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l.,.alcupa Forum Notices: m037.h'-n Page 1 of 2 <br /> cal-cupa forum notices <br /> Letter to Paula Rasmussen <br /> June 22, 1999 <br /> June 22, 1999 <br /> Paula Rasmussen,Chief <br /> State Regulatory Programs Division <br /> Department of Toxic Substances Control <br /> 5796 Corporate Avenue <br /> Cypress, CA 90630 <br /> Dear Ms. Rasmussen: <br /> SUBJECT: CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR <br /> COMPLIANCE -SILVER WASTE <br /> Senate Bill 2111 (Costa)requires wastes containing silver or silver compounds to be <br /> regulated in California only to the extent those wastes are regulated under Resource <br /> Conservation and Recovery Act(RCRA). As a result, requirements for the facilities which <br /> qualify as Conditionally Exempt Small Quantity Generators (CESQG) under federal statute <br /> have been extensively minimized from California mandates. <br /> CESQGs are businesses that generate no more than 100 kg(220 lbs)per month of a RCRA <br /> hazardous waste. As a CESQG, a business is exempt from hazardous waste management <br /> regulations provided that specific requirements are met. A CESQG must conduct a <br /> hazardous waste determination to identify their waste, they may not store more than 1,000 <br /> kg (2,200 lbs)of waste at any one time, and they must provide documentation that the <br /> hazardous waste is either delivered to a certified offsite treatment or disposal facility or that <br /> proper on-site treatment of the hazardous waste is conducted. <br /> A CESQG is not required to obtain an EPA I.D.number,transport waste using a manifest or <br /> a registered transporter, nor are they required to maintain contingency plans and conduct <br /> employee training. <br /> Due to the exemptions these facilities are afforded,the California CUPA Forum Board is <br /> proposing an innovative compliance program for these CESQG silver facilities. This <br /> compliance program would require facilities to: <br /> 1. Attend a certificate training course regarding their responsibilities as CESQGs and the <br /> requirements to maintain their status. <br /> http://www.calcupa.net/notices/nt037.htm 12/7/00 <br />