From: Robert Fricke(firstname.lastname@example.org)
Date: Tue, 30 Jul 2002 10:16:28
Some additional comments.
40 CFR Part 266.70 as it applies to precious metal recovery only applies if the silver is economically significant for recovery. Here are some more thoughts on this subject.
In the case of offsite recycling of used page film, this is true. And I understand that most films do not fail the TCLP anyway. Therefore, you do not have to manage it as hazardous waste.
In the case of silver flake from electrolytic SRUs, this is also true if it is dry and not contaminated by spent fixer, otherwise it may fail the TCLP test and can be regulated as hazwaste. One state, Virginia, used to consider silver flake as hazwaste (early 90's), but it doesn't enforce that policy anymore as far as I know. I don't think there are any others.
In the case of spent fixer, the silver is not economically recoverable by small and midsize printer generators (maybe for large ones). The onsite recovery of silver from spent fixer by a printer generator does not justify the ROI, the major agency consideration for economically significant recovery. (Although there may be an economic benefit in reduced SRU operating costs, the benefit does not offset any of the capital costs of the SRU generally.) If it is treated in an SRU directly connected to the processor and then discharged to the sewer, it is considered a wastewater treatment system and exempt under the hazwaste rules anyway. 266.70 does not apply here. But you're still subject to any applicable state/local wastewater rules, such as California which has some special general permit requirements that apply.
In case of spent fixer collected for offsite recycling, states like California, Massachusetts, Virginia and Connecticut still require you to manage it like hazwaste, including the weekly inspections, labels and other accumulation requirements. I would rather manage it onsite as hazwaste unless I have otherwise written state agency policy/regulation on the matter.
In the case of steel wool canisters, these are regulated as hazwaste unless drained of residual fixer and triple rinsed. This is general agency policy in most of the states I work in. Since the residual canister solution likely fails the TCLP, the canister and silver sludge becomes a hazwaste if transported offsite. I've seen SRU contractors ship the canisters as hazwaste as well as nonhazwaste. It depends on what state they're in and whether they triple rinse them.