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<br /> <br />www.erm.com Project No.: 0565667 Client: Amazon.com Services LLC 17 December 2020 <br />22 CCR 67100.5 Section Citation <br />Description <br />Location in <br />Source Reduction Plan <br />67100.5 (j) An evaluation of source reduction <br />measures available to the generator <br />which are potentially viable. The <br />evaluation shall consider at least all of the <br />following approaches: <br />(j)(1) Input changes <br />(j)(2) Operational improvement <br />(j)(3) Production process changes <br />(j)(4) Product reformulation <br />(j)(5) Administrative steps taken to reduce <br />hazardous waste generation including but <br />not limited to: <br />(j)(5)(A) Inventory control <br />(j)(5)(B) Employee award programs <br />(j)(5)(C) Employee training <br />(j)(5)(D) In-house policies <br />(j)(5)(E) Corporate or management <br />commitment <br />(j)(5)(F) Other programs or measures <br />Page 9 <br />67100.5 (k) Consideration of the following factors for <br />each measure evaluated in accordance <br />with subsection (j) of this section (where a <br />specific factor does not apply identify as <br />N/A): <br />(k)(1) Expected change in the amount of <br />hazardous waste generated <br />(k)(2) Technical feasibility <br />(k)(3) Economic evaluation: <br />(k)(3)(A) Capital cost, operating cost, <br />waste management cost <br />(k)(3)(B) Return on investment (ROI), <br />breakdown point, avoided cost, pre-tax <br />payback period, or any other economic <br />comparison method <br />(k)(4) Effects on product quality <br />(k)(5) Employee health and safety <br />implications <br />(k)(6) Permits, variances, compliance <br />schedules of applicable state local and <br />federal agencies <br />(k)(7) Release and discharges <br />Page 9 <br />67100.5 (l) Any pertinent information, such as waste <br />stream constituents and concentration of <br />constituents, needed to evaluate and <br />implement source reduction measures. <br />Pages 7 – 8 , Table 3 <br />67100.5 (m) A specification of, and a rationale for, the <br />technically feasible and economically <br />practicable source reduction measures <br />which will be taken by the generator with <br />respect to each hazardous waste stream <br />identified in subsection (h) of this section. <br />The specification should include at a <br />minimum, a narrative description of the <br />factors in subsection (k) of this section <br />and also address system capacity and <br />efficiency. Photographs, illustrations, <br />Page 9