Site: Palo Alto, CA Generator Status: Small Quantity Generator (SQG) EPA ID# : CAL000004385
Generator Status Variations State hazardous wastes are included in generator status calculations. Exemption: recycling / reuse on-site (see attached).
Storage Accumulation Time Limits 180 days for SQG if 200 miles to TSDF.
Satellite Accumulation Time Limits If > 220 lb/month haz. waste generated, then accumulation time begins the first day waste is accumulated.
Storage Inspection Requirements Weekly inspections
Satellite Inspection Requirements Weekly inspections
Fire Drill Requirements Minimum annually. To be arranged with local fire/emergency response authorities
Reporting Requirements Report waste generating activity biennially to DTSC by March 1 of each even numbered year.
Waste Minimization Requirements >26,460 lbs hazwaste per year: waste minimization report required March 1 every 4 years and progress reports every 2 years. See attached.
State Manifest Requirements State forms required. 30-days to receive TSDRF copy back. Out-of-state shipments: make copy of returned TSDRF copy and send to DTSC w/in 30 days
State Recycling Requirements Notification required if recycling > 220 lbs. / month. Empty containers > 5 gals. are regulated (see attached for specific procdures). Disposal of > 25 fluorescent tubes or lamps w/mercury is subject to all hazardous waste
regs.
Other Requirements / Comments Universal Waste Regulations are currently under review by State. See attached for more details on CA haz waste rules.
Waste Name Classification Refer Profile Cost Proper Shipping Name DOT ERG Disposal EPA /State Service Center Approved Manifest
(HW/NHW) to No. (All Items) Label # Method Waste Codes TSDRF Distribution
Section Requirements
Disposal Shipping
Waste Ink HW if disposed 9.1.2 $150.00/55 $45.00/55 Non-RCRA Hazardous Waste, Liquid N/A NA Fuel Blend CA343 Fremont, CA ONYX Use CA Manifest:
----------------------------------------------------------- ------------------ Azuza, CA Copy to CA State
Non-RCRA Hazardous Waste, Solid CA352
- See attached for NHW if recycled 9.1.1 Waste Ink - To Be Recycled N/A N/A Recycle N/A
recycling requirements on-site
- Maintain records of
amount recycled
Waste Solvents HW 9.2.2 $125.00/55 $45.00/55 Waste Flammable Liquid, n.o.s, 3, UN1993, Class 3 N/A Fuel Blend D001 Fremont, CA ONYX Use CA Manifest:
PG III Azuza, CA Copy to CA State
Silver Flake HW 9.3.2.1 Non-RCRA Hazardous Waste, Solid N/A N/A Reclaim CA171 Cooke Resources ECS Refining Use CA Manifest:
(silver flake) Co. Santa Clara, Copy to CA State
CA
Steel Wool Canisters HW 9.3.2.2 Non-RCRA Hazardous Waste, Liquid N/A N/A Recycle CA171 Cooke Resources ECS Refining Use CA Manifest:
(steel wool canisters) Co. Santa Clara, Copy to CA State
CA
Waste Film NHW 9.3.3 Waste film - to be recycled N/A N/A Recycle N/A N/A Bill of Lading
Shop Towels NHW- if 9.4 Shop towels - to be laundered N/A N/A Laundered N/A N/A Bill of Lading
laundered
Waste Oil HW 9.5.2 $75.00/55 $45.00/55 Non-RCRA Hazardous Waste Liquid N/A N/A Fuel Blend CA221 Fremont, CA ONYX Use CA Manifest:
(used Oil) Azuza, CA Copy to CA State
Fluorescent Light HW 9.6.2 $42.00/4-ft $35.00/4-ft Hazardous Waste Solid, n.o.s. (mercury), 9, Class 9 31 Recycle D009 Fremont, CA Superior/Sales Use CA Manifest:
Bulbs (w / mercury) fiber & & 8-ft NA3077, PGIII co Copy to CA State
$84.00/8-ft fiber drum Phoenix, AZ
fiber drum
NHW - if tested 9.6.1 $42.00/4-ft $35.00/4-ft Non-RCRA Hazardous Waste, Solid N/A N/A Recycle CA181 Fremont, CA Superior/Sales Use CA Manifest:
below TCLP fiber & & 8-ft (spent bulbs for recycling) co Copy to CA State
limits $84.00/8-ft fiber drum Phoenix, AZ
fiber drum
Waste Batteries, NICad NHW if recycled 9.8.2 $1.80/lb $25.00/5 Hazardous Waste Solid, n.o.s., (cadmium), 9, Class 9 31 Recycle D006 Fremont, CA Kinsbursky Bill of Lading
& NA3077, PGIII Bros or Manifest
$30.00/14 Anaheim, CA
Waste Batteries, NHW - follow 9.8.2 $0.85/lb $25.00/5 Non-Regulated Material N/A N/A Recycle N/A Fremont, CA Kinsbursky Bill of Lading
Alkaline HW rules for & (spent alkaline batteries for recycling) Bros or Manifest
accumulation $30.00/14 Anaheim, CA
Waste Mercury HW 9.9.2 $400.00/5 $30.00/5 Hazardous Waste Solid, n.o.s. (mercury), 9, Class 9 31 Recycle D009, Fremont/, CA Superior/Sales Use CA Manifest:
Thermostats NA3077, PGIII, CA725 co Copy to CA State
