The hearing procedure on page 17 is to be modified to reflect the hearing procedures under the AEO hearing procedure in the Health and Safety Code. It was noted that the goal of CalEPA is to have all of the Health and Safety Code under one umbrella. The problem for the inspector is determining that the waste if being disposed of properly. The proof of whether the dirty oily waste found in these parts washers is hazardous or not is solely the responsibility of the generator. Studies have been conducted by a few CUPAs and the waste sludge found at the bottom of these washers exceeds the STLC at least half of the time.
Filters come back hazardous as well.
A study on fuel filters was conducted by Orange County, which found that gasoline fuel filters are hazardous. Diesel fuel filters pose less of a hazard because of the high flash point. Copies of Orange County's study were provided to the group. Currently, it is recommended that gas stations provide proof of proper disposal of gasoline fuel filters to the inspector. The TAG will recommend that diesel fuel filters be handled much like waste oil filters.