CUPA 2007 Adv HW part 3

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Published on November 7, 2007

Author: BAWare

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9th Annual California Unified Program Conference:  9th Annual California Unified Program Conference Part III Hazardous Waste Container &Tank Standards:  Part III Hazardous Waste Container &Tank Standards Definitions Pictures Regulations & Guidance documents Tank Defined:  Tank Defined UFC 9.122 Tank is a vessel containing > 60 gals. 40 CFR §260.10 Tank means a stationary device, designed to contain an accumulation of hazardous waste which is constructed primarily of non-earthen materials which provide structural support. 22 CCR § 66260.10 "Tank" means a stationary device, designed to contain an accumulation of hazardous waste which is constructed primarily of non-earthen materials which provide structural support. Tank System:  Tank System 40 CFR §260.10 Tank system means a hazardous waste storage or treatment tank and its associated ancillary equipment and containment system. 22 CCR § 66260.10 "Tank system" means a hazardous waste transfer, storage or treatment tank and its associated ancillary equipment and containment system. Container:  Container 40 CFR §260.10 Container means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. 22 CCR §66260.10 "Container" means any device that is open or closed, and portable in which a material can be stored, handled, treated, transported, recycled or disposed of. A Tank is stationary:  A Tank is stationary A Container is portable Is it a: a. Tank or b. Container?:  Is it a: a. Tank or b. Container? Is it a: a. Tank or b. Container?:  Is it a: a. Tank or b. Container? Is it a: a. Tank or b. Container?:  Is it a: a. Tank or b. Container? Is it a: a. Tank or b. Container?:  Is it a: a. Tank or b. Container? Filter Cake Is it a: a. Tank or b. Container?:  Is it a: a. Tank or b. Container? Portable Tank?:  Portable Tank? Ancillary Equipment:  Ancillary Equipment 40 CFR §260.10 reads just like § 66260.10. 22 CCR § 66260.10 "Ancillary equipment" means any device including, but not limited to, such devices as piping, fittings, flanges, valves and pumps, that is used to distribute, meter or control the flow of hazardous waste from its point of generation to a storage or treatment tank(s), between hazardous waste storage and treatment tanks to a point of disposal onsite, or to a point of shipment for disposal offsite. Ancillary Equipment?:  Ancillary Equipment? Hazardous Waste Piping Ancillary Equipment?:  Ancillary Equipment? Green Liquid  Green Liquid pH = 13:  Green Liquid pH = 13 Is it a. Ancillary Equipment or b. A Tank?:  Is it a. Ancillary Equipment or b. A Tank? Filter Press Does it Move? Tanks Standards Apply? :  Settling Tank Tanks Standards Apply? Process Tank Heated Drying Tank Process Tank outflow (waste A). non-hazardous Non-hazardous waste water to sewer Sludge, Hazardous Waste Settling tank sludge outflow (waste B), hazardous waste Which tanks & pipes require a P.E. assessment? The blue & burgundy tanks & piping At what point do the hazardous waste Tank Standards Apply?:  At what point do the hazardous waste Tank Standards Apply? The first tank is a process tank. Materials go in, non-hazardous waste flows out. The settling Tank is a new point of generation. Non-hazardous waste flows in, a hazardous waste flows out. Does 66261.4(c) Exclusion apply?; the manufacturing tank unit situation. 22 CCR 66261.4(c):  22 CCR 66261.4(c) A hazardous waste which is generated in a product or raw material storage tank, a product or raw material transport vehicle or vessel, a product or raw material pipe line, or in a manufacturing process unit or an associated non-waste-treatment-manufacturing unit, is not subject to regulation under this division until it exits the unit in which it was generated, unless the unit is a surface impoundment, or unless the hazardous waste remains in the unit for more than 90 days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials. This apples to the hazardous waste generated in these tanks, not the tanks themselves. The tank is subject to Chapter 32, Title 22 (closure) if the unwanted tank exhibits a characteristic of a hazardous waste. Answer by the CUPA 2005 DTSC Q&A Panel:  Answer by the CUPA 2005 DTSC Q&A Panel A process tank sends non-hazardous waste into a settling tank in which liquid and solid fractions separate by gravity. The solids are hazardous and are pumped to a heated drying tank for additional water removal. The water fraction flows from the settling tank directly to the sewer. Which tanks/pipes in this system would require a tank assessment? The piping and pumps that feed the settled solids to the heated drying tank, and the heated drying tank itself would be a tank