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Generators treating their waste under PBR are ex- If you are treating hazardous wastes in tanks, you empt from the requirement to have third party liability must follow the interim status standards for storage coverage for environmental accidents. or treatment of hazardous wastes in tanks and tank systems found in Article 10 of Chapter 15 (Title 22, Generators operating under PBR are required to CCR, §66265.190 through §66265.200). obtain financial assurance for closure of their autho- rized units by October 1, 1996. The financial assur- DTSC encourages annual integrity tests and uti- ance mechanism must be submitted to your local CUPA lization of secondary containment for treatment by January 1, 1997, or DTSC, if there is no local CUPA. tanks. However, new emergency regulations, adopted June 16, 1995, delayed the deadlines for requirements for tanks that are not regulated under federal regulations, including all onsite treatment and recycling tanks. • Pursuant to HSC §25205.14(a), the initial notifica- tion fee for PBR is $1236 in 1996, which will be billed For non-RCRA regulated tanks, January 1, 1998 to your company by the California Board of Equaliza- is the new deadline for providing an integrity test. tion (BOE), (a state tax collection agency)_ The new deadline for providing secondary contain- ment is also January1, 1998, and this delay also • Every calendar year thereafter, you will be billed by applies to new tanks as well. The secondary con- BOE, an annual fee in the amount of$1236 (adjusted tainment requirement may be permanently changed annually for inflation). in the future. DTSC is studying alternative tank stan- dards as part of the Regulatory Structure Update • You will also be billed by BOE for an amended fee (RSU) process. (50% of the annual fee) for each amended notification you submit. CORRECTIVE ACTION: • SB 1291 changed the onsite treatment fee system. Corrective Action includes assessing the property so that companies will only pay a fee on the highest for any previous release of hazardous wastes (us- tier they operate. Previously, a separate fee was ing the Phase I Environmental Assessment Check- charged for each tier. list)and cleaning up any contamination posing a risk to public health and the environment. Upcoming Change • By January 1, 1997, most of DTSC's responsibili- State law, as amended by SB 1222 (1995), re- ties to implement the generator and onsite treatment quires submittal of a Phase I Environmental Assess- programs will be transferred to the CUPAs who will es- ment Checklist to DTSC by January 1, 1997 (HSC tablish appropriate local fees to support their Unified §25200.14 (a)), or within one (1) year of initial au- Program. DTSC's onsite Tiered Permitting fees will be thorization, whichever date is later. All CA genera- eliminated in jurisdictions where CUPAs are certified. tors and PBR facilities will be notified if there is a You will be notified by the local CUPA as these change in the deadline and provided with guidance. certifications occur. DTSC is also mandated by state law, AB 483 (1995), to study whether the Phase I Environmental CONTAINERS: Assessment Checklist should be limited to the regu- If you are treating hazardous wastes in containers, lated units only. The same study will examine you must comply with §66264.175 of Title 22, CCR, whether information in the Phase I Environmental and with the interim status standards for container stor- Assessment Checklist should be publically acces- age and treatment found in Article 9 of Chapter 15(Title sible or maintained as confidential information, in- 22, CCR, §66265.170 through §66265.177). This in- accessible to both the public and other governmen- cludes, but is not limited to, secondary containment for tal agencies. all container transfer and storage area(s), proper man- agement of the container(s)to prevent leaks and weekly inspection of the storage area.