Managing Hazardous Waste

We protect the environment and communities by ensuring compliance with hazardous waste laws

HWPlan Public Feedback

DTSC encourages input for the development of Hazardous Waste Management Reports and Plans. Feedback submitted to the Hazardous Waste Management Plan (HWPlan) Unit by email or the Public Feedback Form are listed below. If you would like to submit feedback or ask a question click the button below to complete the Public Feedback Form. 

Public Feedback Form 

Letters

Feedback submitted by email to: DTSC_HWPlan@dtsc.ca.gov

Date ReceivedComment or QuestionSource
7/5/2025I’m reaching out to request any informal feedback DTSC may be willing to offer regarding our interpretation of hazardous waste determination requirements under 22 CCR §66262.11 and DTSC-specific requirements, particularly as they relate to post-fire debris containing structurally altered or mixed materials.

Based on DTSC’s published guidance—including the “Defining Hazardous Waste” webpage, the 2015 Generator Guidance Manual, the 2023 Hazardous Waste Management Report, and related training resources—our understanding is that waste must be evaluated at the time of generation, and that the characterization must reflect the condition of the material at the time waste is generated.

This is particularly relevant in the case of fire debris where multiple materials have been structurally altered and now exist as a non-separable composite, where building components no longer exist as individually characterizable waste streams. This is especially important when considering any known or potentially hazardous constituents that may have become minor components of the overall debris matrix. In such cases, we interpret the regulation to require analytical testing to properly characterize the resulting waste stream.

At the same time, we recognize that generator knowledge supported by existing data may still be appropriate for clearly identifiable, intact, and separable materials, where applicable, provided that the determination remains consistent with the requirements of §66262.11.

We’ve summarized the basis for this interpretation in an internal footnote that supports our planning approach. If helpful, I’d be glad to share that summary for your informal review.

To be clear, we are not seeking project-specific advice or feedback tied to any particular site. Rather, our intent is to confirm whether our interpretation aligns with how DTSC applies its regulatory standards under Title 22 and the Department’s own established procedures. Since these standards are meant to apply equally across all generator projects, we’re seeking input that reflects how DTSC would expect the regulation to be interpreted and applied in general—not based on the unique facts or conditions of any one case.

For clarity, our key questions are as follows:

1. Are we correct in our interpretation that hazardous waste must be evaluated based on its condition at the time of generation, rather than its historical product identity?
2. Are we correct in interpreting that where materials have been structurally or thermally altered (e.g., fire debris that exists as a non-separable composite), analytical testing is required when generator knowledge is no longer sufficient to support a defensible waste characterization determination?

Please let me know if you have any feedback or if a more formal submittal would be preferred.		HWPlan Email
7/3/2025To whom it may concern:

Chiquita Canyon, LLC provides the attached comments on the 2025 Draft Hazardous Waste Management Plan prepared by the Department of Toxic Substances Control and presented to the Board of Environmental Safety for approval under section 25135 of the California Health & Safety Code.

Please let me know if you have any questions.		HWPlan Email
5/14/2025Because of the arsenic from burnt materials containing glues and lead in old paint and nylon, and chromium plated objects, the fire debris need to be sorted through and those contaminated with toxins need to be sent to hazardous waste dumps where they could be recycled carefully. If mixed with regular trash, it would become unsafe to recycle regular trash in the future. Toxins could contaminate organic matter in the trash that might later become fertilizer for farms. We cannot keep piling up trash until it blows onto neighbors' heads. A new toxic waste dump or recycling facility with best available control technology is needed where nobody lives and there are no endangered species.HWPlan Email
5/14/2025I am writing to object to the proposed Hazardous Waste Management Plan. In Chapter 7, toxic soil is to be sent to landfills that were not built to handle hazardous waste. This is clearly not protecting the nearby communities, which is what you are supposed to do. I urge you to include actions that will reduce the creation of hazardous waste and to revise the plan so it also includes the updates of changes demanded by communities.HWPlan Email
5/13/2025Please so not allow hazardous waste to be deposited at our local landfills. This includes contaminated soils from the Los Angeles fires of earlier this year. HWPlan Email
5/13/2025I strongly oppose the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California.
We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because managing them locally is more convenient and cost-effective. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place it in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.
Communities near landfills already face severe environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks, through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals.
Instead of lowering our standards, California should lead the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.
I would like you to reject this plan, extend the public comment period, and host more community hearings to make sure that the voices of frontline communities are heard and respected.		HWPlan Email
5/13/2025I strongly oppose the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California.
We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because managing them locally is more convenient and cost-effective. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place it in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.
Communities near landfills already face severe environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks, through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals.
Instead of lowering our standards, California should lead the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.
I would like you to reject this plan, extend the public comment period, and host more community hearings to make sure that the voices of frontline communities are heard and respected.		HWPlan Email
5/13/2025The North Valley Coalition of Concerned Citizens Inc. is writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local Class III landfills, represents a dangerous step backward for public health and environmental safety in California.

We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.

For instance, the Sunshine Canyon Landfill, the largest landfill in the County of Los Angeles is already accepting 2.2 million tons of trash per year. In just a few short months they have already received over 189.000 tons of fire-related debris that was also reclassified thanks to the Water Board... material that should have been sent to a Class I Hazardous Waste Landfill.... and more tonnage expected. While this landfill does have a double liner and leachate collection system, we all know that a liner will only last 25 years at best, and a double liner 50 years. As the leachate collection system ages it silts up, becomes clogged, and collapses. All this, in one of the most seismically active area in all of California, right next to water treatment plants and the LA Reservoir and right next to the communities of Granada Hills and Sylmar. Why because the local authorities and politicians have allowed this in order to have cheap disposal of trash, and the fact that they won't be around to be held accountable for the inevitable contamination and suffering that it will eventually cause. Also, our landfill is located in a pass and the prevailing winds bring odors and dust (over 18,000 odor reports and over 400 NOVs since 2009). Residents have complained for years about the health impacts. The dust is everywhere; residents are having their insurance cancelled because of the accumulation of it on their roofs. If Class III landfills are allowed to take the reclassified hazardous waste soils without any consideration as to the prevailing conditions that exist at those landfills including their proximity to our water supplies, and not just whether or not it has a liner and leachate collection system, it is an environmental disaster waiting to happen, and you will be complicit if you reclassify any currently hazardous waste to non-hazardous or allow said material to be deposited in a Class III landfill.

Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.

The North Valley Coalition of Concerned Citizens Inc., urges you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected.		HWPlan Email
5/12/2025I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California. We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification. Communities near landfills already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals. Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source. I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected.HWPlan Email
5/12/2025I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California.

We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.

Communities near landfills already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals.

Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.

I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected.		HWPlan Email
5/10/2025I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California.

We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.

Communities near landfills, already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals.

Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.

I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected.		HWPlan Email
5/7/2025I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California.
We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification.
Communities near landfills already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals.
Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source.
I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected.

