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based on the change in volume of regulated substances manufactured or formulated for commercial wastestreams. use [40 CFR 261.33]. The term generally includes commercial chemical products and their intermediates Do I need to complete any closure activities (such as off-specification species, spill residues, and container unit decontamination or certification that a unit has residues. The term does not include manufacturing been closed) for any "silver-only" onsite treatment process wastes. Examples of commercial chemical units or wastestreams that will be exempt from products include silver nitrate and silver chloride Tiered Permitting on January 1, 1999? chemical products used in photographic processes. No. Treatment activities regulated under the Scrap metal: Bits and pieces of metal parts or metal provisions of SB 2111 will be exempt from Tiered pieces that may be combined together with bolts or j Permitting requirements, including closure soldering, which when worn or unnecessary can be requirements, as of January 1, 1999. You will be able recycled [40 CFR 261.1(c)(6)]. Examples of scrap to continue operating without going through closure. metal are silver metal shavings from jewelry manufacturing and metal wire pieces. "Excluded scrap However, as stated above, you should notify your metal' is processed scrap metal and unprocessed CUPA and DTSC that your treatment unit is exempt turnings, cuttings,punchings, and borings generated by pursuant to SB 2111 provisions. steel mills, foundries, refineries, and metal working/fabrication industries [40 CFR 261.1(c)(9)]. Do I need a letter from my CUPA or DTSC in order to operate under the SB 2111 provisions? Speculative accumulation: A material is accumulated speculatively if it is accumulated before being recycled. No. However,you should still note your CUPA and A material is not accumulated speculatively if it can be DTSC to assure proper identification of your shown that the material is potentially recyclable, thw regulatory status. there is a feasible means for recycling the material, and that 75 percent of the material accumulated on the first of January of any given year is recycled during the same SELECTED DEFINITIONS calendar year [40 CFR 261.1(c)(8)]. By-product: A material that is not one of the primary products of a production process and is not solely or ADDITIONAL SOURCES OF INFORMATION separately produced by the production process [40 CFR 261.1(c)(3)]. Examples of by-products are process The United States Environmental Protection Agency residues, such as slags or distillation column bottoms. (U.S. EPA), Office of Solid Waste provides a variety of mechanisms for accessing information about Sludge: A solid, semi-solid, or liquid waste generated management of hazardous waste. To talk with a RCRA from a wastewater treatment system or pollution control regulatory specialist about a specific issue or to order f process [40 CFR 260.10]. (The treated effluent publications, call the U.S. EPA RCRA Hotline at generated in the process is not included in the definition (800) 424-9346, Monday through Friday, 9:00 a.m. to of sludge.) Examples of sludge include sludge 6:00 p.m., Eastern time. Information is also available generated by silver recovery from photoprocessing on the Internet at http://www.epa.gov/osw. solutions using metallic replacement cartridges or electrolysis. Copies of the CFR are generally available for review at libraries or environmental regulatory agencies. For Comm_rcial chemical product: This term refers to information on purchasing copies, call the Governmen''1 both listed and characteristically hazardous chemical Printing Office, Customer Service, at (202) 512-1803. ' Page 4