DSHW-2024-007277

ffiGH5$s/R.ts
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January 28, 1992
I f you do cons i der i t hazar dous was te, do we s tore
hazardous was te, man i fes t i t as hazardous was te, and h
licensed hazardous waste transporter to deliver it to a ref
and make sure the refinery is licensed to accept and
hazardous waste?
Dennis R. Downs, Director
Utah Bureau of Sol id and Hazardous Waste
288 Nor th I 460 Wes t
Sa l t Lake Ci t y , Ut ah 841 14- 4880
Dear Mr. Downs:
On January 24, !992 we discusseC over the tclephone sorne
hazardous waste questions with your personnel. We are writingthis Ietter as we were unable to get an official reply over the
t e I ephone.
Our situation is that we are a conditionally exempt smallquantity generator, questioning how we can store, transport andrecycle our silver flake and old film. Both are recycled for
their precious metal (silver) content.
The silver flake is collected from a silver recovery unit we have
connected to our f ilm processor.I would estimate we collect one
pound of silver f lake from the recovery unit each month. Is thissilver flake considered hazardous waste? We are sure it wouldfai I the TCLP test, since the flake is mainly si lver, but sincethe flake is a salable product, does this make it a non-hazardous
waste?
f 99I
i ,lr i, , ,1, , " t i::,: i,,,
t asre a
ne r y ;
e f i ne
We also have some old recyclable film that we selso they can collect the silver remaining in the
used processed film considered a hazardous waste?
I
fi
to a company
lm. Is this
The regulations in 40 CFR, Part 266, Subpart R, are not easily
understandable to the conmon person. Your help in answering
these questions would be greatly appreciated. If you have any
ques t i ons , p I ease cont act me at 973-459 I .
Sincerely,
Dary I J. Koppenaa I
Pressroom Trainer
DJK/ r p
999 W 2610 Sourn, Snr-r Lnre Crry, UT 84119 Ter [phone] . FAx: [phone]