system and would be subject to tank assessments as provided in CCR, title 22, section 66265.193. The settling tank would not be subject to the tank assessment because the waste as it originally entered the tank was not hazardous, even though a hazardous waste is generated in the tank through settling. Answer by the CUPA 2005 DTSC Q&A Panel:  Answer by the CUPA 2005 DTSC Q&A Panel a. What if (instead of a process tank) this system processes a hazardous waste upstream of the settling tank, and the waste entering the settling tank is non hazardous? No change in above answer. Even thought the settling tank is at the back end of a treatment system or unit, the definition of “unit” clear says that it is “…combination of tanks or tank systems…located together that are used in sequence to treat or accumulate one or more compatible HAZARDOUS wastestreams.” Once the wastestream was rendered non-hazardous by the upstream treatment system, the settling tank is no longer part of the unit. Materials Tank that is also used for Waste?:  Materials Tank that is also used for Waste? “A related question concerns the applicability of the hazardous waste tank system standards to process transfer equipment normally used for production purposes, but also used to transfer hazardous waste residue to either a NPDES wastewater treatment system or an onsite RCRA treatment/storage facility. Assuming it is removed within 90 days after production or product storage is stopped, the hazardous waste generated within product/raw material process tanks does not become subject to the hazardous waste tank system standards until it exits the unit in which it was generated.” (FAXBACK 13790) Materials Tank that is also used for Waste: Answer:  Materials Tank that is also used for Waste: Answer “The tank system standards apply to ancillary equipment used to handle the hazardous waste during transfer from its point of origin to a hazardous waste storage/treatment tank. We consider the point of exit from the process tank to be the introductory point for the hazardous waste into a hazardous waste tank system. Therefore, any process transfer equipment, even if normally used for production purposes, that is also used to transfer hazardous waste residue during equipment washout/cleanout procedures to a hazardous waste storage/treatment tank, would be considered part of a hazardous waste tank system and thus subject to the standards for such.” (FAXBACK 13790) Material & Waste Tank System :  Material & Waste Tank System Process A Tanks A, B & C contain material; the piping is used exclusively to transfer the liquid when is no longer useful. Process B Process C D Waste A A + B A+B+C=D D is a tank; what parts of the system require a P.E. Assessment? No hazardous characteristics Hazardous What if A is a listed pesticide? What if D was a 55 gallon drum that was removed when full? Point of Generation = Start of ancillary equipment:  Point of Generation = Start of ancillary equipment If A is a waste listed for toxicity, then D is a hazardous waste under the mixture rule. D is a tank, so The point of generation is normally the exit point (pipe) from a process tank. This pipe will be the introductory point for hazardous waste into a hazardous waste tank system, therefore it is ancillary equipment. (FAXBACK 13790) Answer by CUPA 2005 DTSC Q&A Panel:  Answer by CUPA 2005 DTSC Q&A Panel Three material storage tanks (A,B, and C) are piped together into a fourth tank (D). When materials in tanks A, B, and C are no longer usable, they are released to tank D. The materials in tanks A and B are characteristic hazardous wastes. The material in tank C is non-hazardous. The resultant commingled waste stream found in tank D is non-hazardous. a. What parts of this system would require a tank assessment? All of the piping leading from tanks A, B, and C to tank D, and tank D itself would be considered a tank system. Answer by CUPA 2005 DTSC Q&A Panel:  Answer by CUPA 2005 DTSC Q&A Panel b. Does it matter is one of the wastes (say in tank A) is a listed waste instead of a characteristic waste? Yes. The listing would carry through from tank A through all subsequent tanks and all wastes that the listed waste gets mixed with due to the mixture rule (T22, section 66261.3(a)(2)(E)). The exception to the mixture rule would be if the listed waste was listed only for ignitibility and/or reactivity and the resultant mixture does not exhibit a characteristic. Other specific mixture rule exclusions can be found in 66261.3(a)(2)(F). Is it a Hazardous Waste Tank System?:  Is it a Hazardous Waste Tank System? It is less clear if D is a container or is not a hazardous waste tank (such as, waste piped directly to the POTW system). If hazardous waste is not accumulated, stored or treated in a tank then it is not a