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| Full Document: |  |
| Title: | INTERPRETATION REGARDING THE REGULATORY STATUS OF SILVER RECOVERY UNITS UNDER RCRA REGULATIONS |
| RCRA Online Number: | 11879 |
| Date: | 10/05/1994 |
| To: | Dufficy |
| From: | Petruska |
| Organization of Recipient: | National Association of Photographic Manufacturers, Inc. |
| Description: | If a silver recovery unit that is used to treat wastewater qualifies as a characteristic sludge, it is not a solid waste when destined for reclamation. Materials generated from wastewater treatment are sludges, even if the treatment is not undertaken to meet any discharge requirements. Metals suitable for direct reuse, or that only need minor refining to be usable, are products (e.g., silver flake that is 98% pure refined to 99.99% pure). |
| Regulatory Citation(s) : | 260.10, 261.2(c)(3), 261.3(c)(2)  |
| Statutory Citation(s): | NA Read US Code 42, Chapter 82 |
| Topic(s): | EPA Forms; Hazardous Waste; Hazardous Waste Recycling; Treatment |