From chemistry to the drain, or not

One: make the hazardous waste determination

At the point of generation, before any dilution, mixing or other alteration. For spent fixer that means as it comes out of the process, not after it has joined the rinse water in a bucket.

Two: decide whether you are testing or using knowledge

The rule permits a determination on knowledge of the waste, including its origin, composition, the process producing it and the feedstock. For spent fixer the chemistry is well understood, which is why most generators treat it as characteristic without testing each batch.

Three: check the exclusions first

The determination sequence starts by asking whether the waste is excluded from regulation at all, then whether it is listed, then whether it exhibits a characteristic. Skipping to the characteristic question misses a step the rule puts first.

Four: arrange for it to go somewhere

A silver recovery service, a hazardous waste contractor, or a local program. Spent fixer has recoverable silver in it, which is why recovery services exist and why this is often cheaper than it sounds.

And then the product containers, which are straightforward

Chemical resistance and air exclusion. 149 HDPE and 42 glass containers, 132 of them at or under 500 mL, which is the size that suits a developer you want to keep full.

Keep the determination written down

What the waste is, how the determination was made, on what knowledge or what test, and when. That record is the whole of your position, and it is a page rather than a project.

State and local rules sit on top

Authorized state programs can be broader than the federal baseline, and many municipalities regulate silver discharge to the sewer separately from RCRA. Clearing the federal question does not finish this.

References