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f -not accumulate onsite more than 1000 kilograms FREQUENTLY ASKED QUESTIONS of waste at any time [40 CFR 261.5(g)(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 RCRA definition of"generator". Although many of the "silver-only"hazardous wastes will qualijyfor the reduced management requirements --Sludges generated by the treatment of silver-rich associated with the federal CESQG category or solutions and wastewaters, which are hazardous only precious metals recovery, the wastes must still be for their silver content,are not considered solid waste, handled in accordance with all applicable and therefore not hazardous waste, when reclaimed reguirements. For example, silver-bearing [40 CFR 261.2(c)(3)]. photoprocessing solutions and wastewaters that are 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(f)]. (Examples of acceptable documentation include I am currently operating under the onsite tiers of the contracts with refiners and/or receipts from the Tiered Permitting program and treat wastes that are 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 wastestreams or treating photoimaging solutions and subject to regulation as hazardous wastes [40 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 January 1, 1999, your treatment activity is exempt "silver-only"hazardous wastes,unless the generator from Tiered Permitting requirements. is a CESQG, in which case no manifest is required. Manifests are also not required for characteristically Note: For those facilities located in non-CUPA hazardous sludges that are reclaimed. These sludges jurisdictions, notifications should be sent to DTSC. are excluded from being considered a solid and a hazardous waste and are therefore not regulated under DTSC and the CUPAs are requesting letters from N CRA. facilities operating under the onsite tiers of the Tiered Permitting program in order to update facilityfiles. ••Except for the CESQG requirements, most of the While the requested letter is not mandated by exclusions and exemptions from regulation require SB 2111,facilities are urged to provide the written that "silver-only" hazardous waste be reclaimed. notification to assure proper identification of "Silver-only"hazardous wastes that are not reclaimed regulatory status. may be subject to full regulation under RCRA. Page 3