HWPlan Email
4/30/2025Hello, I watched the presentation put on by DTSC staff last week and was wondering if I could get a copy of the presentation?HWPlan Email
4/11/2025Hello,
My name is Madison.
I am inquiring about the process to create a waste management plan.
Is there any information that can help me with creating our plan as we just were notified this is a requireme		HWPlan Email
3/14/2025The California Environmental Justice Coalition (CEJC) has written the attached letter to express our deep concerns about DTSC's proposed inclusion of alternative management standards for non-RCRA soil in the updated Hazardous Waste Management Plan. Many of us have been working on hazardous waste issues and engaging as DTSC stakeholders since the 1990s. Yet, we were not consulted about this significant policy shift. This lack of communication is disingenuous and suggests an attempt by DTSC to advance major changes without the input of long-standing stakeholders and impacted communities. We urge DTSC to honor its responsibility as a regulator by prioritizing community health and environmental safety over policies that weaken existing protections. As we have done in the past, CEJC is open to working with DTSC to find solutions that truly benefit all Californians, especially environmental justice communities.

Please feel free to reach out to me to engage in further dialogue pertaining to this issue. Thank you for your time.		HWPlan Email
3/7/2025Please see the attached request on behalf of the California Environmental Justice Coalition, Valley Improvement Project, Greenaction for Health & Environmental Justice and the National Diversity Coalition. We respectfully request that public comment for the Hazardous Waste Management Plan begin no earlier than 11 AM on 3/20, as we have more than 50 constituents from across the state traveling for the meeting that would like to participate.HWPlan Email
2/21/2025Good morning,
I would like to know which landfill or Solid Waste Collectors, near Somis, CA (Ventura County), can provide us with and direct us to for disposing of Total Petroleum Hydrocarbons soil described in the attached PDF.

There is approximately 1,356 tons of material that we need to dispose of for this Caltrans project.		HWPlan Email
2/10/2025Hello,
I wanted to subscribe to the email list for updates on the Hazardous Waste Management Plan updates for 2025 plan year
HWPlan Email
1/28/2025Good afternoon,
Are you able to provide a copy of this workshop presentation from October 30, 2024?		HWPlan Email
1/9/2025Please accept the attached comment letter on behalf of Tayo Legacy Foundation regarding the DTSC's planned hazardous waste proposal .HWPlan Email
1/9/2025Hello,
Please accept the attached comment letter on behalf of I AM 1112 regarding the DTSC's planned hazardous waste proposal .		HWPlan Email
1/9/2025Can you tell me how this senate bill will affect repair shops?HWPlan Email

Date ReceivedComment or QuestionSource
11/14/2024I noticed that DTSC has scheduled two workshop on Wednesday, November 20th at overlapping times.

• Virtual Workshop on Candidate Chemicals in Children’s Products 9:30 to 12:00 pm
• Virtual Workshop: Modernization of Analytical Test Methods and Updates to Regulatory References 10:00 am to 12:00 pm

Although it is unlikely that the times can be changed this time but please avoid scheduling workshops at the same time.

Please let me know if you have any questions.		HWPlan Email
11/14/2024To whom it may concern,

I am emailing you from Valar Atomics, a startup company working in the alternative fuels industry. We are in the process of establishing a laboratory space in Hawthorne, CA, and are looking to ensure that hazardous laboratory waste is handled properly.

On your website I see that there is a list of active transporters of hazardous waste—is there anything else needed from us in order to register with the state of California as a producer of waste, or should we contact the transporters directly regarding safe disposal of waste? We will be generating waste from the U-list designation.

Thank you, 		HWPlan Email
11/11/2024I had a questions regarding the Universal waste storage. Caltrain has multi locations like for example the stations or railyards besides a main maintenance facility. Can universal waste be consolidated at one location, like the maintenance facility? Can you please provide reference o CA code of regulations that I can refer to specifically for the universal waste storage, transport and disposal?HWPlan Email
11/1/2024Hello,
Thank you for the informative workshop on Incinerable Waste – Cradle to Grave on Wednesday, 10/30. It addressed many aspects relevant to my current work and the challenges that our organization faces, particularly regarding incinerator shutdowns (Reworld to shut down California’s last MSW incinerator | Waste Dive; Reworld to close Oregon facility, further limiting West Coast incinerator presence | Waste Dive) and waste management solutions.

The complexities surrounding hazardous waste (hazardous pharmaceuticals) and regulated medical waste (including biohazardous waste, pathology, sharps, non-hazardous pharmaceuticals, and trace-chemotherapy) seem to be outside the focus of many discussions. I believe this would be an excellent topic for a future workshop.		HWPlan Email
10/23/2024Hello,
I had a few questions after attending this workshop yesterday:

1. Are companies required to put a caution, hazard, warning type label on any product that is considered hazardous waste?
2. You said in the workshop that generators are required to determine themselves if something is hazardous. What incentive do they have to do all the checking or testing for this? Is there a penalty if they don’t?
3. I know that large amounts of hand sanitizer are considered hazardous waste, but a small amount does not seem to fit any of the categories talked about, since it’s ok for human use. How is this determined? I’m assuming it’s because large amounts could potentially be flammable. And I guess it would be up to the business or consumer to decide if it’s enough to be hazardous?		HWPlan Email
10/22/2024Can I get a recording of the meeting?HWPlan Email
10/22/2024Our company is leasing an auto repair facility that has an outdoor storage area. This is an area that has block walls on three sides and has no roof. It is about 8 feet from the main building. It houses our 2 large bulk oil tanks, one of which is our used oil. It also contains waste drums of used absorbent, brake fluid and other waste. The area has double gates that are kept locked. There is no berm that would contain a spill inside the structure. I am concerned about compliance issues. Can you tell me if this structure is in compliance and if not what steps if any need to be taken to make it compliant.HWPlan Email
10/18/2024What was the reason for codifying VSQG definition but not all the management practices under 40 CFR? What was the negative impact the DTSC saw that made them not to adopt VSQG standards in 40 CFR? DTSC stated at the last CUPA Conference there would be more guidance and workshops regarding GIR, is there a website location that list these workshops?2024 Workshop 6 Pre-Workshop Survey
10/11/2024The current DOHS 22 hazardous waste test method that is required to be completed for assessing hazardous waste is an in vivo fish assay. I have been doing some work with some partners at aQuaTox Solutions, Eawag, and Peta Science Consortium on the topic of comparing the DOHS 22 protocol to the in vitro OECD TG 249 test methods using a complex mixture relevant for industry, and we thought you might be interested in our progress. Recently, I attended PANWAT’s regional conference and presented a poster on a case study comparing results from the DOHS 22 and OECD TG 249 protocols. I have provided the poster and abstract to Renee Roberts (DTSC) and Shannon Murphy (OEHHA) as further information for the OECD TG 249 test method to be considered as an acceptable test method in the State of California. We believe that OECD TG 249 would be more protective (results were more conservative than the DOHS 22 protocol), more informative (in vitro assay defines the mode of action driving gill cell death), and in line with a growing trend for pursuing alternative testing strategies (i.e., NAMs) to traditional animal-based test methods. My collaborators and I have more testing in progress and plan to continue to present/publish on our findings as more data becomes available. Please feel free to contact me if you have any questions. HWPlan Feedback Form
9/5/2024Hello, Thank you so much for your webinar yesterday. I had to leave early due to other meetings. Can you please tell me where this recording will be posted?HWPlan Email
9/4/2024Good Morning, The session today was great! Will the slides and recording be made available?HWPlan Email
8/26/2024We recently moved into a home in Contra Costa county (Walnut Creek) and found two old GE ballasts in the garage. We'd like to safely dispose of these but can not find a service that will dispose of them, can you help?

