California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting

Enforcement Advisory Council Meeting—March 30, 2000

June 27, 2000

Ernest Genter, Chair, EAC
Solid Waste Local Enforcement Agency
Lassen County Public Health Department
555 Hospital Lane
Susanville, CA 96130

Dear Mr. Genter:

Thank you for sending the Enforcement Advisory Council (EAC) Resolutions 00-1 and 00-2 which were passed at the March 30, 2000 EAC meeting.

Resolution 00-01

Disposal of Metallic Discards:

We expect to have a response from our Legal Office, by June 23, 2000, regarding the disposal of metallic discards and necessity for removal of substances which require special handling prior to disposal. We will report to you the results of the legal analysis.

Health and Safety Code 25189 prohibits intentional disposal of hazardous waste.

Guidance on Handling of Appliances and Metallic Discards:

In 1995, the CIWMB prepared the final report for the Metallic Discards Management Plan for removal of materials requiring special handling. This report was mandated by PRC 42176. As a result, we developed an LEA Advisory on metallic discards management, an appliance recycling fact sheet, and an appliance recycling guide to assist in handling and processing special materials contained in major appliances.

The CIWMB Solid Waste Cleanup Program has established a protocol for CIWMB project planning, options for processing, and record keeping requirements for projects with metallic discards. While Board staff developed these procedures for use strictly when overseeing solid waste cleanup projects, the information may offer guidance to LEAs, operators, and technicians in processing and transporting vehicles and appliances for recycling.

All of the documents described are available to the LEA through the CIWMB Publications Office or web site.

At this time, there are no provisions for the financing and administration of removal of special materials. However, household hazardous waste (HHW) grant funds may be used to remove special materials from metallic discards prior to recycling or disposal. Use of these funds must be coordinated in conjunction with a household hazardous waste event. The HHW grants are awarded on a competitive basis with priority given to applicants who demonstrate an essential need for the proposed project.

Further, there are no regulations governing the enforcement of metallic discards disposal and handling requirements.

Resolution 00-02

We agree with the EAC recommendation that Lisa Brown, Assistant General Counsel for Enforcement, CalEPA be invited to speak at the 2000 LEA/CIWMB Conference. Ms. Brown has been invited and will give a presentation on "What is New in Enforcement with CalEPA."

Thank you for the opportunity to review and comment on the EAC resolutions. Should you have questions, please contact me at (916) 341-6360.


original signed by

Julie Nauman
Deputy Director
Permitting and Enforcement Division

cc: Mel Knight, Chair
     CCDEH Solid Waste Policy Committee
     CCDEH-SWPC Members
     EAC Members

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Last updated: February 7, 2005
Enforcement Advisory Council (EAC)
Leta Forland: (916) 341-6395