Date:Wed, 8 Nov 2000 04:32:38 -0600
RE: TCLP filmMr.. Schuler: Recycling of waste materials do not have any impact on generator's responsibility to determine if generated waste is hazardous or not. In other words, generator must determine if photographic film leaches silver or not (TCLP test for Silver). (How can one state on the basis of knowledge that silver does not leach?) If TCLP test is positive, shipment to the reclaimer must be manifested (LQG and SQG). The only exemption that applies is, generator may accumulate this waste for more than 90 days and reclaiming facility does not need a RCRA or equivalent State permit as a TSDF Facility. Thus your statement "If they are simply enforcing the federal rules, they have no right to tell you that film negatives need to be TCLP'd if they are going for recycling or reclamation. The federal rules do have a precious metals exemption for materials that are recycled" is misleading and inaccurate.