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rviuuuay,,vuvc ��• . --- -not accumulate onsite more than 1000 kilograms of FREQUENTLY ASKED QUESTIONS waste at any time[40 CFR 261.5(8)(2)]. - ensure that their "silver-only" hazardous waste is either recycled(reclaimed)or disposed at a facility Does the passage of SB 2111 mean that silver is no that is permitted or otherwise authorized to manage longer regulated as a hazardous waste? that hazardous waste [40 CFR 261-5(g)(3)]. No. Most wastes containing silver above the • Businesses with a"zero waste count" for purposes of regulatory threshold will continue to be regulated as determining their generator category [40 CFR hazardous wastes. But "silver-only" hazardous 261.5(c)(2)] are still considered hazardous waste wastes will only be regulated to the extent that they generators(as CESQGs)because they remain subject are regulated under the federal RCRA. to some RCRA regulatory requirements and meet the Although many of the "silver-only"hazardous wastes RCRA definition of"generator". will qualifyfor the reduced management requirements • Sludges generated by the treatment of silver-rich associated with the federal 6fiSQG category or solutions and wastewaters,which are hazardous only precious metals recovery, the wartes mut still be for their silver content,are not considered solid waste, handled in accordance with °Isilver-bearing ca and therefore not hazardous waste, when reclaimed P processing solutions and that are [40 CFR 261.2(c)(3)]. discharged to the sewer must comply with POTW • Businesses sending silver sludges for reclamation discharge limits. must be able to provide documentation that the sludges are being reclaimed [40 CFR 261.2(01. (Examples of acceptable documentation include I am currently operag under the tret wastes that aronsite tiers Of e contracts with refiners and/or receipts from the Tiered Permitting p sludge transporter for shipments of sludge to a "silver-only"hazardous wastes. What should I do? refiner.) if you are treating "silver-only" RCRA-exempt • Silver metal scraps that are recycled will not be wastestreamsortreatingphotoimagingsolutions and subject to regulation as hazardous wastes 140 CFR wastewaters to remove silver, and are currently 261.4(a)(13)and 40 CFR 261.6(a)(3)(ii)]. operating under the CA, CE, or PBR tiers, you should notify your CUPA in writing that, as of • Manifests are required for offsite shipments of"silver- January nutreatment activity is exempt only" hazardous wastes, unless the generator is a fr Tiered Permittingrequirements. CESQG, in which case no manifest is required. Manifests are also not required for characteristically Note For chose facilities located in non-CUPA hazardous sludges that are reclaimed. These sludges jurisdictions, notifications should be sent to DISC. are excluded from being considered a solid and a hazardous waste and are therefore not regulated under DTSC and the CUPAs are requesting fetters from RCRA. facilities operating wider the onsite tiers of the Tiered Permitting program in order to update facility files. • Except for the CESQG requirements, most of the While the requested letter is not mandated by exen clusions and exemptions from regulation require SB Il ll,facilities are urged P ide n t identihe fication of that "silver-only" hazardous waste be reclaimed. notification to assure proper f "Silver-only"hazardous wastes that are not reclaimed regulatory status. may be subject to full regulation under RCRA. pqg 3 NOU 27 '00 12:47 530 886 0669 PRGE.05