If I generate spent fixer from photoprocessing fluids am I a generator and am I subject to the SQG program?
Photoprocessing activities that generate spent fixer and the spent fixer is not being accumulated (that is, stored greater than 24 hours) prior to on-site recovery through a unit to recover the “sludge” (that is, the cartridge is prepared for shipping off-site for final reclaim of the silver), do not need to notify, do not need an EPA Identification Number, and do not need to do the small quantity generator (SQG) self-certification declaration, given that the recovered material is not subject to RCRA regulation when recycled by being reclaimed under Env-Wm 803.04(b)(1). Certain photoprocessing activities may include silver recovery as part of the photographic process, for example, health care facilities that take X-rays and camera stores that process photographs. Silver that is immediately recovered as part of the photo process is available for recycling, and, therefore, the generator does not need to manifest or obtain an EPA identification number. By contrast, spent fixer that is acc
