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MEMO <br /> the result of puncturing during transit or movement of product within the store; however, a minor amount is <br /> also generated through operational activities at the store. <br /> Using this methodology, the total quantity of hazardous waste generated at STR 0662 was 11,427 pounds <br /> in 2018. This is below the SB 14 threshold of 26,400 pounds (refer to Table 1). <br /> CONCLUSION <br /> Per 22 CCR 67100.2, Applicability, DTSC exempts waste streams from the requirements of SB 14 if the <br /> waste has no source reduction opportunities or is not routinely generated. A portion of waste streams <br /> generated at the store location are not routinely generated and a majority of exempted wastes is the result <br /> of damaged products or spills. Based on Arcadis' review of the waste streams generated in 2018 at <br /> STR 0662 and discussion with DTSC, STR 0662 is not subject to the requirements of SB 14. <br /> Attachment: <br /> Attachment 1: List of Exempted Wastes in 22 CCR 67100.2 <br /> Tables: <br /> Table 1: Waste Generation Summary—2018 <br /> References: <br /> DTSC. 2010. Guidance Manual for complying with the Hazardous Waste Source Reduction and <br /> Management Review Act of 1989. December. <br /> arcadis.com Page: <br /> 3/3 <br />