11 of this division.

76
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
  • Until it exits the unit
  • Or remains in non operational unit for more than
    90 days
  • Or unless the unit is a surface impoundment

77
POG in a Tank
  • FAXBACKs
  • 11420
  • 12865
  • 11102
  • 11588
  • 14152

78
Chapter 32. Management of Tanks 67383.1
Applicability
(a) Establishes standards for all (AST UST)
tanks that held hazardous waste or materials, and
are to be disposed, reclaimed or closed in place,
except as provided in (b), (c) and (d) below. (b)
These requirements do not apply to tanks
regulated under a hazardous waste facility
permit, other than a permit by rule. (c) These
requirements do not apply to a tank system that
meets the definition of "scrap metal" and is
excluded from regulation. (d) These requirements
do not apply to any tank that is not a hazardous
waste.
79
Management of Tanks 67383.1. Applicability
Does you use this closure process?
When?
80
Chapter 32. Management of Tanks
  • Use the Closure Process if
  • The Tank System is identified as Hazardous Waste
  • And the Tank System is not
  • Scrap Metal

81
Hazardous Waste
  • Photo BankPoints of Generation for Hazardous
    Waste

82
Point of Generation
  • The following slides depict points of
  • generation where hazardous waste is being
    produced.
  • Do you agree?

83
Drum Washing Point of Generation?
84
Drum Washing Point of Generation?
When rinsate exits the process unit
A
When rinsate exits the drum
B
The empty drum is the POG
C
The drum is not California empty
85
Drum Washing Point of Generation?
When rinsate exits the process unit
A
B
When rinsate exits the drum
The empty drum is the POG
C
What if the drum is California empty?
86
Drum Washing Point of Generation?
Is the Drum Washing still Tiered Permitting?
How about rinsing 5 gallon pails?
What if the drum is California empty?
87
Process Tanks Point of Generation?
88
Process Tanks Point of Generation?
A
When solution is removed as a waste
Is a product not a waste?
When solution remains in non-operational
equipment for gt90 days
When solution remains in non-operational
equipment for gt 1 year
B
C
89
HCl Bottling Area Poly Tank Point of Generation?
90
HCl Bottling Area Poly Tank Point of Generation?
A
Exit point from tank
B
The sump
When removed from the sump
C
91
Floor of Plating Shop Point of Generation?
92
Floor of Plating Shop Point of Generation?
X
Floor is part of process, not a waste
93
Floor of Plating ShopPoint of Generation?
X
Floor is part of process, not a waste
94
Floor of Plating ShopPoint of Generation?
Haz. Material/Waste Dropped on the Floor
95
Floor of Plating ShopPoint of Generation?
Leaking Nickel Tank
96
The Waste Determination Treatment Tier Land
Disposal Restrictions are all based on
  • The Point of Generation

97
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