EH&S Compliance, Training and Data Management Solutions

---

Tuesday, May 8, 2007

Greetings EH&S Clients and Colleagues:

Are you a large quantity generator of hazardous waste subject to the upcoming SB 14 planning and reporting requirements due by September 1 2007?

Applicability Thresholds:  Are You Required to Prepare the SB 14 Documents?

SB 14 applies to a generator that, by site, routinely generates, through ongoing processes and operations, more than 12,000 kilograms of hazardous waste in a reporting year, or more than 12 kilograms of extremely hazardous waste in a reporting year. It includes hazardous waste regulated by Title 40 Code of Federal Regulations (40CFR), as legislated in the federal Resource Conservation and Recovery Act (RCRA). It also includes non-RCRA California-only hazardous waste. The non-RCRA waste is not regulated as hazardous by 40CFR, but is regulated as hazardous by Title 22, California Code of Regulations (22CCR). 

Examples of waste generation that could place a generator over the threshold include:

• Five 55-gallon drums of hazardous waste per month of RCRA and/or non-RCRA hazardous wastes (e.g., waste oil, waste solvents, etc). In a year this could amount to over 12,000 kilograms of hazardous waste in a year.
• 12 kilograms of expired chemicals (which are extremely hazardous waste) such as lead cyanide, arsenic compound, beryllium compound, bromine, cadmium compound, fluoroacetic acid and salts.

Exempt waste streams include:

• Motor vehicle fluids and motor vehicle filters
• Lead acid batteries
• Household hazardous wastes, wastes from household collection events, and wastes separated at community landfills
• Waste pesticides and pesticide containers collected by county agricultural commissioners
• Spent munitions and ordinance
• Decommissioned utility poles
• Oil generated from decommissioned refrigeration units
• Mercury relays and low-level radioactive tubes generated from removal of telephone equipment.
• Lighting wastes including ballasts and fluorescent tubes.
• Waste from site cleanup and mitigation activities, including remedial investigations
• Samples and evidence from enforcement actions
• Asbestos
• Polychlorinated biphenyls (PCBs)
• Formation fluids and solids from oil, gas, and geothermal exploration and field development
• Recent legislation expands the geothermal drilling waste exemption to include (under certain conditions) wastes generated from the exploration, development, or production of geothermal energy (Senate Bill 1294, Chapter 143, Statutes of 2006).
• Demolition waste/major renovation waste
• Waste generated from emergency response actions
• Waste generated from laboratory scale research
• Medical waste

Required SB 14 Documents

A generator who is subject to SB 14 must prepare documents that describe the source reduction program the generator has developed and is implementing. For the reporting year 2006, the following documents must be prepared by September 1, 2007:

1. Source Reduction Evaluation Review and Plan (Plan)

2. Hazardous Waste Management Performance Report (Performance Report)

3. The Summary Progress Report (SPR)

Additionally, the Summary Progress Report (SPR) must be completed by the generator

and submitted to the DTSC Office of Pollution Prevention and Technology Development

(OPPTD) on or before September 1, 2007. Waste Manifests are required to be used on September 5.

An Easy Way to Comply

Contact me and I would be happy to provide you a quotation for assessing your hazardous waste management practices and preparing the SB 14 documents for you. I have over 15 years of experience in the field and a thorough understanding of hazardous waste management laws and regulations.

Other commonly requested services include: 

• DOT and IATA Hazardous Materials for Shippers
• Bloodborne Pathogens (annual requirement)

• Hazard Communication

• Chemical Hygiene Plan

• General Safety

• Biological Safety

• Radiation Safety

• Many others, please contact me

Served by an Expert in the Field

My credentials include:

• 15 years of experience assisting public and private companies to comply with environmental and safety laws and regulations

• MS in chemistry from University of California, Berkeley

• Certified Hazardous Materials Manager (Masters Level)

• Registered Environmental Assessor

Please feel free to contact me about other services at 650-347-0417 or email at art@hazardsolutions.com.

Kind Regards and Good Luck

Arthur Mahoney, MS, CHMM, REA
Hazard Solutions LLC
326 Sonora Drive, San Mateo, CA 94402

phone: 650-996-3228
fax: 650-963-3250
email: art@hazardsolutions.com
website: www.hazardsolutions.com

--EHS Compliance, Training and Data Management Solutions—