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Nov 25 00 10:31a <br />OF <br />J and B Enterprises <br />YNQItCIIVN AUtNCY <br />9 <br />408-988-4520 1 <br />NOV 30 10j0 11:31-M <br />PETE WILSON, Gosrlp. <br />DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br />Ren��r��l`\n� <br />aol+ I [RECEIVED <br />LS <br />10151 CROY:ON WAY, SUITE 3 <br />SA^_R:.MeNTO. CA 9582'-2105 NOV 3 0 Zoon <br />(916) 255-3545 <br />ENVIRONMENT HEALTJ <br />PERMIT/SERVICES <br />June 6, 1996 <br />As. Ken Epsnan <br />J68 Enterprises <br />342 Laurelwood Road <br />Santa Clara, California 95054 <br />Dear Mr. Epsman: <br />This is in response to your request that the Department of <br />Toxic Substances Control's (Department's) Consultative services <br />program confirm that dust generated fro' printed circuitaboard <br />q <br />cuttings ualifY as excluded recyclable nater_al <br />if in <br />conditions are net. You referenced a 1991 letter frca the <br />Departureat to 1.!r. Budd B. Fr, <br />tarzhauer add_essig the regulatory <br />status of circuit boards, trirlrings, and dust from circuit <br />boards. <br />Uoon ra iew of the 1991 letter, we found that the reference <br />to the federal regulation of used circuit boards has changed. <br />The US EPA and the Departrent nowconsider used and unused <br />circuit boards to be non-regulated scrag metal. The regulatory <br />status of board .r.imnings and the dust generated from <br />autti„g tho <br />boards appears to be the sen= on the federal side (both <br />considered characteristic, by-products that are excluded The DeparLment from <br />aces <br />regulation when going fur rec_emetioil)- <br />so long as they are not mired with finely <br />divided or powdered wastes that exhibit a hazardous <br />characteristic. <br />The dust generated from cutting circuit boards will most <br />li}:ely exhibit a hazardous characteristic for copper, lead, <br />and/or perhaps other natals and be finaly divided or powdered. <br />Since the definition of scrap petal (found in section 66260.10 of <br />Title 22, California Code of Regulations) does not include finely <br />:livided or powdered rlaterials, the dust would be, at least <br />initially, a hazardous �.;aste. As discussed in the 1991 letter, <br />there are provisions found in HSC section 25143.2 that exclude <br />recyclable material (hazardous waste capable of being recycled) <br />f.ron regulation as viaste if certain conditions are net. <br />Although the citation for tha specific exclu6 °aHSCicable <br />to this situation has changed from (d)(7) to (d)(6)o Offcable if the <br />section 25143.2, the basic exclusion is still app <br />1 <br />0 <br />