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• Silver metal scraps that are recycled will not be I am currently operating under the onsite tiers of the subject to regulation as hazardous wastes [40 CFR Tiered Permitting program and treat wastes that are 261.4(a)(13) and 40 CFR 261.6(a)(3)(ii)]. "silver-only" hazardous wastes. What should I do? • Manifests will be required for offsite shipments of If you are treating "silver-only" RCRA-exempt "silver-only" hazardous wastes, unless the generator wastestreams or treating photoimaging solutions and is a CESQG, in which case no manifest is required. wastewaters to remove silver, and are currently However, manifests will not be required for Small operating under the CA or CE tiers,you should notify Quantity Generators (SQGs) when the transportation your CUPA in writing that, as of January 1, 1999, is performed under a contract to reclaim the waste. your treatment activity will be exempt from Tiered Manifests will also not be required for Permitting requirements. A copy ofyour letter should characteristically hazardous sludges that are also be sent to DTSC. reclaimed. These sludges are excluded from being considered a solid and a hazardous waste and are If you are treating "silver-only" RCRA-exempt therefore not regulated under RCRA. wastestreams or treating photoimaging solutions and wastewaters to remove silver, and are currently • Except for the CESQG requirements, most of the operating under the PBR tier,you should notify DTSC exclusions and exemptions from regulation require in writing that, as of January 1, 1999, your treatment that "silver-only" hazardous waste be reclaimed. activity will be exempt from Tiered Permitting "Silver-only"hazardous wastes that are not reclaimed requirements. A copy of your letter should also be may be subject to full regulation under RCRA. sent to your CUPA. DTSC and the CUPAs are requesting letters from 'qREQUENTLY ASKED QUESTIONS facilities operating under the onsite tiers of the Tiered Permitting program in order to update facilityfiles. Does the passage of SB 2111 mean that silver is no While the requested letter is not mandated by longer regulated as a hazardous waste? SB 2111,facilities are urged to provide the written notification to assure proper identification of No. Most wastes containing silver above the regulatory status. regulatory threshold will continue to be regulated as hazardous wastes. But "silver-only" hazardous What if only a portion of the hazardous wastes I wastes will only be regulated to the extent that they generate are hazardous solely due to their silver are regulated under the federal RCRA. content? However, even though, under RCRA, many of the You should notify your CUPA and DTSC of the "silver-only" hazardous wastes will qualify for the portion of the wastes you treat that are hazardous for reduced management requirements associated with silver only and will be exempt from Tiered Permitting the federal CESQG category or precious metals regulation as of January 1, 1999. If your authorized recovery, the wastes must still be handled in a treatment unit treats both "silver-only" and non- responsible manner. For example, untreated silver- silver hazardous wastestreams, you will continue to bearing photoprocessing solutions and wastewaters need authorization under the Tiered Permitting cannot be poured down the drain, or otherwise program for the non-silver treatment activity. disposed, unless the solutions do not exceed However, you should still notify your CUPA and hazardous waste regulatory levels and POTW DTSC of the portion of your wastes which are discharge limits. "silver-only" and exempt as of January i, 1999, because you may be able to operate under a lower tier Page 3