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i <br /> Nov 25 00 10: 31a J and B Enterprises 408-988-4$20 �pp�� 1 � <br /> NOV 30 10j0 11:31-M <br /> •d:- PETE WILSON, GO•sr.w, <br /> :;ATE OF CINLRURNIA-ULRORNIA ENVIRONMENTAL YR:7ilCII1jN AMNCY _ <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL �r III��/ <br /> RE3101i I R IE�J E LI V E 0 'M;I•� <br /> 10151 CROY:ON WAY, SUITE 7 <br /> SA^_R;.MeNTO. CA 9582'-2105 NOV 3 0 Zoon j <br /> (916) 255-3545 <br /> ENVIRONMENT HEALTJ <br /> PERMIT/SERVICES <br /> June 6, 1996 <br /> 1 <br /> As. Ken Epsnan <br /> T68 Enterprises <br /> 342 Laurelwood Road <br /> Santa Clara, California 95054 <br /> Dear Mr. Epsnan: <br /> This is in response to your request that the Department of <br /> Toxic substances Control's (Department's) Consultative services <br /> program coTfirL that dust generated fro ' printed circuit board <br /> cuttings ualifY as excluded. recyclable nateriif <br /> qal certain i <br /> conditions are net. You referenced a 1991 letter frca the <br /> Dapartmeat to D:r. Budd B. Warshauer addressing the regulatory <br /> status of circuit boards, tri=nings, 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 EFA and the Department now consider used and unused <br /> circuit boards to be non-regulated scrap metal . The regulatory <br /> status of bnerd .r. imnings and the dust generated froom Putti„g tho <br /> boards appears to be the sane on the federal side (both <br /> considered characteristic- by-proaucts that are excluded The DeparLment from <br /> cions <br /> regulation when r,�:,iy'9 for reo-emetioil) - <br /> L:1 tP tr..-ings so long as they are nut mired with finely <br /> divided or powd=red wastes that exhibit a hazardous <br /> characteristic. <br /> Tiie dust generated from cutting circuit boards will most <br /> li}:ely exhibit a hazardous characteristic for copper, lead, <br /> and/or perhaps other metals and be finely divided or Powdered. <br /> Since the definition of scrap petal (Pound in section 66260. 10 of <br /> Title 22 , California Code of Reaulations) does not include finely <br /> :livided or powdered rlaterials, the dust would be, at least <br /> initially, a hazardous waste 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 exclusion OfaHSCicable <br /> to this situation has changed from (d) (7 ) to (d) (6) O f e if the <br /> section 25143 . 2, the basic exclusion is still app <br /> r• <br />