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Eldorado <br /> Chemical Company, Inc. <br /> "Specialized Chemical Products" <br /> July 20 , 1989 <br /> Mr. Charles A. McLaughlin, Chief <br /> Surveillance and Enforcement <br /> Unit, Region 1 <br /> Dept. of Health Services <br /> 4250 Power Inn Road <br /> Sacramento, CA 95826 <br /> Dear Mr. McLaughlin: <br /> Eldorado Chemical Co. , Inc. is caught in a nightmare of <br /> bureaucratic regulations that can only be described as a "catch <br /> 22" situation. <br /> The state deems us a "facility" only by virtue of less than <br /> one pound of solvents contaminating a small area of soil. We <br /> have been prevented from cleaning up the pound of solvents since <br /> 1984 by nit-picking technical considerations. (We are paying <br /> our third consulting engineering firm) . Since we are a <br /> "facility" we have filled out a 1988 Facility Annual Report. It <br /> is enclosed. 11 <br /> We understand that if wastes that contain solvents that <br /> were introduced into the process as an ingredient in the <br /> formulation of a product, then the November 8 , 1986 land <br /> disposal restrictions do not apply. In other words, the <br /> material is not an "F" waste and is exempt from the requirements <br /> of "F" wastes. The solvents in our rinse water were never used <br /> as a solvent and are therefore not "spent" solvents. An <br /> additional fact is that the rinse water sent for disposal <br /> contained less than 1000 mg/L of halogenated organic compounds. <br /> We have, since your people do not agree that this is the <br /> law, completed notification statements for the four shipments of <br /> the period in question and sent them to the applicable <br /> facility. Copies are enclosed. <br /> (continued) <br /> P.O. Drawer 34837 a San Antonio, Texas 78265-4837 <br /> (512) 653-2060 a WATS 1-800-531-1088 <br /> Fax (512) 653-0825 <br />