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t <br /> STATE OF CALIFORNIA—ENVIRONMENTAL PRO AGENCY PETE WILSON,Governor <br /> DEPARTMENT OF TOXIC SU .W NCES CONTROL <br /> .100 P Street.4th Floor <br /> s <br /> P.O.Box 806 <br /> Sacramento,CA 95812-0806 <br /> (916) 323-6042 <br /> February 18, 1993 <br /> Ms. Phoebe C. Robb, Corporate Environmental Engineer <br /> Dopaco, Incorporated <br /> 479 Thomas Jones Way, Suite G <br /> Exton, Pennsylvania 19341 <br /> WASTE STREAM RECLASSIFICATION <br /> Dear Ms. Robb: <br /> Thank you for your letter dated December 15, 1992 , to <br /> Ms. Corey Yep of the Department of Toxic Substances Control <br /> (Department) in which you informed us of your intention to self- <br /> classify your off-press make ready (OPMR) wastestream as <br /> nonhazardous. Your letter was referred to me for response. <br /> Notification to the Department of a wastestream <br /> classification is not required. Generators may self-classify <br /> their waste as hazardous or nonhazardous pursuant to Section <br /> 66260. 200 (c) , Title 22 , California Code of Regulations <br /> (22 CCR) , and manage it in accordance with that classification <br /> without notification to the Department. A generator may also <br /> formally request the Department to concur with their <br /> classification pursuant to Section 66260. 200 (d) , 22 CCR. To <br /> obtain a Departmental concurrence, the generator must submit <br /> information which includes, but is not limited to, a description <br /> of the waste, sampling methods used, testing laboratory <br /> information, and analytical results. For such a concurrence, the <br /> State Board of Equalization will assess a fee (currently $8,550 <br /> per wastestream) . <br /> To determine if your wastestream is regulated as a hazardous <br /> waste under the federal Resource Conservation and Recovery Act <br /> (RCRA) , you must first determine if the waste is from a specific <br /> or non-specific source as listed in Subpart D, Part 261, Title <br /> 40, Code of Federal Regulations (40 CFR) . It must then be <br /> determined whether the waste exhibits the federal characteristics <br /> of corrosivity, ignitability, reactivity, or toxicity as <br /> contained in Part 261., Subpart C, 40 CFR. If the waste is listed <br /> under Subpart D or exhibits one or more characteristic under <br /> Subpart C, the waste must be classified and managed as a RCRA <br /> hazardous waste, absent a specific exclusion under federal <br /> regulations. <br />