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1 , � <br /> No significant chemical spills, including developer, have occurred at Qualex Manteca, <br /> perhaps as the result of good secondary-containment features. If chemical spills were <br /> to occur, standard procedures, as detailed in the attached Spill Prevention, Control and <br /> Countermeasure Plan, call for capturing and holding the spilled solution in a tank until a <br /> characterization is made. After the characterization is made, a decision regarding <br /> appropriate disposal would be reached, and disposal executed properly (via discharge, <br /> treatment, or hauling). As there have been no such spills, this decision process has not <br /> been employed. <br /> Item 10b. "Waste in main tank or its effluent was not characterized in accordance with <br /> Title 22." <br /> We apparently introduced confusion regarding management of the solution in this tank <br /> during your visit. The contents of this tank are not discharged to the sewer. This tank <br /> is the main holding tank for solutions that are fed into the silver recovery waste water <br /> treatment system. In fact, the characteristics of this solution are well known; it is a <br /> silver-rich solution that will be treated to remove silver, and, with it, the characteristic of <br /> toxicity. EPA and DTSC have ruled that spent silver-bearing solutions that are treated <br /> for cost-effective silver recovery without prior storage or accumulation are exempt from <br /> counting as wastes. The solution in this tank is not a waste, and therefore does not <br /> require waste characterization. <br /> Other Items <br /> Item 49. Documentation of personnel training will be addressed by 7/2/00, as specified <br /> in your Notice to Comply. <br /> Item 75. We urge you to review the DTSC's Fact Sheet on SB 2111 and its effects on <br /> the regulation of photographic silver in California, which Qualex has previously sent to <br /> your department. We also recommend contacting Mr. Watson Gin, Deputy Director, <br /> Hazardous Waste Management Program for DTSC, or Ms. Cheryl Closson of the <br /> DTSC's Unified Program section, for clarification of the regulatory status of <br /> photographic silver in California. <br /> If, after reviewing this letter and the supporting documentation, you have any remaining <br /> questions or you disagree with the views expressed herein, please contact me so that <br /> all issues can be resolved. <br /> Thank you for your cooperation. <br /> Yours truly, <br /> Jeffry Rose <br /> Health, Safety and Environment Coordinator <br /> Qualex, Manteca <br />