We've been working to dispose of these for some time and have been denied by the below organizations.
• Contra Costa Sanitary District (Household hazardous waste center)
• Clean Harbors
• Clean Earth
• No response from EPA
• No response from GE
More details on the ballasts below.
• Manufactured by GE
• We think these were used to power street lamps in the 1970's
• They are small enough to move, each is a little larger than a shoe box
• Two ballasts, each weighs about 10 pounds, they are 14 in long and 4.5 in wide
• They are not leaking and have been stored in the garage it looks like since the 1970's so about 50 years

HWPlan Email
8/26/2024Hi, I was not able to attend the live seminar, but I reviewed the presentation and offer this suggestion. I suggest adding the new codes one year but delaying the deactivation of the old codes (181 and 611) for 12 months or other defined period. This would allow permitted facilities time to get their permits modified so that the new codes would be in their permit. This would put a strain on DTSC to reissue all the TSDF permits at the same time. Permitted facilities may need to consider whether they would accept all the new waste codes or just some of them. It should also be clear that the modification to change the waste codes in an existing permit would be a Class 1 or Class 1* permit modification.HWPlan Email
8/23/2024Hi, I was unable to submit my question during today’s zoom call. Will HWTS apply the same conversions from yards to tons for the that was used for code 611 (1.41) to all the 600 series for consistency? Same with the 181 (0.8428) series? Especially since we may be using multiple CA state waste codes for one type of waste now. Thanks.HWPlan Email
8/8/2024Hello, I was hoping to get details about any potential requirement or potential certification needed from the Hazardous Materials / Waste Management Program for a New Dental Practice .HWPlan Email
8/8/2024Are all business required to submit a Hazardous waste business plan? HWPlan Email
8/6/2024Hello, will REHS CEUs be available for the Hazardous waste management plan webinar on 8/7/24 from 10-12? REHSs are always looking for CEUs and those of us with hazmat / HHW experience would find these beneficial.HWPlan Email
6/25/2024I am interested in any available information or upcoming events or reports/plans regarding Hazardous Waste Management contaminants of emerging concern for aquatic toxicity, including for antibiotics and pharmaceuticals. Is there someone that I could talk with about what might be helpful for DTSC including providing information to DTSC?HWPlan Email
5/24/2024Can you assist me in generating an invoice for Caltrans to pay DTSC for the following 4 EPA ID numbers . I am unable to navigate to the website where I drop in my epa id( 4 are below) and generate a invoice .
- CAC003151746 = 659.88 Tons
- CAC003105706 = 3147.12 Tons
- CAC003158482 = 117.992 Tons
> Preliminary Fee Estimate = 3,924 Tons x $49.25 per Ton)
HWPlan Email
4/26/2024I am trying to find someone who can help me categorize 2 specific products. I need to know wether or not these two items are considered hazardous waste and should be disposed of in a special bin or if they can be disposed of with regular waste. The first is an empty aresoal foam window cleaner made by ZEP and the second is a instant ice pack made for one time use. I've been trying to research information for 6 months and from what I see they can be disposed of with regular waste. I need confirmation that what I have read is correct. I hope you can help.
HWPlan Email
4/16/2024I am unable to attend today’s zoom meeting on the Hazardous Waste Management Plan.
Please find the attached proposed policy recommendation. Please also enter this into the official record and let me know to whom I should talk with about the next steps for consideration.		HWPlan Email
4/10/2024How can I sign up for this 4/16/24 virtual event?
HWPlan Email
4/4/2024Is your Virtual Workshop: Hazardous Waste Management Plan Update, cover Dental and Medical waste areas as well?
HWPlan Email
4/3/2024Can RCRA training/DOT training be provided to the HWM employees together in one training?HWPlan Feedback Form
2/8/2024Forwarded a "certificate of liability" for a transporter registration application to the HWPlan mailbox. Verified this should go to DTSC Business Operations Unit.HWPlan Email
1/25/2024You are sending me two emails, please remove one email address.
HWPlan Email

Date ReceivedComment or QuestionSource
12/4/2023Hi there, I have a compliance question for transporting and processing hazardous material- specifically beauty products- in California. Who’s the best person to contact?HWPlan Email
10/25/2023Hello, We were wondering if you had a template for a Hazardous Waste Management Plan for San Mateo County.HWPlan Email
10/23/2023On behalf of our clients the California Manufacturers & Technology Association (CMTA) and Chemical Industry Council of California (CICC), we respectfully submit the following coalition comments related to the Department of Toxic Substances Control’s (DTSC) Hazardous Waste Management Report (Report), released for public review and comment on July 17th. While the signatories understand the comment period closed on September 17th, they nevertheless thought it important to share their perspectives and suggestions as you continue your work on the Report and in preparation of the Hazardous Waste Management Plan due in 2025. If you have any questions or if you would like to discuss the comments further, please contact me and I’d be happy to set up a meeting among all of the signatories. Thank you.HWPlan Email
10/18/2023Good morning. On behalf of the California Council for Environmental & Economic Balance (CCEEB), I respectfully submit the attached comment letter regarding the DTSC Hazardous Waste Management Report. Although the official comment period has closed, given this is not a formal rulemaking item and your work to refine the Report, its underlying data, and its use in the preparation of the Hazardous Waste Management Plan (Plan) due to be released in 2025 is ongoing, CCEEB and its members wished to nevertheless provide these comments for your consideration. We appreciate your review of these comments and would be happy to discuss further at your convenience. Thank you.HWPlan Email
10/18/2023Hello,
I am trying to get some clarification for the requirements of obtaining a Temporary EPA ID Number,

One of my customers called DTSC and someone explained that a business( LLC, CORP, INC ) is not required to enter a TAX ID.
Can you please clarify if this is correct, and when is the only time a TAX ID is required when pulling a EPA ID?
HWPlan Email
10/12/2023

In order to perform an environmental site assessment, we would like to request all available documents such as permits, violations, inspections, environmental documents, UST reference, and all other documentation (between January 1, 1950, and today) for the property at...

1090 Shary Circle, Concord, CA 94518 (APN: 129-341-018-7)

Thank you for your help with this project.

