CUPA 2007 Adv HW part 1 POG

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9th Annual California Unified Program Conference: 

9th Annual California Unified Program Conference

Evaluations: 

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.

John Misleh & Michael Vizzier: 

John Misleh & Michael Vizzier San Diego County CUPA john.misleh@sdcounty.ca.gov michael.vizzier@sdcounty.ca.gov

Objective: 

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? We’ll start with the laws and regulations then progress through guidance documents and scenarios.

Part I, Point of Generation : 

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

Is it a Waste? §66261.2. Definition of Waste: 

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…

Is it a Hazardous Waste? §66261.3. Definition of Hazardous Waste: 

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

A Hazardous Waste is:: 

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

Example of waste listed as hazardous due to Benzene: 

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)

Mixture Rule : 

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.

Derived from Rule (Treatment Residue): 

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.

Who Makes a Waste Determination?: 

Who Makes a Waste Determination? The Generator

What’s A Generator? §66260.10 : 

What’s 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.”

What’s A Person? §66260.10: 

What’s 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."

What’s A Site? §66260.10: 

What’s 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.

Whose Act or Process?: 

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.

Co-Generators: 

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).

Point of Generation: 

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

Point of Waste Origination Defined per 22 CCR §66260.10: 

Point of Waste Origination Defined 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.

Point of Waste Origination Defined 22 CCR (Continued): 

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.]

Point of Waste Generation Defined per 40 CFR part 61: 

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)

Points of Generation: 

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.

8.2 What Is the Point of Generation?: 

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 

8.2 What Is the Point of Generation?: 

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 tanks…and pipelines, manufacturing process units, or associated non-waste-treatment-manufacturing units until it exits the unit; or 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. www.epa.gov/OSWRCRA/hazwaste/ ldr/ldr-sum.pdf 

Points of Generation (POG) Tanks A, B & C: 

Points of Generation (POG) Tanks A, B & C Process A 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. Process B Process C D Waste A A + B A+B+C=D Where is(are) the point(s) of generation? The Points Of Generation are

Commingling Tanks A, B & C: 

Commingling Tanks A, B & C Process A Tanks A, B & C contain material. The waste is commingled in the piping. Process B Process C D Waste A A + B A+B+C=D What and where do you sample for a waste determination? The Points of Generation are also the Sampling points

Point of Generation (POG) Tanks A + B = C: 

Point of Generation (POG) Tanks A + B = C Acidic Material A Tanks A & B contain material; the piping is used to mix & transfer the liquid when it is no longer useful. Basic Material B Waste A A + B A+B = C Where is (are) the point(s) of generation? D002 Waste Non-hazardous Waste C Is discharged to POTW C

OSW Answer (faxback 13395): 

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.

FAXBACK?: 

FAXBACK? What’s a FAXBACK? It used to be an automated document fax system, hence the name.

RCRA Online: 

RCRA Online Now it’s RCRA online. http://www.epa.gov/rcraonline/ 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….

Slide32: 

Type the “faxback” Number in here.

References: 

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

http://www.dtsc.ca.gov/: 

http://www.dtsc.ca.gov/ Check DTSC’s web page first, http://www.dtsc.ca.gov/ Publications Index http://www.dtsc.ca.gov/database/Publications/pub_index.cfm Forms Index http://www.dtsc.ca.gov/database/Publications/forms_index.cfm DTSC’s Hazardous Waste and Recycling Letters http://www.dtsc.ca.gov/PublicationsForms/CSERFS/index.html Some are out of date, the laws change.

Slide39: 

http://www.dtsc.ca.gov/HazardousWaste/CSERFS/index.cfm

Slide40: 

9 Files found out of 848 files searched

Treatment Tier Determination: 

Treatment Tier Determination Where do you make a waste determination prior to entering a tiered permitting flow chart? At the Point of Generation

A decision is made to discard the material in tanks A, B & C, then consolidate the waste in tank D.: 

Process A Process B Process C Waste Accumulation Tank. Waste D Process B waste is non-hazardous. Processes A & C wastes are hazardous. Is this hazardous waste treatment? A decision is made to discard the material in tanks A, B & C, then consolidate the waste in tank D. Points of generation No, it is not treatment if the wastes are combined solely for the purpose of consolidated accumulation.

H&SC §25123.4 (b) (1) "Treatment" does not include: : 

H&SC §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.

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 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). A decision is made to discard the material in tanks A, B & C, then treat it in tank D. Points of generation

Because? (CA): 

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

Because? (CE): 

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:

Caution: 

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).

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 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? A decision is made to discard the material in tanks A, B & C, then treat it in tank D. Points of generation Yes, if waste B is added for efficient treatment. No, if waste B is added to dilute hazardous characteristics.

NO: §66268.3. Dilution Prohibited As a Substitute for Treatment : 

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).

YES: Dilution Ref: EPA 530-R-01-007 (revised August 2001): 

YES: Dilution Ref: 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.

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 Process B waste is non-hazardous. Processes A & C wastes are hazardous. Waste D isn’t hazardous, the addition of B reduced the hazardous constituents below the hazardous waste threshold. Is a treatment authorization required? A decision is made to discard the material in tanks A, B & C, then treat it in tank D. Points of generation Yes, authorization is required. Waste A & C are hazardous waste. Dilution is treatment. Additional treatment might be required to meet LDR standards. Waste Accumulation Tank. Waste D

Treatment is: 

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.

Land Disposal Restrictions (LDRs): 

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.

