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Notice of Processing Hazardous Waste Aerosol Cans <br />Holt of California located at 1521 W. Charter Way, CA (EPA # CAL000827892) <br />is dedicated to the proper handling of all our waste streams in acc-ordance with federal, <br />state, and local regulations. This notification is to confirm that as a generator, our aerosol <br />can process is in compliance. Using the California H&S Code Section 25201.16, CCR <br />Title 22, and the fact sheet from the DTSC on Senate Bill 1158 our process was <br />developed; Knowing that certain hazardous wastes which are commonly generated that <br />pose a relative lower risk to people and the environment than other hazardous waste, <br />"universal. wastes are regulated based on a relaxed set of standards" more appropriate to <br />the specific hazard they pose. SB 1158 Section 25201.16 made processing hazardous <br />waste aerosol cans a universal waste handler activity. <br />The following is an account of our "aerosol can processing." <br />• Deeming an aerosol can a waste: At the time a Holt of California employee has <br />determined that one of the criteria in H&S Code25201.16 (2)(A) occurs, we now <br />have a hazardous waste. <br />• Estimated volumes: Due to the fluctuation in market share that Holt represents, <br />and our recycling efforts, the amount of waste we generate has declined. With that <br />said, a conservative estimate would be: 8-15 cases a month (calculated @ 12 cans <br />per, case). This waste is accumulated at or near the point of generation for not <br />more than one year. For that duration, on average, we have not exceeded one foot <br />in a 55 drum that we have had Asbury haul off and recycle. <br />• Management of hazardous residuals: We used appendix V, CCR Title 22 division <br />4.5, chapter 14, MSDS of all aerosols', and our environmental consultants from <br />HDR & NES for guidance on incompatible wastes. The types of product <br />propelled form aerosol cans are: paints, adhesives, cleaners, and lubricants. We <br />have a strong understanding of the consequences with regards to the interactions <br />of incompatible chemicals and this is our basis for establishing proper chemical <br />handling procedures. The product line we represent has no chemical which can be <br />propelled from an aerosol can that is incompatible once comingled that would <br />have a reaction nether mild or violent, immediate or delayed, generation of heat, <br />toxic gas, pressure, fire, explosion, toxic by product or the solubilization of a <br />toxic substance. DeMenno/ Kerdoon in Compton, CA is the destination facility: <br />EPA ID # CAT080013352. This waste is recycled, waste code: H061. <br />• Equipment description: The manufacture of the three can puncture station is <br />AeroVent3. It mounts via a two inch steel pipe bung to a UL listed drum provided <br />by contracted hauler. <br />• Management of containers: This applies to both the container. holding the aerosol <br />cans and the container holding the residue post puncturing the can. Holt of <br />California follows Title 22 subsection 66265.173 and those of H&S 25201.16 <br />