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ITEM #75 _ <br /> STATEMENT: "Return to compliance by 7-20-00." <br /> REPLY: <br /> This document states our status and return to compliance. <br /> Reply to "Checklist and Initial Verification Inspection Report for Permit by Rule, <br /> Conditionally Authorized, and Conditionally Exempt Notifiers" <br /> ITEM #5 <br /> STATEMENT: "All wastes are not properly identified" <br /> "A. Spent photographic solution treated in a pH neutralizer. Spent <br /> photographic solution to be manifested off site on a milk-run to a proper TSDF <br /> beginning 7-20-00." <br /> REPLY: <br /> Refer to the attached documents dated 29 December 1998. On 8 December <br /> 1998 we received documents from California Environmental Protection Agency, <br /> Department of Toxic Substances Control dated November 23, 1998. These <br /> documents refer to Senate Bill 2111 Tiered Permitting Exclusions. <br /> On 29 December 1998 we chose to take advantage of the exclusions and <br /> submitted "Notification of'Silver-Only' Hazardous Waste Treatment Form" <br /> "B. Drums are labeled with magnetic labels. Drums are to be labeled in <br /> accordance with DOT regulations on hazardous material under title 49 CFR Part <br /> 172 beginning 7-20-00." <br /> REPLY: <br /> See reply to ITEM #20 in the "Unified Program Hazardous Waste Inspection <br /> Report" <br /> ITEM #6 <br /> STATEMENT: "All units are not properly identified on DTSC 1772. <br /> A. Phase separation by gravity settling after aqueous waste (PF solvent + <br /> resist) which is hazardous due to the presence of organic (solvent) and <br /> inorganic (metals) constituents is an activity that should be operating <br /> pursuant to a grant of conditional authorization by 7-20-00." <br /> REPLY: <br /> An evaluation of the savings generated by the recovery of as much of our PF solution as <br /> possible by the above mentioned settling operation has demonstrated that it is not <br /> economical if we are to be required to obtain a permit as stated above with its fees and <br /> record keeping requirements. We therefore have discontinued this operation and waste <br /> generated in our process will be directly discharged into manifested HW drums. <br /> 3 <br /> Lustre-Cal Nameplate <br /> 07/14/00 <br />