COMPLIANCE INFO_2020 - Laserfiche WebLink

Home Browse Search

Backus, Garrett From: Backus, Garrett Sent: Thursday, May 7, 2020 5:33 PM To: 'Mike Ubick' Cc: Baker, Lydia; Manzo, Elena K. Subject: RE: source reduction plan Attachments: GuidanceManualRevised-2 2010.pdf,T22 CCR 67100.2 exemptions.pdf,T22 CCR 67100.1 thru 14.pdf, T22 CCR 67100.14 Trade Secrets.pdf,T22 CCR 67100.13 Certification Requirements.pdf Mike, I've answered your questions below in red. See the attached guidance manual —I am directing you to specific sections. I also attached the entire regulation. Garrett Backus, Ld. Sr. RENS, CUPA programs San Joaquin County Environmental Health Department 1868 E Hazelton Ave, Stockton, CA 95205 (209)468-2986 gbackus()sigov.orq https://www.sigov.org/departmenVenvhealth/ A" From: Mike Ubick<mubick@PACIFIC.EDU> Sent:Thursday, May 7, 2020 10:31 AM To: Backus, Garrett<gbackus@sjgov.org> Subject: RE: source reduction plan Garrett: Thank you for the information. Just for background,we do not routinely generate more than 12,000 kg of hazardous waste, but we do generate more than 12kg of extremely hazardous waste a year. The waste is almost exclusively generated by student/teaching and research labs, not by any production or routine processes (other than teaching). Here are some remaining question I have. Most are yes/no. 1. Given we only meet the threshold for Extremely Hazardous Waste (over 12 kg), do we still need to include the large waste streams over 600kg and 5%even though we do not generate more than 12,000 kg of hazardous waste? If a waste is not exempted in Guidance Manual section 2.3 then include in the report. Please also see the attached T22 CCR 67100.2 for details about exemptions. 2. Are we able to mark all the extremely hazardous waste chemicals as confidential under the confidentiality guidance?According to section Guidance Manual section 8.2 and attached T22 CCR 67100.14, any information may be claimed confidential. We'll need to get two copies, one with the confidential pages included and one without. The confidential copy will be kept in the EHD files as "confidential" and not released to the public. The copy with the confidential pages removed will be available for public review. 3. 1 have been summarizing all the data from 2019 to 2017 and can include 2016 if needed. Should I be looking at 2018 only, or another specific window of years? What years are required to be included?The report is due every four years. The reporting years are 2010, 2014, 2018 etc. The report is due to be completed by 1