Date: Wed, 20 Oct 2010 12:42:29 -0700
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Eric Clark <erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
Subject: Re: 90 day area signage
In-Reply-To: <OF574D6D61.689209E1-ON862577C2.00638317-862577C2.0063D7EC**At_Symbol_Here**>
What is the generator status of your facility and what state are you in?  
I'm not familiar with the classification called "episodic generator".  A 
HW generator typically falls into one of three categories:  Large Quantity 
Generator (LQG); Small Quantity Generator (SQG), and Conditionally Exempt 
Generator.  Those 90-day hazardous waste rules apply to LQGs.  If your 
facility's "episode" generated 2200 lbs in a single calendar month, then 
it's classified as an LQG for the entire year, and indeed all those 90-day 
rules, signage, and fees apply.  
If you would tell me your facility's generator status, then I can give you 
a more accurate answer as to what your facility's HW regulatory requirement
s might be.   

Eric Clark, MS, CCHO, CHMM 
Safety & Compliance Officer 
Los Angeles County Public Health Lab  

>>> Maria Race  10/20/2010 11:10 AM >>>
Does anyone know what the regulatory citation is for signage for a 90 
area?  Usually, you see signage that says something like "Hazardous 
Accumulation Area" then some other verbage which I've seen vary.  I 
find the citation.  This is for an episodic generator, not a TSDF.

Maria Race

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