RCRA Reclamation Rules for Precious Metals

Precious metals include gold, silver, platinum, iridium, osmium, palladium, ruthenium, rhodium and a combination of these metals. If a facility produces, stores, or transports metal wastes to reclaim a significant amount of precious metals, then the reclamation rules for precious metals are applicable to the facility. Some examples of waste units wherein these regulations are applied include spent lead solder in circuit board manufacturing, which recovers a significant amount of gold, processed printed circuit boards, which recovers a significant amount of gold or platinum and spent photographic fixer solution, which contains high silver concentrations.

Requisition for Recyclable Materials

• If the materials from which the precious metals are recovered are recyclable, then they are exempt from the complete hazardous waste regulation and only the administrative requirements are applicable. These requirements include:

  • An EPA (Environmental Protection Agency) Identification Number
  • Record-keeping requirements have to be met
  • Land disposal restriction notification requirements have to be met

Storage Requirements

• As per the storage requirements, the containers which are used to store the precious metal wastes to be recycled should be in good condition. It should be taken care that the leaking containers are replaced. The contents of the container need to be labeled. A buildings used for the purpose of storage has to be an engineered structure made of non-earthen materials. It has to have a floor, walls and a roof, which prevent contacts with rainwater.

Shipping Requirements

• As per the shipping requirements, if hazardous wastes containing precious metals are shipped, then a hazardous waste manifest is required. After waste disposal, the hazardous waste manifest needs to be retained for five years.

Record-keeping Requirements

• As per the RCRA (Resource Conservation and Recovery Act) recommendation, it is better to maintain records of annual inventories of precious metals for at least five years. As per the record-keeping requirements, it is necessary to keep records of the volume of material that is stored as inventory at the beginning of the year, the volume of material received during the year and the inventory which remains at the end of the calendar year. Also, it has to be ensured that 75 percent of the accumulated material is recycled. If the facility does not recycle 75 percent of the accumulated material annually, then full hazardous waste regulations must be applied to the facility. The generator should also maintain at least three-year records of all shipments of excluded hazardous secondary materials. These records should contain details such as the name and address of the generating facility, the name of the transporter, the date at which the materials have been received, the quantity that has been received and a summarized description of the industrial process which produced the material.