(Gem Group Project 23-17478 public records request sent 10/12/2023)
HWPlan Email
10/6/2023AwesomeHWPlan Feedback Form
10/3/2023Hello! Would you be willing to have somebody come down to San Diego and speak to us about your Hazardous Waste Management Plan? I work with a non-profit organization called the “Environmental Bankers Association” (EBA). We educate bankers on environmental issues to help manage environmental risk for lenders and small businesses. We host an annual conference and typically have regulators from the host state come and educate our members. We are having our annual conference in San Diego on February 5th to 8th 2024 and would love to hear from you! Please let me know if you have anybody that would be interested in speaking with us. If you wanted a little more info about who the EBA is, their info is below. https://www.envirobank.org/page/AboutUsHWPlan Email
9/28/2023I am an Arizona graduate student and concerned citizen with a question regarding the Draft Hazardous Waste Management Report from the beginning of the year. I have read that this report proposes ending out-of-state hazardous waste dumping starting in 2025. Is this true? If not, are there other conversations being had in your state to end this practice?
HWPlan Email
9/22/2023I am an engineer and project manager from the Site Mitigation and Restoration Program. I have cursorily reviewed the Hazardous Waste Management Plan and have the following comments and suggestions.

Draft DTSC Hazardous Waste Management Plan Review
Comments

1. The report was informative and provided valuable insights, and was easy to read and navigate.
2. At the recent report out to the Joint Legislative Committee, the following issues were described by the individuals who made comments at the hearing (paraphrasing of their complaints):
• reneging on previous commitments during EIR processes when deals were allegedly made with polluters that would allow too much contamination to stay on site,
• delays in implementing promised cleanups,
• incomplete cleanups,
• recalcitrance to using bioremediation and new technologies and taking early action,
• excessive use of capping, land use restrictions, and dig and haul,
• compromises made with polluters without consultation with stakeholders,
• excessive use of CEQA exemptions when EIRs and public review are needed, and
• lack of inclusion of cumulative impact among others.
If they are not already included in the Plan as categories for further research, perhaps they should be included or addressed in some way.

3. Some facilities in HWTS only have one year of reported waste manifests, but continue to operate. Does DTSC check what is happening with the waste that once was documented but no longer appears on the manifest log?
4. Some facilities (e.g. metal recyclers/shredders) claim that their materials are not waste or that it exempt from HWCL due to a granted variance. How does DTSC require the facilities to prove continuously that the waste or materials are exempt?
5. Some facilities (e.g. metal recyclers/shredders) deny that their processes fall under the category of “treatment”. How will DTSC provide certainty regarding this term and the storage and disposal terms with respect to all of the various hazardous wastes generated in the state?
6. In auto dismantler and salvage yards, there is often motor oil all over the ground surface. How are releases prevented in auto dismantler and salvage yards?
7. How does DTSC plan to effectively communicate its definitions, rules and regulations and expectations, incentive and incentives to achieve its hazardous waste management goals?
8. Can DTSC make sure all generators carry adequate pollution liability insurance?

9. Consider using 24-hr LIDAR, spectrophotometry, and infrared to monitor for emissions and leaks and capturing plume extents and particle sizes.

10. Consider using breathing zone air pollution monitoring using mobile monitoring of communities.

11. Considering using real-time community air pollution monitoring and alert systems equipped with 360 degree LIDAR, spectrophotometry and infrared recording capacity.

12. Consider using drone technology to sample inside plumes.

13. Consider including in permit language rights for DTSC to use these methods and to report data to the public.

14. Consider reinstating pollution prevention program and working with Water Board LEAs to incorporate elements into the annual SWPPP inspectionsy.

15. Consider separate legislation, regulations and rules for recycling solid resource streams that are hazardous (e.g. metal shredder, metal recycler facilities, wastestreams with recoverable portions). Consider using this to incentivize innovations in producer stewardship/circular economy.

16. Consider requiring producer stewardship/circular economy and concurrently removing the incentive to remain a generator only by having requirements of generators similar to those of TDSF. This puts research and development in the hands of producers who have the ability to generate revenue to develop those. Through R&D they can develop a service industry for themselves that implements the developed technologies.

17. Consider using CERS reports as basis of operations/facility inspections.

18. Consider streamlining RMR and exclusion and exclusion compliance reporting to make it available for public scrutiny. Raise awareness of the only 8 exclusions vs 44 federal exclusions for RCRA wastes by providing more education outreach on that.

19. Consider more public outreach/education regarding non-RCRA an RCRA regulated wastes and expectations about and resources for hazardous waste management and resource recovery.

20. Some facilities currently under-report their hazardous materials and wastes on the CUPA CERS business plan. CUPA inspector should be able to identify these discrepancies, and fines and penalties should be issued for these omissions.

21. Consider requiring/incentivizing large size cleanup sites to site a treatment facility on site for on-site treatment and incentivizing them for accepting and treating hazardous waste from smaller sites. Incentives could be fast-track evaluations, guidance, and process certifications.

22. Consider creating a testing, certification, and demonstration process for new resource recovery and treatment processes like ARB Executive Order process for emissions control devices.

23. Consider turning hazardous waste landfills increasingly to resource recovery and treatment centers. Consider using these centers as incubators for technology and hazardous waste treatment startups who can become part of a network of hazardous waste treatment and disposal facilities.

24. Consider including a method for reducing impacts from illegal dumping of hazardous substances.

25. Consider creating new categories of landfills for hazardous waste treatment and resource recovery landfills of different types. Considering different certification levels for these landfills that create different standard levels allowing for entry opportunities, as well as opportunities for service level differentiation.

26. For the zoning data field and for the zoning and geographic analysis, consider including a field for names of community plans, and any special environmental justice-related overlays, plans or zoning restrictions including local hazardous waste management plans.

27. Consider including a requirement to provide proof of the selected NAICS/SIC for a given facility and to demonstrate of adequate pollution liability insurance for the given NAICS/SIC.

28. Consider requiring digital reporting of hazardous waste management data.

29. Consider including a description of investigation/discovery and enforcement activities, and giving statistics related to these activities including the amounts of fines and the costs of resulting cleanups to RPs, acres cleaned up and certified, acres redeveloped and revitalized with examples of successful corrective action cleanups and enforcement activities.

30. Does the HWMP include all of the following essentials of hazardous waste management which to some extent require coordination with sister agencies? Consider ongoing formal knowledge, data and resource sharing and coordination with sister agencies for resource development and more effective action especially with complex facilities. Considering making publicly available compliance/non-compliance status on such facility requirements. Consider using this data to issue regular warnings, reminders and to suspend and revoke permits and authorizations.
Maintaining a DTSC permit;
Maintenance of a CUPA/fire safety permit;
Maintenance of adequate pollution liability insurance;
Maintenance and reporting of a hazardous materials business plan and report of onsite
hazardous materials,
Maintain operations plans,
Maintain closure plans,
Stormwater pollution prevention plan compliance,
Industrial wastewater permit compliance,
Management and tracking of emissions, discharges, disposal, recycling, reuse, and
reclamation,
Staff certification and training in hazardous materials and waste management,
Containerization,
Hazardous/storage communication (e.g. chemical, hazards, start date of accumulation)
information labeling of the subject wastes or materials containers,
Maintenance of inventory records that contain source information (specific source
company name, industry code, process, stage, hazardous classification, types of waste
including names of specific chemicals if known, and planned destination (e.g. recycling
facility, internal reclamation, or reuse, etc.),
Available chemical data safety sheets for hazardous materials on site,
Disposal of hazardous waste with a permitted transport, disposal, and storage facility
(TDSF),
Maintenance of a log of inventory movement including a manifest log,
Maintenance of Records of any exclusions and documentation that criteria for exclusions are
continuously valid

Please let me know if it would be helpful for me to elaborate further on any of these.

