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DTSC Finds Hazardous Waste Violations at California Battery Recycler

Posted on 7/29/2016 by Roger Marks

For violations of California’s State hazardous waste requirements found in Title 22 of the California Code of Regulations (22 CCR), a City of Industry battery recycler will take extensive corrective action. According to an order from the Department of Toxic Substances Control, the agency authorized to enforce California’s hazardous waste rules under the State Health and Safety Code, the battery recycler is permitted to manage hazardous waste but failed to comply with critical provisions of the Title 22 rules.

California’s Title 22 hazardous waste rules are often more stringent that the Federal Resource Conservation and Recovery Act (RCRA) requirements, and it’s crucial that generators in the state comply with these unique standards.

Title 22 Hazardous Waste Violations

DTSC inspectors initially visited the battery recycler’s facility in May 2016 and returned on June 9 and July 6. During these inspections, DTSC discovered violations of California hazardous waste rules related to hazardous waste and lead-bearing material stored in a containment building also called the “Batch House,” including:

  • Failure to have in place secondary containment in a building used to manage hazardous waste containing free liquids or treated with free liquids [Title 22, §66264.1101(b)(3)];
  • Failure to have a functioning leak detection and liquid collection system to collect accumulated hazardous waste and liquids at an earlier possible time [Title 22, §66264.1101(b)(3)];
  • Not operating the containment building in a way that minimized the possibility of any release of hazardous waste or hazardous constituents to the air, soil, or surface water [Title 22, §66264.31]; and
  • Failure to repair a condition that could lead to or has caused a release of hazardous waste [Title 22, §66264.1101(c)(3)].
To settle the allegations, the battery recycler has agreed to a schedule for compliance that includes:

  • Immediately ceasing to put hazardous waste or other lead-bearing material in the containment building;
  • Completely enclosing the containment building—meaning, at minimum, fixing any holes in the walls or ceiling and sealing all gaps or spaces under doors—in line with the requirements of Title 22, Division 4.5, and having the work certified by a professional engineer (PE) registered in California;
  • Establishing a functioning leak detection and liquid collection system and having the engineering design approved by a California PE; and
  • Creating a work plan, to be approved by DTSC, for removing all stored hazardous waste and other lead-bearing materials from the containment building.
Spillable batteries containing lead

Lastly, DTSC reserves the right to assess a monetary civil penalty at a later date for the violations outlined in its enforcement order. The maximum civil penalty for hazardous waste violations in California is $25,000 per day, per violation.

See the full DTSC hazardous waste Enforcement Order here.

Title 22 Hazardous Waste Training for California Generators

If you manage hazardous waste in California, you must know the unique, stringent Title 22 requirements that apply to your site. Knowing the Federal rules is not enough—California’s hazardous waste regulations are more complex and stricter than the US EPA RCRA standards.  At the Hazardous Waste in California Workshop, learn the latest rules, discover exceptions and reliefs you can use, and be confident you know what it takes to keep your site safe and in compliance.

Can’t make the workshop this year? The same expert training is now available in an interactive online course format. Packed with exercises to keep you engaged, this online course is an effective, convenient way to meet DTSC’s annual training requirement for hazardous waste personnel.  

Tags: California, DTSC, hazardous waste, state rules

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