9th Annual California Unified Program Conference

1
9th Annual California Unified Program Conference
Advanced Hazardous Waste Inspector Training
2
Part IIIHazardous Waste Container Tank Standards

• Definitions
• Pictures
• Regulations
• Guidance documents

3
Tank Defined

• UFC 9.122 Tank is a vessel containing gt 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.

4
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.

5
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.

6
A Tank is stationary

• A Container is portable

7
Is it a a. Tank or b. Container?
8
Is it a a. Tank or b. Container?
9
Is it a a. Tank or b. Container?
10
Is it a a. Tank or b. Container?
Filter Cake
11
Is it a a. Tank or b. Container?
12
Portable Tank?
13
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.

14
Ancillary Equipment?
Hazardous Waste Piping
15
Ancillary Equipment?
Green Liquid ?
16
Green Liquid pH 13
17
Is it a. Ancillary Equipment or b. A Tank?
Filter Press
Does it Move?
18
Tanks Standards Apply?
Process Tank
Process Tank outflow (waste A). non-hazardous
Settling Tank
Settling tank sludge outflow (waste B),
hazardous waste
Sludge, Hazardous Waste
Heated Drying Tank
Which tanks pipes require a P.E. assessment?
Non-hazardous waste water to sewer
The blue burgundy tanks piping
19
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.

20
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.

21
Answer by the CUPA 2005 DTSC QA 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.

22
Answer by the CUPA 2005 DTSC QA 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
  systemslocated 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.

23
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)

24
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)

25
Material Waste Tank System
Tanks A, B C contain material the piping is
used exclusively to transfer the liquid when is
no longer useful.
Process A
Process B
Process C
No hazardous characteristics
Hazardous
Waste A
A B
ABCD
D is a tank what parts of the system require a
P.E. Assessment?
What if A is a listed pesticide?
D
What if D was a 55 gallon drum that was removed
when full?
26
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)

27
Answer by CUPA 2005 DTSC QA 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.

28
Answer by CUPA 2005 DTSC QA 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).

29
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 dont
  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.

30
Tank?
Process tank
Floor sump
31
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)

32
Emergency Spill Containment or is it Primary
Containment?
Berms surrounding tanks area
Hazwastes on floor
33
Emergency Containment? Secondary Containment?
Floor Sump
34
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)

35
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, its a tank
• Fail If it cant pass, then it is a surface
  impoundment. A surface impoundment requires RCRA
  storage permit.

36
Ancillary Equipment?Secondary Containment?
Plating shop floor
37
Ancillary Equipment?
Floor trenches
38
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

39
Joes Plating Shop
Elevated grate Or catwalk
Is the sump in the floor a tank? Is the
concrete floor ancillary equipment?
40
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

41
What if its 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
  facilitys contingency plan (2) An enforcement
  action for an inadequate contingency plan or
  permit violations or (3) Enforcement action for
  illegal disposal. FAXBACK 12748

42
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

43
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.

44
Wet Floors Is the floor a regulated tank unit?

• They are a problem

45
Big hole in floor beneath acid tank
Acid soln. with copper
46
Deteriorated floor below metal finishing tank
Hazwastes
47
Floor trench used at metal finishing process room
Trench 3 depth
48
Deteriorated floor underneath metal finishing
tanks
49
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.
• DTSCs Weblink to read full consent order..
  http//www.dtsc.ca.gov/HazardousWaste/Projects/upl
  oad/ULTIMA_ENF_CO.pdf
• cont..

50
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.

51
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

52
Some exceptions to remember.. 66261.3(a)(2)(F)(1
),(2)(3)

• And...
• 1. Some F listed solvents that dont exceed 1 ppm
  of discharge, or
• 2. . Some F listed solvents that dont exceed 25
  ppm of discharge, or
• 3. K050, or

53
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

54
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.

55
Some exceptions to remember.. 66261.3(a)(2)(F)(6
)(7)

• 6. K157 that dont exceed 5 ppm by weight, or
• 7. K156 that dont exceed 5 ppm by weight

56
Answer by CUPA 2005 DTSC QA 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.

57
Answer by CUPA 2005 DTSC QA 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.

58
So, Is this OK?
Trench system
Drain opening
59
How about this?
Trench
60
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

61
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/

62
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)

63
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.

64
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

65
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 .

66
Small Quantity Generators California Law
regulation

• HSC 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.

67
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

68
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

69
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

70
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
• HSC 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.

71
Is it Clear now?
A new Study indicates that attempts to thoroughly
understand Title 22 CCR tank standards
contributes to the early onset of Alzheimers
disease.
72
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)

73
Two More Examples

• Dont forget your evaluation

74
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?

75
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.
76
Initial drain sink in lab area for receiving
hazardous waste liquid and piping (gravity feed)
the waste to a lift station sump tank
77
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.
78
Final hazardous waste accumulation drum. Located
inside the waste storage shed that receives waste
from the labs via the lift station sump/tank
system.
79
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 thats what I think.

80
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?

81
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
• Youre right! These standards were not covered
  its advanced training.

82
(No Transcript)
83
(No Transcript)
84
Biotech Laboratory Waste System 2
85
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.

86
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.

87
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.

88
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.

89
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

90
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?

91
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.

92
The End

• Dont Forget Your Evaluations
• If you have any questions, please contact us

San Diego County CUPA john.misleh_at_sdcounty.ca.gov
michael.vizzier_at_sdcounty.ca.gov