Thanks for your hard work on this.
HWPlan Email
9/17/2023Please see attached.HWPlan Email
9/17/2023Please find attached my comments on the Draft Hazardous Waste Management Report. Please confirm receipt of these comments.HWPlan Email
9/16/2023Please find attached comments from the Del Amo Action Committee on the Draft Hazardous Waste Management Report.
Do not hesitate to contact us anytime.

HWPlan Email
9/16/2023Please find attached comments from the Rural County Representatives of California on DTSC’s Draft Hazardous Waste Management Report. Please let me know if you have any questions or have any difficulty accessing this .pdf.HWPlan Email
9/15/2023Thanks again for the great talk today. I wanted to circle back after taking a last look at the hazardous waste report, and I think there are few things I would highly recommend changing if that's an option.
1. Page 3 - I recommend striking the word "contaminated" from before soil on the last bullet point, since from our conversation it appears that a significant portion of soil being manifested actually not contaminated under any federal or California cleanup laws.		HWPlan Email
9/15/2023Dear Department of Toxic Substances Control’s Hazardous Waste Management Plan (HWPlan) Unit:
Please see attached for a public comment letter regarding the Draft Hazardous Waste Management Report from the undersigned organizations: California Environmental Justice Alliance (CEJA), Center on Race, Poverty, & the Environment (CRPE), Parents Against Santa Susana Field Laboratory, and Physicians for Social Responsibility - Los Angeles (PSR-LA). We look forward to continuing to engage with you regarding the development of the statewide Hazardous Waste Management Plan.
HWPlan Email
9/14/2023To whom it may concern,

Please see attached comments re: the Hazardous Waste Management Plant. Appreciate the opportunity to provide feedback.

HWPlan Email
9/13/2023Are these workshop presentations archived and available for viewing if unable to attend the original presentation?HWPlan Email
9/13/2023Hi, is this webinar available to view on line? I was not able to attend the live versionHWPlan Email
9/13/2023When are comments due? Sunday 9/17 or Tuesday 9/19?HWPlan Email
9/8/2023I am a dentist and I am applying for a temporary EPA hazardous waste number so that I might properly dispose of a non functioning X-ray head containing a PCB
liquid.		HWPlan Feedback Form
8/24/2023I apologize for the delay in response. We appreciate the notification of the availability of the 2023 Draft Hazardous Waste Management Report, developed as a deliverable to comply with SB 158. We read the draft report and provide the following informal comments on the document on topics related to disposal and water quality requirements.

California Water Code, section 13173, defines designated waste (in part) as hazardous waste that has been granted a variance from hazardous waste management requirements pursuant to section 25143 of the Health and Safety Code. California Code of Regulations, title 27, requires designated waste be disposed in Class II waste management units. The report should acknowledge this as an alternative way for hazardous waste to be disposed that DTSC may not track.

The report includes a discussion on treated wood waste as a hazardous waste with a variance, treated wood waste is able to be disposed at a non-hazardous waste landfills as long as alternative management standards are followed (composite-lined Class II, Class III, and municipal solid waste landfills). This is a separate distinction from treating the material as designated waste.

Further, the report includes a discussion on treated wood waste not being required to follow the hazardous waste manifest and disposal requirements, but the report does not include a similar discussion on chemically treated metal shredder residue (CTMSR). Title 22, section 662641.4, Exclusions, includes distinctions for CTMSR to be considered as not hazardous for purposes of off-site transportation and disposal as long as the CTMSR is similarly disposed in composite-lined facilities.

Water Board staff also recommend DTSC consider other treatment alternatives for certain waste streams considered to be hazardous. Water Board staff urges DTSC to consider treatment alternatives for green materials that could be considered hazardous waste based on toxicity. Water Board staff have had many discussions with DTSC and CalRecycle staff regarding materials such as unprocessed cannabis that exceed toxicity thresholds. Water Board staff urge DTSC to consider composting as a viable treatment alternative for this and similar unprocessed green materials as composting transforms the waste into a renewable product. The report indicates if all hazardous waste was to be disposed in California (rather than being transported out of state), there is 20 years of remaining capacity. While waste oil and soil are the majority of manifested waste streams, viable options for any waste streams would be beneficial to support a more circular model.

Regarding the question on the definition of secure landfill, we are unaware of any regulation where the term is defined. Based on a search, it seems a secure landfill could be any landfill constructed to modern landfill design criteria to isolate waste from the surrounding environment.

We appreciate the opportunity to comment on your draft document. We are happy to meet to discuss more if that would be beneficial for you. We look forward to continuing to collaborate on related topics.		HWPlan Email
8/17/2023Good afternoon, I registered for the 2023 Draft Hazardous Waste Workshop and I was unable to attend. Was this workshop recorded? If this was recorded, then will you please inform me on how I can access it? Thank you.HWPlan Email
8/15/2023Hello! I was not able to attend the whole workshop last week (Aug 9th), would you be willing to share the recording? Thank you.HWPlan Email
8/14/2023Is there a date when comments are due on the Plan?
Thank you for responding to my question.		HWPlan Email
8/14/2023Hi there, I hope you had a good weekend. I am wondering when/where the recording can be found for the webinar that occurred last week? Thank you in advance!HWPlan Email
8/11/2023Can you share the recording of the webinar conducted earlier this week?HWPlan Email
8/10/2023Hello DTSC, I was not able to attend the entire Workshop. By any chance was it recorded to be uploaded to your website so the public can view it later? Thank you.HWPlan Email
8/10/2023It was interesting what was presented and well thought out.  But I cannot help the feeling that we (CA) are sending hazardous waste outside to other states so not to deal with the waste.  I appeared to me that NMBY “Not in my backyard” was the most prominent feature.  This was my impression.HWPlan Email
8/10/2023is the meeting over?HWPlan Email
8/9/2023Will this workshop be offered again in the near future? There is a conflict with the Report Writing Training this morning. Thank you!

HWPlan Email
8/9/2023Will any of this be recorded in case I cannot stay on for the entire presentation or I get disconnected?HWPlan Email
8/8/2023Can you share an agenda for tomorrow’s workshop? Didn’t see it on your website.HWPlan Email
7/31/2023What type of CEQA document will be prepared for this plan? Also, will the plan be considered a land use plan for purposes of CEQA? Should project proponents make sure their projects comply with the plan as part of their CEQA analysis for their projects?HWPlan Feedback Form
7/28/2023Hi, is there a deadline to submit comments on this draft report? Thanks.HWPlan Email
7/27/2023There should be MORE hazardous waste drop off sites. I am a senior and live in Sonoma. I'm told I have to drive north to a site in Petaluma to drop off rat poison and paint. Since that is not an option for me, I'm told by others to just dump the rat poison and I DO NOT WANT TO DO THAT, as it would pose a danger to wildlife. More drop off sites with scheduled pick-ups should be a PRIORITY!!!HWPlan Feedback Form
7/26/2023These emails need more context to generate interest. What is this report for? Who writes it?HWPlan Email
7/19/2023Good Morning! We received the email regarding the Wednesday, August 9 workshop and are very interested in attending via Zoom, however we have an all-day conference already planned for that day that we cannot miss. Is there any way to get a recording of the workshop afterward so we can review it? Thank you in advance for your time and assistance with this,HWPlan Email
7/19/2023Thanks for the prompt response. I had downloaded the full report and did not realize tables were still separate as some sections (i.e. 3) did have the tables inside the full report.HWPlan Email
7/18/2023Greetings DTSC HW Plan Team Member, I registered for the meeting and received a Zoom invite (which I still might accept). My plan, however, was to be present (in Sacramento) on the 9th. Is there anything, in addition, I need to do to attend the “in-person”? Thank you

