SU0002684 - Laserfiche WebLink

Home Browse Search

Mr. Michael Serra December 22, 1999 Page 2 B) Applying knowledge in light of the materials or processes used in generating the waste. In addition, 22 CCR section 66260.200(c), allows a generator to self-classify their waste as a result of their findings as described above and manage the waste in accordance with that classification. When self-classifying their waste, a generator need not provide notification to the Department of Toxic Substances Control (DTSC) of their intention to do so. However, if a generator wishes to obtain a concurrence from DTSC pursuant to 22 CCR section 66260.200(d), the generator must submit to DTSC for review that information which is required by 22 CCR section 66260.200(m). Until the DTSC completes its assessment of the information submitted in support of a concurrence pursuant to 22 CCR section 66260.200(d), the generator of the waste must manage the waste as hazardous waste. In this particular case, you and Mr. Murillo presented me with a packet of various types of information related to the fly ash. Much of it was informational in nature, but included only a limited amount of analytical data. While no final conclusion with respect to the characteristics of the fly ash can be drawn from the analytical data presented, it appears to indicate (on a preliminary basis) that the fly ash may not exhibit the federal Toxicity Characteristic (TC) as measured by the Toxicity Characteristic Leaching Procedure (TCLP) pursuant to 22 CCR section 66261.24(x)(1), nor exhibit the characteristic of corrosivity pursuant to 22 CCR section 66261.22(a)(3). As I mentioned in our December 1 meeting that a more comprehensive evaluation or analysis of the fly ash may be warranted. More specifically, Chapter 11 ,Division 4.5, 22 CCR outlines the requirements and criteria to determine when a waste is identified as a hazardous waste. The Chapter 11 criteria include the characteristics of toxicity (acute and chronic), reactivity, ignitability, and corrosivity. If the waste exhibits one or more of these aforementioned characteristics, the waste is classified as hazardous waste and must be managed as such. Therefore, to ensure that the fly ash is properly characterized, I would recommend that the following analytical testing be performed or continue to be performed on a minimum of four representative samples of the fly ash: 1) The TC as measured by the TCLP pursuant to 22 CCR section 66261 .24(a)(1); 2) The characteristic of corrosivity (for solids) pursuant to 22 CCR section 66261.22; 3) The characteristic of acute toxicity as measured by the aquatic bioassay pursuant to 22 CCR section 66261.24(a)(6); 4) A measurement of the total concentration of the persistent and bioaccumulative toxic substances pursuant to 22 CCR section 66261 .24(a)(2)(A);and, 5) A measurement of the soluble concentration of the persistent and bioaccumulative toxic substances as measured by California's Waste Extraction Test (WET) pursuant to 22 CCR section 66261.24(a)(2)(A).