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MEMO pollutants to the environment. The regulations specify the format for documenting a careful review and evaluation of potential source reduction measures, rather than the waste management actions that must be taken. SB 14 APPLICABILITY SB 14 applies to a generator that, by site, routinely generates, through ongoing processes and operations, more than 12,000 kilograms (26,400 pounds) of hazardous waste in a reporting year, or more than 12 kilograms of extremely hazardous waste in a reporting year. The total quantity of waste generated at STR 1022 in 2018, prior to exemption considerations, was 39,346 pounds, 12,946 pounds above the applicability threshold. EXEMPTED WASTE DTSC exempts a waste stream from the specific requirements of SB 14 (but not from the management requirements of other Articles of 22 Code of California Regulations [CCR]) if the waste has no source reduction opportunities or is not routinely generated. A generator does not include exempted waste streams when calculating the total weight of hazardous waste generated at a site to determine SB 14 applicability. The list of exempted wastes is found in 22 CCR 67100.2 and is included as Attachment 1. METHODOLOGY FOR EVALUATING SB 14 APPLICABILITY Arcadis reviewed the waste streams and quantity of waste generated in 2018 at STR 0662 (refer to Table 1). The majority of the waste streams generated in 2018 at STR 0662 are considered exempt and are not included when calculating the total weight of hazardous waste generated. The following exemptions were applied to waste streams generated in 2018 at STR 0662: • Hazardous wastes that are designated as universal wastes in 22 CCR 66261.9; • Lead acid batteries; • Lighting wastes including ballasts and fluorescent tubes • Waste from site cleanup and mitigation activities, including remedial investigations; and • Waste generated from emergency response actions. The federal and state-only California hazardous waste generated at STR 0662 is primarily associated with the receipt of products damaged during transport and spills that occur during movement of products within the store location. Based on a discussion with Ms. Mary Misner of DTSC (916) 255-3617, on March 11, 2014, these types of wastes generated would fall under the exemptions for"emergency response actions" or"site cleanup" and would not be considered a waste stream applicable to the SB 14. While the majority of The Home Depot's waste streams should be considered exempt, the store's operations do produce some on-going waste streams. For several of the waste streams covered under the "emergency response actions" or"site cleanup" exemptions, between 5% and 15%was considered to have been generated by onsite activities and was included when calculating the total weight of hazardous waste generated (refer to Table 1). These specific waste streams may be generated because of damaged/spilled product and as part of facility operations. For example, aerosol can wastes are primarily arcadis.com Page: 2/3