I plan on thoroughly reviewing the 254-page report before attending.		HWPlan Email
7/18/2023Section 7, page 7, last paragraph. The second half of following statement is incorrect: "A generator records on the hazardous waste manifest the quantity of hazardous waste it generates and uploads information from the manifest to DTSC’s Hazardous Waste Tracking System (HWTS)." The HWTS access is limited. The generator does not upload data into HWTS. The statement needs to be revised to indicate the data in HWTS is entered by agency staff (or contractors).HWPlan Feedback Form
7/18/2023Section 4.2.4.2 references Tables 4.2-1 thru 4.2-4 however those tables are missing.HWPlan Feedback Form
7/17/2023Will this workshop be recorded to watch later?HWPlan Email
7/13/2023Ryan Dominguez presented at the 7/12/2023 BES meeting. Ryan Dominguez and Diana Peebler and company are generating a foundation for trust in their work to improve haz waste management in CA and in addressing contemporary public priorities and comments. Thank you Ms. Peebler, Mr. Dominguez, and company! I hope that upper management fully support this very important work.HWPlan Feedback Form
7/10/2023What is the status of the HW Management report that the DTSC website indicates being finalized in Spring 2023. This is all I can find:

The first responsibility of the HWPlan Unit is to prepare a Hazardous Waste Management Report by Spring 2023. The initial report is the starting point to determine the types of information and additional research needed to generate the first hazardous waste management plan. As such, the main objectives of the first report are the following:

Establish a baseline understanding of the management of hazardous waste in the State of California,
Identify data gaps and items that require additional research, and
Develop plans to fill data gaps and complete additional research.
To help achieve these objectives, the first report will include available information regarding items such as hazardous waste streams produced in the state (waste generation, transportation, treatment, and disposal) and hazardous waste facilities that operate in the state.

Following the initial report, the HWPlan Unit will continue to conduct research and gather information in pursuit of completing the first Hazardous Waste Management Plan by March 1, 2025. Thanks for your help !!
HWPlan Email
5/3/2023New fee structure is exceeding difficult for federal facilities to work with as the types and volume of waste generated is now charged at an fraction of a ton yet funding is programmed based on historical volumes, always seeking to project lower amounts of waste generation; yet now more waste streams are subject to the fees. Previous range based method was superior for being in the ball-park with projections. Unsure how to project for waste streams that have lost exemptions and now subject to reporting and fees. A longer lead-in time for implementation is requested or alternative options to accommodate anti-deficiency act criteria associated with federal funding.HWPlan Feedback Form
5/2/2023About two years ago Dr. Yacoub came to our office and delivered a presentation on Pollution Prevention. I am wondering if he is still with the DTSC or if he has retired.
I am looking for someone from the department to make a presentation on the same topic in June. Could you please let me know if you can direct me to someone to make my request. Thanks in advance.
HWPlan Email
3/31/2023Trying to follow-up after the CUPA Conference. Presentation included a website on page 42 that produces a “404-error”. Please advise on correct address.
https://dtsc.ca.gov/hazardous‐wastemanagement‐plan/		HWPlan Email
3/29/2023Good morning,
I hope you're well. I'm an editor at Waste Dive covering hazardous waste. I understand DTSC is scheduled to release its 2023 Hazardous Waste Management Report this spring and possibly by the end of March. I'd like to know if DTSC has a publication date set, and whether there will be a press briefing or press access to an embargoed copy of the report. If so, I'd like to be included in that process.
HWPlan Email
3/1/2023Please forward me a draft (or link to the draft) of the HWPlan once it becomes available. I have 30 years of experience in the remediation of brownfield sites and waste management, and I can provide numerous options on how to reduce the amount of contaminated soil exported off-sites for disposal.HWPlan Feedback Form
2/27/2023Is there a link to file the 2023 Hazardous Waste Management Report? I am on the Hazardous Waste Management Plan | Department of Toxic Substances Control (ca.gov). There is nowhere to file. Can you help me?HWPlan Email
2/17/2023I've been in contact with the DTSC regarding the annual and biennial Hazardous Waste Reports. I asked about the Triennial and was told to check with the email address on this memo. The annual reports person didn't know about a triennial. The website mentioned in the memo does not have it either.
Is there more information? 		HWPlan Email
2/9/2023As an Environmental, Health and Safety Professional in industry for the past 43 years and 40 years of waste profile and manifest preparation, I would like to inquire about the possibility of providing assistance or insight for the HWPlan Team. In my opinion this concept is long overdue but may also be a duplicate of the summary of the Generators Biennial Reports and the TSDF Annual Reports. ThanksHWPlan Feedback Form
2/7/2023Interested in promoting additional avenues for recycling and for generator self-treatment of hazardous wastes to reduce transportation of hazardous wastes for treatment or landfilling.HWPlan Feedback Form
Date ReceivedComment or QuestionSource
5/3/2023New fee structure is exceeding difficult for federal facilities to work with as the types and volume of waste generated is now charged at an fraction of a ton yet funding is programmed based on historical volumes, always seeking to project lower amounts of waste generation; yet now more waste streams are subject to the fees. Previous range based method was superior for being in the ball-park with projections. Unsure how to project for waste streams that have lost exemptions and now subject to reporting and fees. A longer lead-in time for implementation is requested or alternative options to accommodate anti-deficiency act criteria associated with federal funding.HWPlan Feedback Form
3/1/2023Please forward me a draft (or link to the draft) of the HWPlan once it becomes available. I have 30 years of experience in the remediation of brownfield sites and waste management, and I can provide numerous options on how to reduce the amount of contaminated soil exported off-sites for disposal.HWPlan Feedback Form
2/9/2023As an Environmental, Health and Safety Professional in industry for the past 43 years and 40 years of waste profile and manifest preparation, I would like to inquire about the possibility of providing assistance or insight for the HWPlan Team. In my opinion this concept is long overdue but may also be a duplicate of the summary of the Generators Biennial Reports and the TSDF Annual Reports. ThanksHWPlan Feedback Form
2/7/2023Interested in promoting additional avenues for recycling and for generator self-treatment of hazardous wastes to reduce transportation of hazardous wastes for treatment or landfilling.HWPlan Feedback Form
12/9/2022Thank you so much for presenting on the status of the HWMP project at our HHWIE a few months ago. We have another event coming up on Feb 8-10, which is our statewide Used oil and HHW Symposium. We'd love for someone from your staff present something similar for this event, which will have attendees from local jurisdictions all over the state. The event will be held at the Holiday Inn in downtown Sacramento.

