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Ja"fo Sr" <br /> UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> A ,w <br /> ��� WASHINGTON, D.C. 20460 <br /> i <br /> r��r�<vAotF°r� <br /> Z2 W9 <br /> OFFICE OF <br /> SOLID WASTE AND EMERGENCY <br /> RESPONSE <br /> Ms. Jennifer J. Peters <br /> Sr. Vice President/Regulatory Affairs <br /> The Silver Council <br /> 2300 M Street,N.W. <br /> Suite 800 <br /> Washington,DC 20037 <br /> Dear <br /> Thank you for your letter requesting information about the Resource Conservation and <br /> Recovery Act hazardous waste management regulations. Specifically, you ask about <br /> circumstances under which a generator may recycle its own hazardous waste on-site without <br /> counting the waste toward the monthly hazardous waste quantity determination used to <br /> determine the generator's regulatory status (e.g., large or small quantity generator). We apologize <br /> for the delay in our response. <br /> The regulations at 40 Code of Federal Regulations (CFR) 261.5(c)(3) state that"When <br /> making the quantity determinations of this part and 40 CFR part 262, the generator must include <br /> all hazardous waste that it generates, except hazardous waste that . . . is recycled, without prior <br /> storage or accumulation, only in an on-site process subject to regulation under 40 CFR <br /> 261.6(c)2 . . . " <br /> In your letter, you state that silver-bearing solution that is removed from a photo <br /> processing machine may be carried directly to an onsite silver recycling unit in buckets or other <br /> similar means of conveyance. You ask whether EPA would consider recycling under these <br /> circumstances to have occurred "without prior storage and accumulation." <br /> As explained to you by Ann Codrington, of the Office of Solid Waste, it is not necessary <br /> that a generator install direct piping connections between the waste generation process and the <br /> recycling unit in order to meet the conditions for not counting hazardous wastes under <br /> §261.5(c)(3). Silver-bearing solution may be transferred via a bucket if the solution that is <br /> removed from the processing machine is transferred immediately from the machine to the <br /> recycling unit. A generator need not count the silver-bearing solution against the monthly waste <br /> accumulation limit if no storage or accumulation has taken place. If however, the photo <br /> processor stores or accumulates the silver bearing solution before it is recycled, the solution <br /> would have to be counted towards the monthly quantity of hazardous waste generated. <br /> Raeycled/Recyclable•Printed wnh Vegetable Oil Based Inks on 100%Recycled Paper(40%Postconsumer) <br />