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Backus, Garrett [EHD] <br /> From: Backus, Garrett [EHD] <br /> Sent: Thursday, September 24, 2020 11:21 AM <br /> To: Charles Galea; Hani Yosif <br /> Cc: Saeed, Haza [EHD] <br /> Subject: RE: Aqueous Ammonia 19% SDS <br /> Hi Charles and Hani, <br /> I was looking at the yellow highlighted section in the consolidation site regulations when I suggested remote <br /> consolidation. The Tracy Booster site in San Joaquin County is a very small quantity hazardous waste <br /> generator(vSQG) as defined by the federal government. A vSQG has to identify hazardous waste and dispose <br /> of it properly but HW manifesting is not required. The ammonia waste becomes regulated as a non-RCRA HW <br /> since it's not regulated for the movement from place to place as long as it's disposed of properly. That's why I <br /> thought it qualifies for remote consolidation as defined by California law. <br /> That being said, the receiving facility is in Stanislaus County and Hani makes the call on being able to accept <br /> the waste. <br /> Garrett Backus, Ld. Sr. REHS, CUPA programs <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> Desk: (209)468-2986 Cell: (209)616-3030 <br /> Email: gbackus(cDsigov.org <br /> https://www.sigov.org/department/envhealth/ <br /> AMJOUIN <br /> CC%mM-V <br /> 25110.10. <br /> (a) "Consolidation site" means a site to which hazardous waste initially collected at a remote <br /> site, as defined in Section 25121.3, is transported. <br /> (b) Hazardous waste initially collected at a remote site and subsequently transported to a <br /> consolidation site, which is operated by the generator of the hazardous waste, shall be deemed <br /> to be generated at the consolidation site for purposes of this chapter if the generator complies <br /> with the notification requirements of subdivision (d) and all of the following conditions are met: <br /> (1) The hazardous waste is non-RCRA hazardous waste, or the hazardous waste or its <br /> management at the consolidation site is otherwise exempt from, or is not otherwise regulated <br /> pursuant to, the federal act. <br /> T40 CFR 260.10 Definition of a very small quantity generator <br /> Very small quantity generator is a generator who generates less than or equal to the following amounts in a <br /> calendar month: <br /> 1 <br />