Would you be able to present?

HWPlan Email
11/1/2022Dear Hazardous Waste Management Plan Unit, Please see attached the Center on Race, Poverty, and the Environment and Communities for a Better Environment’s comments to aid the development of the Hazardous Waste Management Plan. Please feel free to respond to this email if you have any questions.
HWPlan Email
10/17/2022We have facility in Riverside, CA. I’m trying to look up for the proper waste storage and disposal of used sorbents, contaminated material, and other waste products must be stored and disposed of in accordance to federal, state and local regulations. We are plastic manufacturing company; we make houseware plastic products.

We have some rags and sorbents that absorb all the hydraulic oil from the plastic injection machines. We placed it in the yellow bags (trash bags) that contains all old rags, sorbent full of oil.

Need to know about proper disposal of yellow bags, we didn’t want to put in regular trash compactor until we know that it’s okay or not allowed to dispose of it?

I need to find link that show about hazardous waste program that we can use to do the proper way of spill kit procedures.

Thank you and look forward to hearing from you about proper of disposal.		HWPlan Email
10/16/2022Please add me to your distribution list.HWPlan Email
10/12/2022That is fantastic! We have a subcommittee meeting next week to discuss the materials you mentioned and to develop our strategy. I will let you know if any questions come out of that meeting. You should have 20 minutes to speak, with time for Q&A. I will send you the agenda with the Zoom information a week before the meeting.HWPlan Email
10/10/2022I staff the Contra Costa County Hazardous Materials Commisssion. The Commission is a 14-member advisory body to the Contra Costa County Board of Supervisors on hazardous waste and hazardous materials issues. It was created in 1986 to help draft the first Contra Costa Hazardous Waste Management Plan and has been actively providing advice to the Board of Supervisors ever since. The Commission has interacted with staff from DTSC on a wide range of issues over the years, most recently on the development of policy recommendations concerning the reuse and recycling of lithium-ion car batteries.

The Commission is very interested in your effort to develop a Hazardous Waste Management Plan for the State. They want to initiate a review of hazardous waste management in Contra Costa County to complement the findings of the Hazardous Waste Managment Report that you are preparing in March, 2023.

I would like to know if someone from your staff would be available to attend our next Commission meeting (virtually) on October 27th from 4:00 to 6:00 to provide the Commission with an overview of the scope of the Hazardous Waste Managment Report, a summary of your efforts to date and a timeline for completing the report. I think the Commission will be very interested in providing input to you on the report.

I look forward to hearing from you soon.

HWPlan Email
10/7/2022So as a business I am only required to have the HMBP not the HWMP? And how often must be update this plan? I know I submit it annual to CERS but if after the annual recertification time if I acquire other hazardous materials how often do I update it?HWPlan Email
10/6/2022I was seeing if I could get some information on a Hazardous Materials Management Plan and what the difference is between that and a Hazardous Materials Business Plan? Does the industry you’re in dictate what your plan consists of?HWPlan Email
9/16/2022
I hope you are doing well in your new role regarding the development of the subject plan. I just saw and enjoyed the video and thought it was well done. I guess I am not still sure of what will be the potential outcome of the plan in terms of managing the generation of hazardous wastes and protecting health and the environment in California. Maybe you could clarify it for me.

I have attached for you some comments I made a year ago regarding SB 673 Track 2 and the ability of DTSC to really reduce cumulative risk to communities via permit conditions with the development of these regulations. In reality, land use planning involving industry, etc. has been left to the locals for the most part. At that time, I was aware of H and SC Section 25135, but really didn’t know what DTSC (your unit now) would be doing. In this document I referenced Hand SC Section 25135 and took liberties in suggesting that such an effort could possibly be used to assess options for looking at the “big picture” of managing wastes in California and potentially reducing cumulative risk and adequately protecting vulnerable communities. It seems this law could give DTSC a potential inroad in dealing with locals in their planning and overall efforts to protect the environment. I look forward to hearing back from you. Take care.		HWPlan Email
8/5/2022Good Morning! Is a recording available?
HWPlan Email
8/5/2022I too am sorry that I could not attend 🙁 - I had an important staff meeting that conflicted with it. This topic is very relevant to a campaign I am working on, and all of my co-workers are also interested and equally disappointed that they could not attend. Is there any chance of accessing a recording of the talk?

HWPlan Email
8/4/2022Can I go online and listen to the meeting? I would like to hear if there are new regulations in the works. Sorry I missed it the day got away from me. Thanks for getting back though. Have a good day Sent from my iPhoneHWPlan Email
8/3/2022How are you? It’s a good information from the Hazardous Waste Transportation Presentation.

The logistics of hazardous waste is complicate if you have not worked in the private sector before. Especially, all the hazardous waste transporters would not like to provide any pricing to any governmental agency unless such agency would use the transporter’s service or issue a Request For Proposal (RFP) for hazardous waste or environmental service. The easiest way to initiate the negotiation of hazardous waste transportation pricing is by comparing the use of Danger Goods Freight transportation pricing from the common carriers like UPS, USPS and FedEx. Especially, they have more networks of labor and vehicles (including both trucks and rails). Once you can determine the baseline from Dangers Good transportation pricing from these common carriers, you can then factor in the hazardous waste transportation pricing since the trucker is mostly independent contractor, who does not bind by the prevailing wages (aka union wages or minimum wages in CA) but the per-mile or per-load charge. Therefore, the transportation cost would be factored into the actual distance due to fuel price fluctuation and incremental weathers.

If you want to discuss more about this issue, I am happy to share what I know from my experience in private sector.		HWPlan Email
7/22/2022Question: I am an Environmental compliance inspector with the City of LA and some industrial user has asked me the following:
1) Which waste corresponds to RCRA waste code usually shipped with code 181 in California?
2) Is there a comparison list (and definition) between RCRA and non-RCRA waste? If so , please include a link in your response.
Thanks in advance for your clarification.
Regards		HWPlan Email
7/18/2022Your agencies have done nothing to keep the neighbors safe around this property. Nothing has been done about the sewer line leaking arsenic into the soil. There are high levels of radiation which are not background everywhere. No investigation into the storm sewer and sanitary sewer lines. There has been no offsite monitoring of the neighbors and many neighbors have cancer.HWPlan Email
7/14/2022My schedule is conflicted with our yearly Enforcement Symposium Workshop Series the 3rd Wednesday of the month.
It would have been nice if someone would have reached out since to us, this is a topic very important to our community and we have taken much time to engage in this topic. Decades really.
Disappointed to say the least.
My schedule is conflicted with our yearly Enforcement Symposium Workshop Series the 3rd Wednesday of the month.
It would have been nice if someone would have reached out since to us, this is a topic very important to our community and we have taken much time to engage in this topic. Decades really.
Disappointed to say the least.
HWPlan Email
7/9/2022Is this July 20 webinar going to have any mention of actions to take regarding Santa Susana Field Lab area cleanup? Has boeing, nasa and doe been able to shut down all policing of themselves?

