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4RTMENT OF TOXIC SUBSTANCES CONTROL <br />MU. 4iW FLOOR <br />;Doe <br />jfMTO. CA 95812.OWO , <br />.6) 5-2625 <br />: IF <br />May 20, 1994 <br />TO: All Interested Parties <br />SUBTECT: INTMUM POLICY REGARDING TRANSPORTATION OF LIGHTING <br />WASTES <br />The mercury -containing lighting waste recycling facilities <br />issued Interim Status December 31, 1993, pursuant to Health and <br />Safety Code sections 25200.51 25200.9, and 25201.61 are requiredwith Health and Safety <br />to operate those facilities in compliance <br />Code section 25201.6 and title 22, California Code of Regulations <br />(title 22 CCR) section 67800.1. These facilities must comply <br />with the standards for interim status facilities as specified in <br />title 22, CCR, division 4.5, chapter 1. These standards require <br />e use of a manifest and a registered transporter for the <br />ipment of hazardous wastes to the �J t rim Status facility for <br />1whe purposes of recycling. <br />Until the -creation of -the Standardized Permit tier, the <br />Department of Toxic Substances Control (Department) historically <br />allowed fluorescent -lamp waste recycling facilities to operate <br />pursuant to Research, Development, and Demonstration (RD&D) <br />variances. Each of the RD&D variances allowed the use of a bill <br />of lading and a non -registered transo er for the transportation <br />facility. A Fact Sheet <br />of fluorescent lamps to the recycling <br />public and <br />issued by the Department's Pollution Prevention, Publosed) <br />Regulatory Assistance Program in Nov y1992ba copy <br />yon enclosed) <br />details this variance policy. The poli <br />cy an <br />interpretation of title 22, CCR, section 66266.120 that allows <br />transportation of up to ten pounds of elemental mercury to a <br />recycling facility without the use of a manifest or a registered <br />transporter. <br />The Department is reviewing the applicability of title 22, <br />CCR, section 66266.120, and is proposing to develop regulations <br />the transportation specifically addressing tion of mercury-containing <br />lighting wastes to recycling facilities. The Department is <br />a modified manifesting system for lighting <br />considering proposing the develo meet <br />wastes. Your comments will be solicited during P <br />of these regulations. <br />n <br />r. <br />