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STATE OF CALIFORNIA—CALIFORNIA ENVIRONME .PROTECTION AGENCY PETE WILSON,Governor DEPARTMENT OF TOXIC SUBSTANCE, ,CONTROL 400 P STREET.4TH FLOOR P.O.BOX 806 SACRAMENTO,CA 95812-0806 (310) 590-5523 : !• [� August 24, 1995 EPA ID: CAD095654273 RV CIRCUITS INC Forfacility locared at. MR. ARTHUR SMITH 916 S CENTER ST 916 S CENTER ST STOCKTON, CA 95206-1310 STOCKTON, CA 95206-1310 STATUS OF FACILITIES TREATING COPPER CLEANSERS AND CONDITIONERS UNDER CONDITIONAL AUTHORIZATION Dear Mr. Smith: This letter is to inform you of some recent legal changes affecting certain Conditionally Authorized (CA) facilities. Our records indicate that your facility treats spent copper cleaners and conditioners in a CA unit. As of January 1, 1995, the statutory authority that authorized treatment of this wastestream under CA expired and, technically, this wastestream is now legally subject to the requirements of the Permit by Rule tier. The Department of Toxic Substances Control (DTSC) is taking steps to rectify this situation and is advising businesses, such as yours, that you may continue to operate under the previous guidelines. Background: Assembly Bill 1772 (1992) established a special category under CA for the treatment of less than 1,000 gallons per month of spent copper cleansers and conditioners which contain up to 5,000 parts per million(ppm) of copper. This limit goes beyond the allowance for other metals treated under CA, which are limited to a concentration of 1,400 ppm. These copper limits, set forth in Health and Safety Code 25200.3(c)(11), were written to expire on January 1, 1995, unless extended by the Legislature. AB 1772 also required DTSC to conduct a study of the risk of the waste. Current Status: The study of the relative risk of the waste was not completed and the Legislature took no action to extend this category under CA by the January 1, 1995 sunset date. Therefore, technically, this waste category no longer exists under CA, and any treatment of this waste is subject to the more stringent Permit by Rule (PBR) requirements, if the concentration exceeds 1,400 ppm. DTSC has recommended to the Legislature that this waste category be continued in CA indefinitely and that the study requirements be dropped. Assembly Bill 1966 of 1995 (Figueroa) would continue this waste in CA until 1998 and extend the deadline for this study. In the meantime, in order to avoid imposing an unnecessary burden on the regulated community, DTSC will not take enforcement action against CA facilities treating copper cleansers and conditioners pursuant to the original statutory conditions nor will DTSC require amended notifications to be filed or operation of these units under PBR. DTSC is trying to avoid unnecessary filings or changes, as the Legislature is expected to approve the extension under CA for these wastes until 1998. If legislative action is not taken this year, it may be necessary to permanently handle this treatment under the PBR tier. Your Options: If you are treating these wastes, DTSC is requiring no immediate action on your part while the Legislature considers the proposed extension. However, if you feel so compelled, you do have the option to (1) revise your notification to show the copper operations as Permit by Rule units, (2) meet the 11b L� v„�wa�n.Mi.a aw«