State Environmental Faqs

STATE OF CALIFORNIA--HEALTH AND WELFARE AGENCY
GEORGE DEUKMEJIAN, Governor

DEPARTMENT OF HEALTH SERVICES
714/744 P STREET
P.O. BOX 942732
SACRAMENTO. CA 94234-7320

(916) 322-3670 January 18, 1990


Mr. John Randall
Hi-Tech Ind.,Inc.
17029 Devonshire St. #124
Northridge, CA 91325-1679

Dear Mr. Randall:


ANTI-FREEZE RECYCLING
This is in response to your letter dated November 21, 1989. The
questions you have posed regarding the recycling of waste
anti-freeze will be answered in the sequence in which they were
asked.

Question 1:
What are the laws governing the disposal of used anti-freeze?
Answer:
In the state of California, waste anti-freeze (coolant coming
out of an automobile) is considered a hazardous waste and
must be managed as such according to Chapter 6.5, Health and
Safety Code (HfSC), and Title 22, Article 11, California Code
of Regulations (CCR).

Question 2:

1. If a customer chooses to provide an "onsiten recycling service
to one of his customers, would there be laws or regulations
governing that Service?

2. Which laws, how about for his own use, do they differ?
3. How do they differ?
Answer:

If your company were to provide this service utilizing a
device which is transported to a job site to recycle a
hazardous waste, the company providing the service would
be exempt. This is in keeping with the H&SC Section
25143.2.
Mr. John Randall
Page 2


If the company were to buy this unit for their own
recycl ing needs , according to Health and Safety Code
25143.2(c) (2) (A) (B) (C), the company may be exempt in that they
would be recycling their own wastes on-site where the wastes
are generated.

For the purposes of recycling, there is in no practical
difference. If the TTU was for treating hazardous wastes
not for recycling purposes, then the TTU would need to be
fully permitted.

Question 3:

How and where would our customers dispose of the used
contaminated filters?

Answer:

Disposal of such materials must be discussed with the
Departments Waste Evaluation Unit (916) 322-4233. A
determination is made as how to best dispose or treat this
new waste.

Question 4:

What are the current and proj ected laws pertaining to the
transportation of used anti-freeze?

Answer:

Regulations for the transportation of hazardous waste is found
in Title 22, Article 6.5, CCR. The generators management of
hazardous waste is found in Title 22, Article 6, CCR. The
Department has a Transportation Unit which may aid you in
answering many of your transportation questions.

Question 5:

1. What licenses are required?
2. How are they obtained?
Answer:
a. For purposes of recycling, the "service" company
using a TTU, need not be permitted for this purpose.
The company may want to ask the Transportation Unit
regarding the transport of this unit. For the
generator using this service or for their own use,
no permit is required.

Mr. John Randall
Page 3


b. Contact your regional office. Contact
Headquarters.

Toxic Substances Control Program TSCP
Facilities Permitting Unit Transportation Unit
Region 3/BURBANK Headquarters
1405 San Fernando Blvd. 714/744 P Street
Burbank, CA 91504 P.O. Box 942732
(818) 567-3000 Sacramento, CA 94234-7320
(916) 324-2428

Question 6:
How can we find out what Federal Laws apply?
Answer:
Most information can be found in the Code of Federal
Regulations (CFR) Title 40. If you need to talk to someone,
call EPA's Resource Conservation and Recovery Act (RCRA)
Hotline at 1-800-368-5888.

Question 7:
What are the laws for reselling recycled anti-freeze?
Answer:
First, this is dependent upon if the TTU unit is considered
exempt. Then, if the waste anti-freeze which has been
recycled through the unit, can be used again as a product it
will no longer be considered a waste and thus not subject to
the hazardous waste management regulations.

If you have any questions regarding this letter, you may contact
me at (916) 322-4742.


BSincerely,


Patrick F. Rodriguez
Alternative Technology Division
Toxic Substances Control Program

cc: Robert McCormick
Toxic Substances Control Program
714/744 P Street
P.O. Box 942732
Sacramento, CA 94224-7320

PR/PR:db

 

 

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