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Message Page 1 of 2 <br /> Michelle Henry [EH] <br /> From: Michelle Henry [EH] <br /> Sent: Tuesday, November 27, 2007 3:14 PM <br /> To: 'Larry Moothart' <br /> Subject: RE: HSC 25143.12 <br /> Larry, <br /> After further review and discussion with my program coordinator, we have decided this exemption can <br /> be applied to the disposal of these vapor recovery and vent lines only. <br /> I want to emphasize this exemption does not apply to ANY product piping as HSC section 25281(y)(1) <br /> defines pipe storing hazardous substances as underground storage tanks. Additionally, AB 2481 <br /> added vapor recovery, vent lines, and fill pipe to the definition of pipe as of July 1, 2003. <br /> Thank you <br /> Michelle Henry, REHS <br /> From: Larry Moothart [mailto:Larry@ belshire.com] <br /> Sent: Tuesday, November 27, 2007 10:55 AM <br /> To: Michelle Henry [EH] <br /> Subject: HSC 25143.12 <br /> Ms. Henry, <br /> The petroleum debris exemption was sponsored by WSPA in Senate Bill 1648 and is now law as identified <br /> in the California Health and Safety Code section 25143.12. <br /> This exemption allows for the disposal of non hazardous debris, which has been contaminated with <br /> petroleum or any of its fractions, into Class I or II solid waste landfills as a non-hazardous waste. The <br /> debris must meet all of the following requirements: <br /> a) is wood, paper, textiles, concrete rubble, metallic objects, solid manufactured objects. Pipe Qualifies as <br /> a solid manufactured product <br /> b) not Federally regulated qualifies under the exemption in 40 CRF 261.4 (b) 10 <br /> c) does not contain free liquids would pass the paint filter test <br /> d) if not contaminated with petroleum, the debris would not be regulated as a hazardous waste there is <br /> nothing present in or on the pipe that would make it hazardous if it wasn't contaminated with petroleum <br /> e)debris is not a container or tank not one of these <br /> f)disposed in a class I or II landfill Buttonwillow is a class I <br /> We have managed pipe from many UST sites into the Clean Harbors Buttonwillow landfill as non <br /> hazardous under this exclusion. We propose to manage this pipe as non hazardous to the Buttonwillow <br /> landfill. This pipe qualifies for this exemption because the pipe is satisfies all of the conditions as stated <br /> above. <br /> Please let me know your thoughts. <br /> Thanks <br /> 11/28/2007 <br />