Slide54: 

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)

Treatment Tier Determination Treatment Units in Series: 

Settling Tank Treatment Tier Determination Treatment Units in Series Process Tank Heated Drying Tank Process Tank outflow (Waste A) Non-hazardous Non-hazardous waste water to sewer Sludge. Hazardous Waste Settling Tank sludge outflow (Waste B), hazardous waste. Q: Which waste is used to determine treatment tier, A or B? Waste B. Must have hazardous waste to have hazardous waste treatment.

Treatment Trick Question: 

Treatment Trick Question HF 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? NaOH waste HF HF+NaOH H2O+NaF D002 Waste NO. Fluoride salts are a Non-RCRA hazardous Waste.

Is the Sodium Fluoride subject to LDRs?: 

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!

Treatment Standard Determination -Waste Mixture-: 

Treatment tank Non-Haz Waste A Non-Haz Waste B Hazardous Waste C 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. Treatment Standard Determination -Waste Mixture- Hazardous Waste D

Treatment Standard Determination -Characteristic Waste-: 

Settling Tank Treatment Standard Determination -Characteristic Waste- Process Tank Heated Drying Tank Process Tank outflow (waste A). Non-RCRA, Ni > 20 mg/l STLC Pre-treated Waste water (Waste C) to POTW. Sludge, Hazardous Waste Settling tank sludge outflow (waste B), RCRA, D006 (Cd) and Non-RCRA Ni. 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.

Sludge: 

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)

Waste water No Land Disposal, No LDR: 

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.

Treatment Standard Determination -Listed Waste-: 

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

F006 Sludge : 

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

Commingling (diluting) Hazardous Waste: 

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

Commingling Ref:EPA 530-R-01-007 (revised August 2001): 

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.

Is this Dilution Permitted?: 

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.

Is it Treatment?: 

Is it Treatment? H&SC §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.

Do LDRs Apply?: 

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.

Recycling & LDRs: 

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

Short Break: 

Short Break Take 5 John Misleh, next speaker.

Point of Generation: 

Point of Generation Tanks & Containers

Hazardous Waste Determination & Point of Generation (POG): 

Hazardous Waste Determination & Point of Generation (POG) B Process Tank 2 Process Tank 1 Heated Drying Tank Process Tank outflow (waste A). Non-hazardous Non-hazardous waste water to sewer. Sludge (waste B) hazardous waste. Settling tank sludge outflow (waste C) hazardous waste. Q: Where is the point of generation? A or B or C? A: The outflow from the Process Tank - Waste C – is hazardous and is the POG.

Hazardous Waste Determination & Point of Generation (POG): 

Hazardous Waste Determination & Point of Generation (POG) B Settling Tank Process Tank Heated Drying Tank Process Tank outflow (waste A). Non-hazardous Non-hazardous waste water to sewer. Sludge (waste B) hazardous waste. Settling tank sludge outflow (waste C), hazardous waste. Q: Where is the point of generation? B or C? A: The settling tank - Waste B – is hazardous and is the POG.

Hazardous Waste Determination & Point of Generation (POG): 

Hazardous Waste Determination & Point of Generation (POG) A Settling Tank Waste Tank input Non-hazardous waste. Q: Where is the point of generation? A: The settling tank sludge is hazardous, the POG is in the tank. Sludge is Hazardous

POG in a Tank §66261.4(c) Exclusion: 

POG in a Tank §66261.4(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.

POG in a Tank: 

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

POG in a Tank: 

POG in a Tank FAXBACKs 11420 12865 11102 11588 14152

Slide78: 

(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. Chapter 32. Management of Tanks §67383.1 Applicability

Slide79: 

Management of Tanks §67383.1. Applicability Does you use this closure process? When?

Slide80: 

Use the Closure Process if : The Tank System is identified as Hazardous Waste And the Tank System is not: “Scrap Metal” Chapter 32. Management of Tanks

Hazardous Waste: 

Hazardous Waste Photo Bank Points of Generation for Hazardous Waste

Point of Generation: 

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

Slide83: 

Drum Washing Point of Generation?

Slide84: 

Drum Washing Point of Generation? When rinsate exits the process unit When rinsate exits the drum The empty drum is the POG The drum is not California empty

Slide85: 

Drum Washing Point of Generation? When rinsate exits the process unit When rinsate exits the drum The empty drum is the POG What if the drum is California empty?

Slide86: 

Drum Washing Point of Generation? What if the drum is California empty? Is the Drum Washing still Tiered Permitting? How about rinsing 5 gallon pails?

Slide87: 

Process Tanks Point of Generation?

Slide88: 

Process Tanks Point of Generation? When solution is removed as a waste Is a product not a waste? When solution remains in non-operational equipment for >90 days When solution remains in non-operational equipment for > 1 year

Slide89: 

HCl Bottling Area Poly Tank Point of Generation?

Slide90: 

HCl Bottling Area Poly Tank Point of Generation? Exit point from tank The sump When removed from the sump

Slide91: 

Floor of Plating Shop Point of Generation?

Slide92: 

Floor of Plating Shop Point of Generation? Floor is part of process, not a waste

Floor of Plating Shop Point of Generation?: 

Floor of Plating Shop Point of Generation? Floor is part of process, not a waste

Floor of Plating Shop Point of Generation?: 

Floor of Plating Shop Point of Generation? Haz. Material/Waste Dropped on the Floor

Slide95: 

Floor of Plating Shop Point of Generation? Leaking Nickel Tank

The Waste Determination Treatment Tier Land Disposal Restrictions are all based on: 

The Waste Determination Treatment Tier Land Disposal Restrictions are all based on The Point of Generation

Ten minute Break: 

Ten minute Break