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Violation 102: Metal Fines/Shavings from Key Cutter& Pipe Threader: Before you can recycle the metal key fines/shavings and metal pipe threader fines, a metal fines hazardous waste determination needs to be made. Metal fines hazardous waste determination information is below. Please refer to California Code of Regulations,the California Health &Safety Code, and the Code of Federal Regulations for the exact and most complete requirements: Business owners are required to make a hazardous waste determination for all wastes generated by their facility. They can use generator knowledge (Title 22 CCR 66262.11(c)(2)) or analytical testing (Title 22 CCR 66262.11(c)(1)). a. Generator knowledge from Safety Data Sheets, other material literature, other sources. b. Analytical testing as specified in T22 starting in T22 CCR 66261.20. Hazardous waste characteristics are Toxicity, Reactivity, Ignitability, and Corrosivity. Hazardous waste can also be on a list (listed). Generator knowledge cannot be used to declare the waste as nonhazardous for key and pipe threader fines since the business owner does not know the metal composition of EVERY key and pipe that come into his facility. That leaves analysis. The business owner can also declare the metal fines to be hazardous waste and handle/dispose of it as hazardous waste. To do analysis the business owner can sample the key and pipe threader fines and send them to a California ELAP certified hazardous waste lab. Here's the list of labs: http://www.waterboards.ca.gov/drinking water/certlic/labs/index.shtml The lab our department uses for analysis is Geoanalytical Laboratories, Inc. 209-669-0100. We do not recommend any specific lab. Metal fines including key and pipe threader fines need a particle size test to determine if any of the metal fines are less than 100 microns in size. If all of the metal fines are larger than 100 microns then it can be sent to a metals recycler as allowed by T22 CCR 66261.6(a)(3)(B) and 66260.10. No hazardous waste disposal manifest needed but it cannot be disposed of in the trash. The business owner should keep proof of recycling. If any of the fines are less than 100 microns in size then we need a hazardous waste characteristic test for Toxicity. We limit the Toxicity testing to the most likely hazardous components which are hazardous metals. Hazardous waste metals listed in T22 CCR 66261.24 are Antimony, Barium, Beryllium, Cadmium, Chromium 6, Chromium, Cobalt, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Silver,Thallium,Vanadium, Zinc. The listed metals have threshold values above which they are hazardous. First TTLC testing is done (T22 CCR 66261.24(a)(2)(A)) (also called CAM-17 testing). If the TTLC results exceed the TTLC limits then we have hazardous waste and the determination is finished. Otherwise, if the TTLC results for any metal are 10X greater than the STLC limit then a STLC test is required. Otherwise, if the TTLC results for any metal are 20X greater than the federal regulatory limit (T22 CCR 66261.24(a)(1)(B))then a TCLP test is required. TTLC test results that exceed the TTLC limit are non-RCRA hazardous waste. STLC test results that exceed the STLC limit are non-RCRA hazardous waste.TCLP test results that exceed the TCLP limit are RCRA hazardous waste. All require a full hazardous waste manifest for disposal. 4