Variance TWW-2021-HT-00266 to Allow the Transport and Accumulation of Treated Wood Waste under Alternate Procedures by Silverado Contractors, Inc.


SCH Number
Public Agency
Department of Toxic Substances Control
Document Title
Variance TWW-2021-HT-00266 to Allow the Transport and Accumulation of Treated Wood Waste under Alternate Procedures by Silverado Contractors, Inc.
Document Type
NOE - Notice of Exemption
Document Description
The Department of Toxic Substances Control (DTSC) has issued a variance to Silverado Contractors, Inc. to The variance allows treated wood waste to be managed under procedures different from, but equally protective to human health and the environment to, the provisions of California Health and Safety Code (HSC) Articles 6, 6.5 and 9 of Chapter 6.5 and California Code of Regulations (CCR), Title 22, Division 4.5, Chapters 12, 13, 14, 15, 16, 18, and/or 20. Under the terms and conditions of Variance TWW-2021-HT-00266, Silverado Contractors, Inc. will ensure the treated wood waste will be appropriately managed. The treated wood waste management activities include removal dilapidated wood structures in the water to make way for new construction such as: ferry's, landings, piers, and wharfs. Treated wood waste is a fully regulated California-only hazardous waste because it exhibits the hazardous waste characteristic of toxicity. From 2007 to December 31, 2020, treated wood waste was managed under alternative management standards, established in 22 CCR 67386. The legislation that authorized the alternative management standards for treated wood waste expired on December 31, 2020. Silverado Contractors, Inc. is a marine demolition contractor that previously conducted treated wood waste management activities under the now expired alternative management standards established at 22 CCR 67386. Under the variance, the authorized handler may collect and accumulate treated wood waste from generators, transporters, or other handlers. Operations generally include loading and unloading operations. Accumulation of treated wood waste includes taking appropriate precautions to prevent unauthorized access to and prevent leaching to the environment of the treated wood waste. No transportation activities are authorized as a part of this variance. The variance will expire on October 19, 2021 with possibility of extension for an additional six months.

Contact Information

Kahui Lim
Agency Name
Department of Toxic Substances Control
Contact Types
Lead/Public Agency


Alameda, Contra Costa, San Francisco, San Joaquin, Santa Clara
San Francisco Bay Area
Other Location Info
Pier 96, San Francisco, CA 94124

Notice of Exemption

Exempt Status
Categorical Exemption
Type, Section or Code
CCR Title 14, Sec. 15301
Reasons for Exemption
All analysis conducted included the potential extension of the variance for an additional six months. DTSC has determined none of the exceptions to the categorical exemptions apply to this project, as described in Public Resources Code Section 21084(c), (d), and (e), and 14 CCR Section 15300.2. This project consists of the accumulation and storage of the treated wood waste is consistent with the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structure, involving negligible or no expansion of existing or former use.


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