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RECEIVE® JUN - 9 2000 ENVIRONMENTAL HEALTH June 9, 2000 PERMIT / SERVICES San Joaquin County Public Health Services Environmental Health Division 304 East Weber Avenue, Third Floor Stockton, CA 95202 Attention: Michael Kith Regarding: Unified Program Hazardous Waste Inspection Report, 6/2/00 Dear Mr. Kith: The following shall serve as Qualex' response to allegations of illegal operations detailed under item # 10 of the Inspection Report you issued to this site on Friday, June 2, 2000. The "Notice to Comply" attached to the report required the facility to "submit results' within one week of notice. Item 10a. "Waste solution from TMT tank, filter for RA developer, and developer and chemical spills are disposed into the sewer without characterization in accordance with Title 22." As you know, Title 22 allows generators to characterize wastes via several different methods. Among them is, "Applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used." Facilities do not generally perform aquatic toxicity testing of components of a mixed waste stream if there are reliable alternate sources available that provide the same information. Eastman Kodak Company is the supplier of the TMT compound used in the silver recovery treatment system at Qualex. Attached is a copy of a Kodak advisory document addressing the California and Federal regulatory status of TMT precipitate, including the California waste profile. As you will note, the document goes through a detailed decision tree analysis and demonstrates that the TMT compound is not regulated as hazardous waste under Federal or California law. San Joaquin County Environmental Health Division inspected this site on 10/28/97, and, after reviewing MSDS for process chemicals, requested that Qualex perform 96- hour aquatic toxicity testing on spent filters from film processing developer. The inspector, Robert McClellan, was concerned that the presence of the color developer component (CD) in film developer might cause the filters to fail California's aquatic toxicity test. Qualex had aquatic toxicity testing performed on film developer filters at Sequoia Analytic Labs in early 1999, and the results indicated that the filters do not display aquatic toxicity under the test conditions. A copy of the test results is attached. The concentration of CD in film developer working solution is approximately 0.55%. The concentration of CD in RA paper developer you cited is approximately 0.39%. It is logical and reasonable to conclude that if film developer filters do not display aquatic toxicity, neither will paper developer filters, due to the lower concentration of CD in RA developer.