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1 . INTRODUCTION ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- 1 .1. PURPOSE Dragon Products,LLC. (Dragon)has prepared this Source Reduction Evaluation Review and Plan (Plan)to comply with the 1989 Hazardous Waste Source Reduction and Management Review Act("Act")under California Senate Bill 14. 1.2. REGULATORY BACKGROUND In September 1989,California adopted the Hazardous Waste Source Reduction and Management Review Act ("Act") under California Senate Bill 14. The Act applies to all generators that,by site,routinely generate, through ongoing processes and operations,more than 12,000 kilograms (26,400 lbs)per year of hazardous wastes,or 12 kilograms (26.4 lbs)per year of extremely hazardous waste in a reporting year. The Act requires subject facilities to examine current waste generating activities,evaluate source reduction measures, and create action plans to implement feasible measures. The Act exempts certain non-routinely generated hazardous wastes and other waste streams from the applicability determination. A generator subject to SB 14 must prepare a Hazardous Waste Source Reduction Evaluation Review and Plan ("Plan"),Hazardous Waste Management Performance Report("Performance Report"),and Summary Progress Report("SPR")by September 1,2015. Under SB 14,a generator considers only hazardous waste generated during the"reporting year'when determining if either applicable threshold is exceeded. "Reporting year"is the calendar year immediately preceding the year in which a source reduction document is to be prepared. In other words,the report due in 2019 is based on the hazardous wastes generated in calendar year 2018. The Act only requires that source reduction measures be implemented for"major"waste streams. Major waste streams are those that constitute at least 5%of a facility's hazardous waste inventory. Once completed all required SB 14 documents must be maintained onsite and provided upon request by regulatory authorities. 1 .3. REQUIRED DOCUMENTS SB 14 requires a Plan,Performance Report and SPR for all applicable major waste streams for the subject Reporting Year. The Plan must include an estimate of the quantity of hazardous wastes generated,an evaluation of potential source reduction approaches,a timetable for implementing selected source reduction measures and a four year amount. The Plan must also address the predicted effectiveness of selected measures at reducing hazardous waste and releases to all environmental medium (the air,land and water). The SB 14 Performance Report must include an assessment of the effect on waste generation of each waste management approach implemented since the base line year,including source reduction,recycling and treatment measures. The Performance Report includes discussions of the generator's approaches to managing hazardous waste including source reduction,on-site and off-site recycling,treatment and disposal. The Performance Report should contain sufficient detail to convey an understanding of the hazardous waste management approaches used at the site. The use of narratives,photographs,illustrations,figures and data is encouraged. Note that a generator who qualifies as a small business,and who is also required by 22 CCR Section 66262.41 to prepare a USEPA biennial generator report(BGR),may use the most recent BGR as the Performance Report required by SB 14. The Summary Progress Report summarizes the results of implementing the source reduction measures identified in the generator's previous Plan and the amount of reduction that the generator anticipates will be achieved by the implementation of source reduction measures selected in the current Plan. Dragon Products, LLC. I SB 14 Source Reduction Evaluation and Review Trinity Consultants 1 1