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e 1— e \ll' Ir' APR 2 2 2004 April 20, 2004 -/SERVICES Michelle Le Environmental Health Department San Joaquin County Sr.Registered Environmental Specialist 304 E. Weber Avenue,Third Floor Stockton, CA 95202-2708 Re: March 22, 2004 Inspection of LensCrafters Store# 135 Dear Ms. Le: I am writing in response to your inspection of our LensCrafters Store located at 4950 Pacific Avenin.;, Stockton, California ("Store 135"), conducted on March 22, 2004. As we discussed in our telephone call following the inspection, there are a few items raised in your Inspection Report that require some clarification and/or explanation,which I have set forth below. In addition,pursuant to your requests in the Inspection Report and in our follow-up conversation, I have enclosed certain materials for your review. As an initial mat ei, in your Inspection Report you incorrectly characterized our process of curing small amounts of excess lens coating as Conditionally Exempt Small Quantity Treatment ("CESQT"). As discussed during our telephone conversation, the appropriate category is the Conditionally Exempt Specified Waste Stream ("CESW"). LensCrafters uses a tireble hard coating material, LTI-HT-850X- 12B, to create a scratch resistant coating on our polycarbonate lenses. This coating is applied to the optical lens in a machine specifically designed for such application, where it is then cured by ultraviolet (UV) light in accordance with the manufacturer's instructions. A small amount of overspray results from the application process and this coating(several ounces) is collected in the machine. The procedure established for managing the tintable coating waste is to collect the material directly from the coating machine in an enclosed, labeled container. Next, the coating is transferred from the container into a small tray, where it is placed under the UV light in the machine until it is properly cured. This small amount of coating is polymerized into a solid through application of the UV light. Once it is fully hardened and no longer exhibits any potentially hazardous characteristics, it is disposed of as ordinary solid waste. This process is performed daily and is conducted pursuant to the specified waste stream treatment authorization found in Section 25201.5(c) of the California Health & Safety Code. Accordingly, in 1996 LensCrafters submitted notifications to the State of California that it was curing the coating waste pursuant to this provision for the Company's California stores using the appropriate form. Per your request, I have enclosed copies of the notification form for Store 135 that was submitted in 1996, the Material Safety Data Sheet for the coating material, and the manufacturer's instructions for proper disposal from their operations manual. Second, in your inspection report, you requested copies of the analytical results for the coating waste and the polisher waste. With respect to the coating waste, the material is characteristically hazardous only when it is in a liquid state due to its ignitability. Once the waste material is cured, it becomes a solid and no longer exhibits this characteristic. This waste is then disposed of in the daily trash pursuant to the manufacturer's recommendation. Finally, LensCrafters has not conducted analytical testing on the polisher waste (product name "Slurry of Aluminum Oxide"). This material is primarily water and aluminum oxide, and does not