hazardous waste tank system. So tank standards don’t apply. The piping is a hazardous waste conveyance system, but It has to be part of a hazardous waste tank system to be ancillary equipment to a hazardous waste tank. Tank?:  Tank? Floor sump Process tank Sumps:  Sumps Temporary or Emergency Containment Sumps – exempt subject to management procedures, i.e. clean & dry except after emergency. Secondary-containment Sumps – must meet secondary containment standards Primary-containment sumps – regulated as tanks (FAXBACK 12442) Emergency Spill Containment or is it Primary Containment?:  Emergency Spill Containment or is it Primary Containment? Berms surrounding tanks area Hazwastes on floor Emergency Containment? Secondary Containment?:  Emergency Containment? Secondary Containment? Floor Sump Sumps #1:  Sumps #1 “Sumps may present the same potential for leaks and releases as hazardous waste storage and treatment tanks and generally should be subject to the same standards as tanks.” 51 FR 25441 of July 14, 1986. Sumps for 90-day storage, “Assuming the sumps are made of non-earthen material and have sufficient structural integrity, they would be regulated as tanks.” (faxback 12442) Sumps #2 :  Sumps #2 Parking lot test (faxback 12104, 12224) Surface Impoundment or a Tank? If freestanding in a parking lot will the unit provide sufficient structural support to hold its contents? Pass – If it can, it’s a tank Fail – If it can’t pass, then it is a surface impoundment. A surface impoundment requires RCRA storage permit. Ancillary Equipment? Secondary Containment?:  Ancillary Equipment? Secondary Containment? Plating shop floor Ancillary Equipment?:  Ancillary Equipment? Floor trenches Floor Drains & Trenches:  Floor Drains & Trenches Building Floor Drains and Trenches used to transfer hazardous wastewater to an in-ground storage tank are ancillary equipment. (FAXBACK 12829, 13653) 22 CCR 66265.193(f) “Ancillary equipment shall be provided with full secondary containment... Except for” Components inspected daily, e.g. above ground piping Joe’s Plating Shop:  Is the sump in the floor a tank? Is the concrete floor ancillary equipment? Joe’s Plating Shop Elevated grate Or “catwalk” Is it a hazardous waste tank?:  Is it a hazardous waste tank? Is the drag-out from a plating shop a hazardous waste? Yes Is the drag-out routinely generated? Yes “Generally speaking, any tank system into which hazardous waste is routinely and systematically introduced, regardless of frequency or duration of storage, is not considered either a temporary tank or part of the secondary containment system and therefore must be provided with secondary containment (see 51 FR 25422; July 14, 1986).” Re: OSWER Directive 9483.00-3 What if it’s a spill?:  What if it’s a spill? “If cleanup activities do not begin promptly, the spill is considered a land disposal site subject to permitting requirements. …Extended responses which are not judged to be immediate in nature may result in: (1) A modification to the facility’s contingency plan; (2) An enforcement action for an inadequate contingency plan or permit violations; or (3) Enforcement action for illegal disposal.” FAXBACK 12748 How about a spill into secondary containment?:  How about a spill into secondary containment? Secondary containment for a hazardous waste tank system, that meets tank standards? Then… §66265.196. Response to Leaks or Spills and Disposition of Leaking or Unfit-for-Use Tank Systems. A tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use, shall be removed from service immediately, and the owner or operator shall satisfy the following requirements: §66265.196:  §66265.196 (c) Removal of waste from tank system or secondary containment system. (1) If the release was from the tank system, the owner or operator shall, within 24 hours after detection of the leak or, if the owner or operator demonstrates that that is not possible, at the earliest practicable time remove as much of the waste as is necessary to prevent further release of hazardous waste to the environment and to allow inspection and repair of the tank system to be performed. (2) If the release was to a secondary containment system, all released materials shall be removed within 24 hours or in as timely a manner as is possible to prevent harm to human health and the environment. Wet Floors: Is the floor a regulated tank unit?:  Wet Floors: Is the floor a regulated tank unit? They are a problem Big hole in floor beneath acid tank:  Big hole in floor beneath acid tank Acid soln. with copper Deteriorated floor below metal finishing tank:  Deteriorated floor below metal finishing tank Hazwastes Floor trench used at metal finishing process room:  Floor trench used at metal finishing process room Trench 3’ depth Deteriorated floor underneath metal