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-?, Ms. Janet Ortiz <br /> i3 October 31 , 1995 <br /> Page 5 <br /> In no case is any generator allowed an additional 9o-ay accumulation period for waste that has <br /> accumulated in a satellite area for one year. If wastes from different satellite accumulation areas <br /> are commingled, the initial date of the oldest waste is the detemining date for the entire <br /> container. <br /> Discussion: The initial San Diego response incorrectly limited the one year deadline to the time <br /> the waste is held in the satellite area instead of it applying to time the waste is held at the entire <br /> generator site, allowed an additional 90 days in the 090-day accumulation area"if a year has <br /> already expired in the satellite area, and stated that to waste can ever be kept over one year. <br /> DTSC will soon be issuing a revision to the MM to reflect 1995 legislative changes and to <br /> provide for the clarification on the issues raised in your letter. <br /> Your letter to Scripps also mentions formation of a focus group on biotech issues- I <br /> would also be very interested in the outcome of any discussions with the industry and direct you <br /> to Ms. Charleen Williams, Chief of the Northem California Branch, Statewide Compliance <br /> Division, who is the DTSC contact person on issues related to management of hazardous waste <br /> generated by laboratories. She can be reached in our Berkeley office at (510) 540-3855. <br /> If you have any further questions on generator accumulation requirements, please contact <br /> me or Dr. Sangat Kals, Chief, Tiered Permitting Compliance Section at (916) 324-8293. <br /> Sincerely, �J <br /> Paula Rasmussen, Division Chief <br /> State Regulatory Programs Division <br /> cc: Mr. Stuart Rosenberg <br /> Director, Environmental Health and Safety <br /> The Scripps Research Institute <br /> 10666 North Torrey Pines Road <br /> La Jolla, CA 92037 <br /> S/E abed `•nvLt:oL 00- L-unr `S6SL1/VS08 `Vd10/ijnl Hi�V3H 8IAN3 0A :AS }uos <br />