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Haza <br /> From: Garrett Backus [EH] <br /> Sent:Wednesday, March 15, 2017 11:41 AM <br /> To: Haza Saeed [EH] <hsaeed@sicehd.com> <br /> Subject: metal fines hazardous waste determination <br /> Metal fines hazardous waste determination information is below. Please refer to California Code of Regulations and the <br /> California Health &Safety code and the Code of Federal Regulations for the exact and most complete requirements: <br /> 1. Business owners are required to make a hazardous waste determination for all wastes generated by their <br /> shop. They can use generator knowledge (Title 22 CCR 66262.11(c)(2)) or analytical testing (Title 22 CCR <br /> 66262.11(c)(1)). <br /> a. Generator knowledge from Safety Data Sheets, other material literature, other sources. <br /> b. Analytical testing as specified in T22 starting in T22 CCR 66261.20. Hazardous waste characteristics are <br /> Toxicity, Reactivity, Ignitability, and Corrosivity. Hazardous waste can also be on a list (listed). <br /> 2. Generator knowledge cannot be used to declare the waste as nonhazardous for brake rotor shavings since the <br /> business owner does not know the metal composition of EVERY brake rotor that come into his shop. That leaves <br /> analysis. The business owner can also declare the metal fines to be hazardous waste and handle/dispose of it as <br /> hazardous waste. <br /> 3. To do analysis the business owner can sample the brake rotor shavings and send to a California ELAP certified <br /> hazardous waste lab. Here's the list of labs: <br /> http://www.waterboards.ca.gov/drinking water/certlic/labs/index.shtml <br /> a. The lab we use for analysis is Geoanalytical Laboratories, Inc. 209-669-0100. We do not recommend <br /> any specific lab. <br /> b. Metal fines including brake rotor shavings need a particle size test to determine if any of the metal fines <br /> are less than 100 microns in size. <br /> c. If all of the metal fines are larger than 100 microns then it can be sent to a metals recycler as allowed by <br /> T22 CCR 66261.6(a)(3)(B) and 66260.10. No hazardous waste disposal manifest needed but it cannot be <br /> disposed of in the trash. The business owner should keep proof of recycling. <br /> d. If any of the fines are less than 100 microns in size then we need a hazardous waste characteristic test <br /> for Toxicity. We limit the Toxicity testing to the most likely hazardous components which are hazardous <br /> metals. Hazardous waste metals listed in T22 CCR 66261.24 are Antimony, Barium, Beryllium, Cadmium, <br /> Chromium 6, Chromium, Cobalt, Copper, Lead, Mercury, Molybdenum, Nickel,Selenium,Silver, <br /> Thallium,Vanadium,Zinc. The listed metals have threshold values above which they are hazardous. <br /> e. First TTLC testing is done (T22 CCR 66261.24(a)(2)(A)) (also called CAM-17 testing). If the TTLC results <br /> exceed the TTLC limits then we have hazardous waste and the determination is finished. Otherwise, if <br /> the TTLC results for any metal are 10X greater than the STLC limit then a STLC test is <br /> required. Otherwise, if the TTLC results for any metal are 20X greater than the federal regulatory limit <br /> (T22 CCR 66261.24(a)(1)(B)) then a TCLP test is required. <br /> f. TTLC test results that exceed the TTLC limit are non-RCRA hazardous waste. STLC test results that <br /> exceed the STLC limit are non-RCRA hazardous waste.TCLP test results that exceed the TCLP limit are <br /> RCRA hazardous waste. All require a full hazardous waste manifest for disposal. <br /> 2 <br />