finishing tanks:  Deteriorated floor underneath metal finishing tanks State DTSC recent enforcement news:  State DTSC recent enforcement news December 8, 2005 enforcement settlement: The California Department of Toxic Substances Control (DTSC) announced it has reached a $200,000 settlement with Ultima Circuits, LLC for hazardous waste violations at its facility located at 4361 Pell Drive in Sacramento. DTSC’s Weblink to read full consent order….. http://www.dtsc.ca.gov/HazardousWaste/Projects/upload/ULTIMA_ENF_CO.pdf cont.. Ultima Circuits recent enforcement case:  Ultima Circuits recent enforcement case The settlement stems from violations observed by DTSC inspectors on 1/7/04, & 3/9/05. The violations were: • Failing to provide secondary containment for eight hazardous waste treatment tanks • Discharging hazardous waste directly onto the floor of the facility, where waste then flowed into an UST that lacked secondary containment • Failing to prepare a written assessment, certified by an independent, registered professional engineer, for hazardous waste treatment tank systems, as well as the floor used as a hazardous waste collection tank. Ultima Circuits has ceased using the facility floor as a hazardous waste tank. Some exceptions to consider when dealing with what is a hazardous waste and the “wet floors scenario”:  Some exceptions to consider when dealing with what is a hazardous waste and the “wet floors scenario” §66261.3 Definition of a Hazardous Waste §66261.3(a)(2) (E) & (F) lists a few mixtures of listed wastes and wastewater that are not hazardous wastes when discharged to a POTW or NPDES permitted waste water treatment facility. [What is really says is: small amounts of listed waste that no longer exhibit a characteristic of a hazardous waste when combined with facility waste water] Some exceptions to remember….. §66261.3(a)(2)(F)(1),(2)&(3):  Some exceptions to remember….. §66261.3(a)(2)(F)(1),(2)&(3) And... 1. Some F listed solvents that don’t exceed 1 ppm of discharge, or 2. . Some F listed solvents that don’t exceed 25 ppm of discharge, or 3. K050, or Some exceptions to remember…. §66261.3(a)(2)(F)(4):  Some exceptions to remember…. §66261.3(a)(2)(F)(4) 4. “P & U” listed chemical arising from "de minimis" losses from manufacturing operations in which these materials are used as raw materials or are produced in the manufacturing process. "de minimis" losses include those from normal material handling operations (e.g., spills from the unloading or transfer of materials from bins or other containers, leaks from pipes, valves or other devices used to transfer materials); minor leaks of process equipment, storage tanks or containers; leaks from well-maintained pump packings and seals; sample purgings; relief device discharges; discharges from safety showers and rinsing and cleaning of personal safety equipment; and rinsate from empty containers or from containers that are rendered empty by that rinsing; Some exceptions to remember…. §66261.3(a)(2)(F)(5):  Some exceptions to remember…. §66261.3(a)(2)(F)(5) 5. Laboratory wastewater containing wastes listed for toxicity (T) provided that the annualized flow of laboratory wastewater does not exceed 1% of the total faculty wastewater or provided that the wastes combined average concentration does not exceed 1 ppm in the headwaters of the facilities wastewater treatment. Some exceptions to remember….. §66261.3(a)(2)(F)(6)&(7):  Some exceptions to remember….. §66261.3(a)(2)(F)(6)&(7) 6. K157 that don’t exceed 5 ppm by weight, or 7. K156 that don’t exceed 5 ppm by weight Answer by CUPA 2005 DTSC Q&A Panel:  Answer by CUPA 2005 DTSC Q&A Panel A grated trench carries only non-hazardous wastes (mainly oily residue in water and dirt) to a on-site waste water handling (treatment) facility. The sediment that accumulates in the trench may be non-RCRA (hazardous) due to metals. Would the trench be regulated as a tank under the hazardous waste tank regs? The panel agreed that the trench is not a regulated tank system since the trench is not being used to convey a hazardous waste. The sludge that is incidentally accumulating in the trench does not become a hazardous waste until it is removed from the trench. Answer by CUPA 2005 DTSC Q&A Panel:  Answer by CUPA 2005 DTSC Q&A Panel a. How does this thinking apply to wet floors located beneath plating areas? The panel expressed that this thought process may be extended to wet floors in some instances. It was pointed out that many wet floors operate as secondary containment for the hazardous materials that are contained in the tanks above them, and that in those instances, the constant conveyance of liquids on wet floor may diminish the ability of the floor to operate as a containment structure. One panelist suggested that operators