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What if only a portion of the hazardous wastes I By-product: A material that is not one of the primary generate are hazardous solely due to their silver products of a production process and is not solely or content? separately produced by the production process [40 CFR 261.1(c)(3)1. Examples of by-products are process You should notify your CUPA of the portion of the residues,such as slags or distillation column bottoms. wastes you treat that are hazardous for silver only and are exempt from Tiered Permitting regulation as Sludge: A solid, semi-solid, or liquid waste generated ofJamrary 1, 1999. Ifyour authorized treatment unit from a wastewater treatment system or pollution control treats both "silver-only" and non-silver hazardous process [40 CFR 260.10]. (Il1e treated eluent wastestreams,you will continue to need authorization generated in the process is not included in the definition under the Tiered Permitting program for the non- of sludge.) Examples of sludge include sludge silver treatment activity. However, you should still generated by silver recovery from photoprocessing notify your CUPA of the portion of your wastes solutions using metallic replacement cartridges or which are "silver-only"and exempt as of January 1, electrolysis. 1999, because you may be able to operate under a lower tier based on the change in volume ofregulated Commercial cheadcal product: This tern refers to wastestreams. both listed and characteristically hazardous chemical substances manufactured or formulated for commercial Do I need to complete any closure activities(such as use [40 CFR 261.331. The term generally includes unit decontamination or certification that a unit has commercial chemical products and their intermediates, been closed)for any "silver-only" onsite treatment off-specification species, spill residues, and container units or wastestreams that are exempt from Tiered residues. The term does not include manufacturing Permitting effective January 1, 1999? process wastes. Examples of commercial chemical products include silver nitrate and silver chloride No. Treatment activities regulated under the chemical products used in photographic processes. provisions of SB 2111 are exempt from Tiered Permitting requirements, including closure Scrap metal: Bits and pieces of metal parts or metal requirements,as of January 1, 1999. You will be able pieces that may be combined together with bolts or to continue operating without going through closure. soldering, which when worn or unnecessary can be However, as stated above, you should notify your recycled [40 CFR 261.1(cx6)]. Examples of scrap CUPA that your treatment unit is exempt pursuant to metal are silver metal shavings from jewelry SB 2111 provisions. manufacturing and metal wire pieces. "Excluded scrap metal' is processed scrap metal and unprocessed Do I need a letter from my CUPA or DTSC in order turnings,cuttiM,ptmehinM and borings generated by to operate ander the SB 2111 provisions? steel mills, foundries, refineries, and metal woricing/fabrieation industries (40 CFR 261.1(c)(9)]. No. However,you should still notify your CUPA to assure proper identification of your regulatory status. Speculative accumulation: A material is accumulated speculatively if it is accumulated before being recycled. A material is not accumulated speculatively if it can be SELECTED DEFINITIONS shown that the material is potentially recyclable, that there is a feasible means for recycling the material,and Generator: Any person, by site,whose act or process that 75 percent of the material accumulated on the first produces hazardous waste identified or listed in 40 CFR of January of any given year is recycled during the same Part 261 or whose act first causes a hazardous waste to calendar year[40 CFR 261 A(cxg)]. become subject to regulation[40 CFR 261.10]. Pnec{ NOV 2? 100 12:49 530 ee6 0669 PAGE-OG