Do you think the childhood cancer incidence ascribed to SSFL toxins in the area has efficacy?

Does DTSC have any involvement at all with the nearby wildlife crossing over the 101? Can you comment on the status of that, even tho it’s not in your domain?
HWPlan Email
6/29/2022Hi there Ryan, I am slightly confused if there is anything I need to do differently at our permanent hazardous waste collection facility regarding the Universal Waste Management Plan? Thanks.HWPlan Email
6/23/2022I just wanted to communicate that I was actually on the call yesterday. However, by audio only.
This was informative review, and didn’t realize how “Universal Waste” was going to be part of this particular report.

A few questions:
Clarification; the totals noted in slides 17-20 indicate that U-waste generated in California is shipped to other countries?

When discussing batteries (lead-acid/Nicad) were totals including various industries, including Telecommunications, back-up, generator start-up batteries from vehicle repairs?

How will the HWPlan impact the regulated community and household community, overall?

Will LED lights (aka LED Light Tubes often now being replaced for old MCL-style tubes) be included as Universal Waste program or part of the HWPlan?

Look forward to your reply.		HWPlan Email
6/2/2022I'm with Murrieta Family Pet Hospital. I need some direction / assistance in figuring out how to dispose of specimens in specimen jars that contain formalin. I have probably about 20-30 containers fairly small in size.
Could someone email me with the information ( do I need an account? cost? etc) or they could contact me via phone at 760-978-5486. I appreciate the help!		HWPlan Email
5/26/2022I am an engineer working on a project and we need information regarding removing and disposing of 1200 gallons of a solution which is 90% Water and 10% ethylene glycol.  This solution is currently inside the piping of an HVAC system. Can you please provide guidance on how we can remove this?HWPlan Email
4/27/2022Thanks for the chance for input. I intent to watch this process closely. I apologize in advance for my soap box comments.

Although HHW is a small portion of the state’s entire hazardous waste stream, the programs serve an important function of providing a safe opportunity for management of HHW and VSQG wastes. These programs are a mandated jurisdiction requirement to develop a program even if there is no specifics on what type of program each jurisdiction maintains. These community service program are not operated by jurisdictions at a profit thus they continue to deserve exemptions for fees and less burdensome requirements. As state in HSC 25218 (c):

To facilitate and increase the collection of household hazardous waste and conditionally exempt small quantity generator waste, it is the responsibility of the state to provide for an expedited and streamlined permitting and regulatory structure for household hazardous waste and conditionally exempt small quantity generator waste collection and handling. Overburdensome regulations defeat the objectives of providing convenient and accessible collection facilities and the protection of public health and safety.

This charge is unlike other hazardous waste generators and should be recognized in the plan.

I can think of a number of topics that can impact HHW/Used Oil programs from development of the Hazardous Waste Management Plan (HWMP) based upon that was win the legislation including:

• Part of the plan is to quantify hazardous Waste (HW) generation. HHW programs already provide more accurate reporting of this generation amount via the Form 303 which includes not only the manifest tracking but the amount of HHW sent on bills of lading. Although there are issues with the Form 303 reporting (and annual OPP reports) in terms of accuracy (story for another time), the hazardous waste management plan should not impose additional reporting or recordkeeping for HHW programs.
• The statute requires the HWMP to reduce hazardous waste generation. This could be a good opportunity for EPR and Product Stewardship which are more established for HHW programs but more are needed. (Paint, SB212, oil, cell phones versus more needed for batteries, marine flares and the “Future of e-waste” project CalRecycle initiated)
• There is a requirement for the HWMP to review the hazardous waste criteria (testing). This was attempted many years ago with the Regulatory Stricture Update (Jesse Huff project) that got shelved (mention of this effort may make the old timers at DTSC cringe). AS indicated in the legislation, detection limits for instruments are much lower now and we could start looking for establishing much lower levels for classification of hazardous wastes(e.g. PFAS limit of 13 ppt used by the SWRCB for landfill sampling). Thus, more hazardous wastes could be added to the list without consideration for how jurisdiction will pay for these collections (Teflon pans to the HHW facility? (Paranoid, maybe)). HSC 25135 (b)(5)(C). Chemicals may exhibit hazards or toxicological impacts but may not deserve to be regulated as “hazardous wastes”.
o “An assessment of additional contaminants, chemical constituents, or hazard characteristics or traits that are not currently included in the hazardous waste identification criteria, and the additional public health or environmental protections that could be achieved if those additional contaminants, chemical constituents, or hazard characteristics or traits were to be added to the hazardous waste identification criteria in the state.”
• This review of the testing criteria should look at the Aquatic toxicity test as discussed in the Retail Waste Working Group. California and Washington are the only states I believe that use the test. There was testing done by a number of District Attorneys that indicated some toothpaste, baby shampoo, vitamins and other common products failed the test. This testing protocol has not been reviewed since the 1970’s when it was established.
• There is also an issue with the “empty” determination for plastic containers that held used oil. They can meet the standard of empty with no continuous flow one day but the next day the oil will flow out in small amounts. Should this criteria be based on a time limit? This was also a recommendation of some of us in the Retail Waste Working Group as well as other issues.
• The Safer Consumer Products initiative is a great start to reducing toxicity on the front end
• There may be an attempt to increase fees for DTSC to cover these efforts which is always a concern for HHW programs and their sponsoring jurisdictions.

These are some of the off the top of my head considerations. I am sure we will find more. I applaud DTSC for taking on this effort even if required by legislation.

Please let me know if you have any questions. Let me know how it goes.

HWPlan Email
4/13/2022Thank you for sending this information out. I participated in the workgroup on lithium-ion battery recycling and would love to participate in this effort as well. Please let me know what you may need from me to join this effort.

HWPlan Email
4/11/2022The following message found its way into my spam folder and has been flagged as suspicious. Gmail gives the following warning about it:
"Be careful with this message
Black Rock Auto Mail could not verify that it actually came from dtsc.ca.gov. Avoid clicking links, downloading attachments, or replying with personal information."

I called dtsc at 1-877-454-4012, and asked about this email, but they could not verify whether it is legitimate or not. So they provided us with your email, and said to contact you about it.

Can you let us know if this was a legitimate message? Please understand that email is easily spoofed and downloading documents from unverified sources can be extremely risky.
HWPlan Email
4/7/2022Why are you sending me this and ignoring the contamination at Hughes/Ratheon Canoga Park?HWPlan Email
4/6/2022To Whom It May Concern,

Clients of ours have received a letter from DTSC (Ryan Dominguez, PE) say that a Hazardous Waste Report is due by March 1 2023 and a Plan is due by March 1 2025 but there are no further details.

What is required to be included in the Report and Plan? Is there a template? We need guidance on exactly what we are supposed to do.		HWPlan Email
4/6/2022Hello Ryan,

Thank you for the quick response. I reviewed the link provided for additional information and from my understanding, Generators (stakeholders) are not responsible for providing additional information to facilitate the States Plan and Report. Is my assessment correct?

Please let me know. Thanks.		HWPlan Email
4/5/2022It would be nice to know which waste reports you are working on?HWPlan Email

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