of businesses that have wet floors be left with a suggestion to hose-off or remove all contamination from the floor at least weekly, if for no other reason but to provide a clear way to inspect the floor to ensure that the containment structure has not been compromised. So, Is this OK?:  So, Is this OK? Trench system Drain opening How about this?:  How about this? Trench Hazardous waste Tank Categories:  Hazardous waste Tank Categories Portable tanks = Containers RCRA permitted tanks PBR, CA & CE Treatment tanks LQG RCRA and Non-RCRA tanks SQG RCRA & Non-RCRA tanks CESQ treatment tanks Hazardous Waste Laws & Regulations:  Hazardous Waste Laws & Regulations California hazardous waste regulations, 22 CCR, Division 4.5 : http://www.calregs.com/ California hazardous waste laws, Health & Safety Code Division 20, Chapter 6.5 : http://www.leginfo.ca.gov/ Tank Standards for Onsite Treatment under PBR:  Tank Standards for Onsite Treatment under PBR The owner or operator of a fixed treatment unit deemed to hold a Permit By Rule shall comply with Chapter 15, Article 10 Tank Systems {§67450.3(c)(9)(F)} Tank Standards for Onsite Treatment under a Grant of Conditional Authorization:  Tank Standards for Onsite Treatment under a Grant of Conditional Authorization §25200.3 (c)(4) The generator unit shall comply with container and tank standards applicable to non-RCRA wastes, specified in 22 CCR §66264.175 (a) and (b), and to Article 9 and Article 10 of Chapter 15. Onsite Treatment Activity Conditionally Exempt from Permit Requirements:  Onsite Treatment Activity Conditionally Exempt from Permit Requirements Rarely seen: §25201.5(e)(1) Ancillary equipment for a tank or container treating hazardous wastes solely pursuant to this section is not subject to §66265.193 of Title 22 CCR, if the ancillary equipment's integrity is attested to pursuant to §66265.191 of Title 22 CCR every two years from the date that retrofitting requirements would otherwise apply...{but remember §25201.5(d)(9) reqs. for HW generators} Onsite Accumulation Large Quantity Generators:  Onsite Accumulation Large Quantity Generators §66262.34 Accumulation Time. (a) A generator may accumulate hazardous waste on-site for 90 days or less without a permit or grant of interim status, provided that: (1) (A) the waste is placed in containers and the generator complies with the applicable requirements of articles 9, 27, 28 and 28.5 of chapter 15 of this division , or the waste is placed in tanks and the generator complies with articles 10, 27, 28, and 28.5 of chapter 15 of this division , except §§66265.197(c) and 66265.200 . Small Quantity Generators California Law & regulation :  Small Quantity Generators California Law & regulation H&SC §25123.3(h) (1) reads the same as 66262.34(d) A generator of less than 1000 kg/month of hazardous waste must comply with the container and tank standards for small quantity generators in 40 CFR. Since 1997 California SQGs are not subject to Title 22 LQG container & tank requirements, unless they treat waste onsite under PBR or CA tiers. Small Quantity Generators Regulation:  Small Quantity Generators Regulation §66262.34(d) Notwithstanding {in spite of }.. subsections (a) and (c) of this section and §66262.35, a generator of less than 1,000 kilograms of hazardous waste in any calendar month who accumulates hazardous waste onsite for 180 days or less, or 270 days or less if the waste is transported, over a distance of 200 miles or more, for offsite treatment, storage, or disposal, is not a storage facility if all of the following apply: Small Quantity Generator §66262.34(d) continued:  Small Quantity Generator §66262.34(d) continued (1) The quantity of hazardous waste accumulated onsite never exceeds 6,000 kilograms. (2) The generator complies with the requirements of subdivisions (d), (e) and (f) of section §262.34 of Title 40 CFR §262.34 (d)(3) The generator complies with the requirements of Sec. 265.201 in subpart J of part 265; Title 40 CFR 22 CCR, Chapter 15 Applicability:  22 CCR, Chapter 15 Applicability Still not sure if Chapter 15 applies? §66265.1 Purpose, Scope, and Applicability (d) The requirements of this chapter do not apply to: (7) a generator accumulating waste on-site in compliance with section 66262.34 of this division, except to the extent the requirements are included in section 66262.34 of this division; What Makes Tanks Subject to T22 Ch. 15, Art. 10? :  What Makes Tanks Subject to T22 Ch. 15, Art. 10? 