Phoenix, AZ
Last Revision: 1/25/01 HWMP, Site Specific HW Matrix, Appendix 1
Lead Acid Batteries NHW if recycled 9.10 $0.45/lb $125.00/5 Batteries, Wet, Filled with Acid, 8, UN2794, Class 8 60 Recycle N/A Fremont, CA Kinsbursky Bill of Lading
(50 ppm 9.11 $1.30/lb $95.00/55 RQ Waste Polychlorinated Biphenyls, 9, Class 9, 31 Incinerate CA262 or Fremont, CA ONYX-PTA Use CA Manifest:
UN2315, PGII PCB CA731 Port Arthur, Copy to CA State
TX
NHW if labeled 9.11.3 $0.85/lb $75.00/55 Non-Regulated Material N/A N/A Recycle N/A Fremont, CA Superior/Sales Bill of Lading
“No PCBs” (spent light ballasts for recycling) co
Phoenix, AZ
Asbestos Reg. under 9.12 Asbestos-containing waste Asbestos Landfill CA151 N/A Contact E&S
NESHAPS Label
Empty Drums NHW – Must be 9.13 $25.00/each $10.00/ Non-RCRA Hazardous Waste N/A N/A Recycle ? Fremont, CA Western Bill of Lading ?
(see attached for RCRA & CA each (empty container, last contained ????) Container
specific procedures) empty
Ethylene Glycol NHW $75.00/55 $45.00/55 Non-RCRA Hazardous Waste, Liquid N/A N/A Recycle CA343 Fremont, CA ONYX Use CA Manifest:
(waste anti-freeze) Azusa, CA Copy to CA State
Absorbent with NHW Non-RCRA Hazardous Waste, Solid N/A N/A Landfill CA352 Use CA Manifest:
Hydraulic Fluid Copy to CA State
Nar-Coil Concentrate HW Waste Corrosive Liquid, Acidic, Inorganic, Incinerate Use CA Manifest:
(spent acid) n.o.s (Hydrofluoric/phosphoric acid), 8, Class 8 60 CA791 Copy to CA State
UN3264, PG II, RQ (D002)
Last Revision: 1/25/01 HWMP, Site Specific HW Matrix, Appendix 1
California State Requirements
Universal Waste Regulations
Noel Laverty of Dept. of Toxic Substance Control was contacted. Currently under review by
the department.
Empty Containers
California has a more stringent definition of an empty container. A container or liner must
meet the following criteria to be considered empty:
1) If the hazardous material is a liquid, the container is considered empty, if no material
can be drained from the drum by tilting, inverting, etc.
2) If the hazardous material is a solid or powder, the container is considered empty if no
material can be removed by any means (excluding rinsing) commonly employed to
remove such materials. No significant buildup of hazardous material may be evident
on or in the container.
3) If the container held an acute hazardous waste, it must be triple rinsed prior to disposal.
Empty containers must be handled according to the following guidelines:
1) if the container is 5 gallon capacity and not exempted should be:
1) Marked "Empty" with the date the container was emptied, and
2) Placed in the Hazardous Waste Storage Area prior to shipment to the designated
TSDRF.
PCBs
The state considers any PCB contaminated material as hazardous if it contains >5 ppm PCBs
irrespective of its form or condition. Material containing <5 ppm PCB may be considered non-
hazardous.
Recycling/Reclamation Requirements
Note: Recyclable Material is subject to state hazardous waste control laws. However, materials
destined for recycle must be included in generator status calculations but are not included for certain
reporting requirements discussed below (Waste Minimization Report).
1. Hazardous Waste Ink and Silver-Bearing Solutions
All recycling activities are subject to state department review. Permits are generally required,
although the state may allow certain site specific exemptions. See your ⌠Operations Manual≈
for on-site treatment of silver solutions from the film processors
2. Non-RCRA Waste (Waste Ink)
Non-RCRA wastes recycled on-site are exempted from permitting and inclusion in generator
status calculations provided they are:
a) reused at the same facility,
b) labeled and marked "Excluded Recyclable Material."
c) included in the site Business Plan,
d) stored an handled in accordance with local ordinances / codes, and
e) if you recycle more than 220 lbs / month, you must notify the local health officer in
writing.
Waste Minimization Reports
Waste minimization reports are due once every 4 years by March 1. Reports are required for
generators of over 26,460 lbs of hazardous waste per year. The quantity triggering the report
threshold does not include materials exempted from full hazardous waste regulations. Materials
destined for recycling are an example of material that need not be included in generation quantities.