In October, the California Department of Toxic Substances Control (DTSC) released its first statewide scorecard for permitted facilities that treat, store, or dispose of hazardous waste.
To create the scorecard, California DTSC reviewed 10 years of hazardous waste inspection results and scored each violation with a numeric value indicating its significance and potential for harm.
DTSC added up the violations to arrive at a “final score” for each facility. Scores from 0—20 are deemed “acceptable,” scores from 20—40 are “conditionally acceptable,” and scores of 40 or greater are “unacceptable.”
Scores for all 78 permitted hazardous waste facilities are available here.
How California Facilities Scored
Of the 78 total permitted hazardous waste facilities in the state, the vast majority (64) scored as acceptable. Only 5 were scored “unacceptable.”
According to DTSC’s announcement
, facilities scored as “unacceptable” may be subject to a denial, suspension, or revocation of their permit. Facilities scored as “conditionally acceptable” will be subject to additional permitting requirements and/or operating restrictions.
Violations frequently cited by DTSC include:
- Hazardous waste storage containers in poor condition
- Storage of ignitable wastes too near the property line
- Making false statement on the Hazardous Waste Manifest
- Storage of incompatible wastes together
- Failure to manage hazardous waste in a way that reduces risk of a fire or release
- Improper labeling of hazardous waste containers
DTSC’s new Violation Scoring Procedure to fulfill a mandate in SB 673
, which amended the state Health and Safety Code to require DTSC to establish transparent, consistent procedures to improve the hazardous waste permitting program.
Facilities can dispute DTSC’s score by following the requirements laid out in 22 CCR 66271.53(c).
Why It Matters for Hazardous Waste Generators
While DTSC only scored California’s operating permitted facilities, sites that generate hazardous waste can benefit from the new scoring system. Selecting the right Treatment, Storage, and Disposal Facility (TSDF) is crucial to ensure compliance with Federal RCRA and Cal/EPA hazardous waste standards. If a TSDF improperly stores or disposes of your waste, your facility can ultimately be held liable for releases to the environment.
Many generators trust critical hazardous waste compliance efforts to their TSDF. If your TSDF assists you with hazardous waste ID, applying waste codes, completing LDR paperwork, or other regulated tasks, you should have confidence that they will do what's required to protect the environment, the safety of Californians, and your reputation.
Title 22/RCRA Hazardous Waste Training
For training to ensure compliance with California’s complex, unique hazardous waste laws and regulations, join Lion for the California Hazardous Waste Management Workshop
Meet EPA and Cal DTSC annual training mandates for hazardous waste personnel. Plus, stay up to date on the latest updates to California’s Title 22 hazardous waste regulations and the state Health and Safety Code.
In Spring 2020, the workshop comes to San Diego, Ontario, San Jose, and Sacramento.
Can't join us for instructor-led training?
Train online with reliable, easy-to-use online courses that cover what you must know to properly identify, store, and dispose of your site's hazardous waste.
California Hazardous Waste Management
California Hazardous Waste Management Refresher