22 CCR §67450.3(c)(9)(F) points PBR tanks to Ch. 15, Art. 10 H&SC §25200.3 (c)(4) points CA Tanks to Ch. 15, Art. 10 22 CCR §66262.34(a) points LQGs to Ch. 15, Art. 10 22 CCR §66262.34(d) points SQGs to 40 CFR §265.201, not Article 10. Is it Clear now?:  Is it Clear now? A new Study indicates that attempts to thoroughly understand Title 22 CCR tank standards contributes to the early onset of Alzheimer’s disease. Hazardous waste Tank Standards:  Hazardous waste Tank Standards Portable tanks = Containers RCRA LQG, PBR & CA Treatment (Chapter 15, Article 10) RCRA & Non-RCRA SQG tanks (40 CFR subpart J, §265.201) Two More Examples :  Two More Examples Don’t forget your evaluation Biotech Laboratory Waste System #1:  Biotech Laboratory Waste System #1 This system transfers waste solvents from the laboratory areas to an exterior hazardous waste accumulation area. The solvents vary (sometimes up to 75% methylene chloride); they are corrosive and ignitable. Question #1. Is it a hazardous waste tanks system? Question #2. Does the system satisfy 22 CCR container and/or tank standards? Slide75:  Initial lift station/sump tank inside laboratory cabinet for pumping waste from the lab to the hazardous waste storage room outdoors. Small double wall sump, single wall pipes. Slide76:  Initial drain sink in lab area for receiving hazardous waste liquid and piping (gravity feed) the waste to a lift station sump tank Slide77:  Lift station sump tanks on the floor that receives waste via plastic piping and pumps the waste to the outdoors waste storage shed. Double walled sumps, single wall pipes. Slide78:  Final hazardous waste accumulation drum. Located inside the waste storage shed that receives waste from the labs via the lift station sump/tank system. Biotech Laboratory Waste System:  Biotech Laboratory Waste System This system transfers waste solvents from the laboratory areas to an exterior hazardous waste accumulation area. The solvents are corrosive and ignitable. Question #1. Is it a hazardous waste tank system? Yes. It is a hazardous waste tanks system. Those little sumps are stationary; they are tanks. At least that’s what I think. These double wall sumps routinely contain waste:  These double wall sumps routinely contain waste Some piping is PVC. The solvents are up to 75% methylene chloride. Question #2. Does the system satisfy 22 CCR container and/or tank standards? Is it compatible? Biotech Laboratory Waste System:  Biotech Laboratory Waste System Question #2. Does the system satisfy 22 CCR container and/or tank standards? No, Single wall pipe in wall cannot be visually monitored PVC vent pipe not compatible with solvents. http://www.coleparmer.com/techinfo/chemcomp.asp You’re right! These standards were not covered; it’s advanced training. Biotech Laboratory Waste System #2:  Biotech Laboratory Waste System #2 Oligator(TM) An Oligator is used to oil alligators:  Oligator(TM) An Oligator is used to oil alligators Oligator machine in the lab. There are 11 of these machines in the lab. The large tube going up the left side of the machine is a vent tube, from the machine itself. It does not vent any waste products or vapors. Narrow stainless steel pipe next to the vent tube is the waste pipe. Waste is pumped up this pipe to the larger stainless steel header. Actually an Oligator makes oligonucleotides – short links of nucleic acids:  Actually an Oligator makes oligonucleotides – short links of nucleic acids The waste pipe feeding out of the back of the Oligator. Other pipes feed in raw materials. Waste & vent piping from Oligator(TM) room:  Waste & vent piping from Oligator(TM) room Narrow stainless steel pipe feeds the waste to the header. Pipe enters the wall and passes into the H3-H7 rated (Building & Fire Codes) waste room. Waste piping from Oligator(TM) room:  Waste piping from Oligator(TM) room Hazardous waste tanks in the H3-H7 rated waste room. Each tank has a dual-level alarm sensor. The first level alarm pages environmental staff. The second level alarm goes off, the valve closes flow to the first tank and diverts it to the second tank. Once the first level alarm of the second tank goes off, a waste pick-up is scheduled. Top of 275 gallon tote:  Top of 275 gallon tote Hazardous waste tank in the H3-H7 rated waste room showing the header flowing into one tank. Close-up view Hazardous Waste Tank System?:  Hazardous Waste Tank System? The waste is piped into 275 gallon UN approved totes. The waste is pumped out of the totes pictured and into similar totes for transportation from the generator's facility to a TSDF. Is it a hazardous waste tank system? Is it a Hazardous Waste Tank System?:  Is it a Hazardous Waste Tank System? Yes, it is a hazardous waste tanks system. The totes contain hazardous waste and they are stationary (hard plumbed). The waste is pumped out and into identical totes that are hazardous waste containers. The End:  The End Don’t Forget Your Evaluations If you have any questions, please contact us: San Diego County CUPA john.misleh@sdcounty.ca.gov michael.vizzier@sdcounty.ca.gov

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