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Department of Toxic SubstanceVtontrol <br /> VOW Edwin F. Lowry, Director <br /> 400 P Street, 4th Floor, P.O. Box 806 <br /> Winston H. Hickox Sacramento, California 95812-0806 <br /> Gray Davis <br /> Secretary for Governor <br /> Environmental <br /> Protection September 8, 1999 <br /> t - <br /> Uz3.dcus <br /> Mr. James Leagan SEP 0 9; <br /> Director of Regulatory Compliance <br /> Wolf Camera s 3Z7AN a3 <br /> 4955 Marconi Drive <br /> Alpharetta, Georgia 30005 <br /> Dear Mr. Leagan: <br /> Thank you for your letter regarding the Department of Toxic Substances Control's <br /> (DTSC) implementation of Senate Bill (SB) 2111 (Costa, Chapter 309, Statutes of 1998] <br /> regarding the regulation of wastes that are hazardous solely due to their silver content("silver- <br /> only"hazardous wastes). The main concerns expressed in your letter focus on regulation of <br /> Conditionally Exempt Small Quantity Generators (CESQGs) of"silver-only"hazardous waste, <br /> the imposition of fees by Certified Unified Program Agencies (CUPAs) on those CESQGs, and a <br /> CUPA Forum CESQG compliance program proposal. <br /> SB 2111 Provisions <br /> In general, you are correct in stating that SB 2111 mandates that, effective January 1, 1999, <br /> "silver-only"hazardous wastes are to be regulated in California only to the extent they are regulated <br /> under the federal Resource Conservation and Recovery Act (RCRA). The major provisions of SB <br /> 2111, codified in California Health and Safety Code(HSC) section 25143.13,are as follows: <br /> 25143.13. (a)Notwithstanding any other provision of law, except as provided in subdivision <br /> (c), wastes containing silver or silver compounds that are RCRA hazardous wastes solely due <br /> to the presence of silver in the waste are subject to regulation under this chapter solely to the <br /> extent that these wastes are subject to regulation under the federal act. <br /> (b) Notwithstanding any other provision of law, wastes containing silver or silver compounds <br /> are exempt from regulation under this chapter if the wastes are not subject to regulation under <br /> the federal act as RCRA hazardous waste, and the wastes would otherwise be subject to <br /> regulation under this chapter solely due to the presence of silver in the waste. <br /> (c) With respect to treatment of a hazardous waste, subdivision(a) applies only to the removal <br /> of silver from photo imaging solutions and photo imaging solution wastewater. Any other <br /> treatment of wastes containing silver or silver compounds that are RCRA hazardous wastes is <br /> subject to all of the applicable requirements of this chapter. <br /> California Environmental Protection Agency <br />