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Source Reduction Plan Applicability: <br /> Applicability Test—Is a Source Reduction Plan Required? <br /> HSC 25244.15(d)(1) - ". . . generators who, by site, routinely generate, through ongoing processes and <br /> operations, more than 12,000 kilograms of hazardous waste in a calendar year(Test 1), or more than 12 <br /> kilograms of extremely hazardous waste in a calendar year(Test 2)." <br /> 1. Test 1—Based on hazardous waste data, University of the Pacific DOES NOT routinely generate <br /> more than 12,000 kg of hazardous waste in a calendar year. <br /> 2. Test 2—Based on hazardous waste data, University of the Pacific DOES routinely generate more <br /> than 12 kilograms of extremely hazardous waste in a calendar year. <br /> Therefore, a Source Reduction Plan is required due to Test 2 above. <br /> Chemicals: <br /> Chemical Inclusion Test—What Chemicals must be included? <br /> HSC 25244.19(b)(3)—Identify " . . . all routinely generated hazardous waste streams that annually weigh <br /> 600 kilograms or more and that result from ongoing processes or operations and exceed 5 percent of <br /> the total yearly weight of hazardous waste generated at the site (Test 3), or,for extremely hazardous <br /> waste,that annually weigh 0.6 kilograms or more and exceed 5 percent of the total yearly weight of <br /> extremely hazardous waste generated at the site (Test 4). <br /> 3. Test 3—Three hazardous waste streams have been identified as exceeding 600 kg and 5%of the <br /> total yearly weight of hazardous waste generated at the site. <br /> 4. Test 4—One extremely hazardous waste stream has been identified as exceeding 0.6 kg and 5% <br /> of the total yearly weight of extremely hazardous waste generated at the site and is the same as <br /> one of the waste streams included in Test 3 above. <br /> Evaluation: <br /> All three identified hazardous waste streams, including one extremely hazardous waste stream, are <br /> generated from the teaching of students in laboratory settings as well as from research activities within <br /> research laboratories.There are no manufacturing production processes involved. Waste volumes vary <br /> based on student enrollment levels and current research requirements. Waste is minimized by utilizing <br /> the least amount possible,while still providing student and faculty appropriate safety protection, a <br /> quality education for our students, and appropriate research capabilities within the University. <br /> Determination: <br /> Given our waste minimization processes and dependency on our educational and research purposes, <br /> processes, requirements, and levels, as well as our safety and environmental protection requirements, <br /> establishing targeted reduction amounts are not feasible at this time for any of the three applicable <br /> waste streams. <br /> 6/8/2020 <br />