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J�tSEO ST+r�S <br /> :m A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> $ WASHINGTON, D.C. 20460 <br /> AUG 4 1995 <br /> OFFICE OF <br /> SOLID WASTE AND EMERGENCY <br /> RESPONSE <br /> Ms . Orlean Thompson <br /> Senior Environmental Scientist <br /> Corporate Environmental Services <br /> Health, Safety and Environment <br /> Eastman Kodak Company <br /> Rochester, New York 14652-6279 <br /> Dear Ms . Thompson: <br /> This is in response to your May 3rd letter to Stephen <br /> Bergman of my staff . Both he and Marilyn Goode found the tour <br /> that you arranged of the photographic processing facilities at <br /> the National Geographic Society to be quite informative. <br /> Based upon past conversations that we have had with you and <br /> your attorneys, it appears that it would be useful for me to <br /> clarify our policy regarding the regulatory status under the. <br /> Resource Conservation and Recovery Act (RCRA) of silver recovery <br /> units used in photo processing. <br /> A silver recovery unit used to treat photo processing <br /> wastewater that exhibits a characteristic is considered to be a <br /> characteristic sludge (regardless of whether the sludge is <br /> produced as a result of required wastewater treatment) and, as <br /> such, is not subject to RCRA regulations when sent for <br /> reclamation. A characteristic sludge being reclaimed is not <br /> considered a solid waste, according to the provisions of 40 CFR <br /> §261 . 2 (c) (3) . <br /> Again, thank you for arranging for my staff to visit a <br /> silver recovery operation and for your continued efforts to get <br /> us the materials that we needed to make an informed <br /> determination. If you have any further questions, please contact <br /> Stephen Bergman at (202) 260-5944 or Marilyn Goode at (202) 260- <br /> 6299 . <br /> Sincerely, <br /> Michael Petruska, Chief <br /> Regulatory Development Branch <br /> Recycled/Recyclable <br /> PrinteE with Soycanala Ink on paper that <br /> �. *ontelns at least 50%reoycled Ober <br />