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printreg, November, 2000
RE: TCLP film


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From:Jeff Adrian (jeffadrian@johnroberts.com)
Date:08 Nov 00 10:28:45 -0600


Jeff Adrian 11/8/00 Sherry: Your questions have come up before. It seems we go through this confusion = because some state regulators have their individual interpretations of the = regulations for these waste streams, sometimes defying "logic". 1) Request that the film manufacturers (Kodak, Fuji, etc.) provide the = printer with their TCLP documentation establishing that the bound silver = will not leach out. They should be able to readily provide this = documentation, and going this route is less expensive than running your = own TCLP tests. 2) Generally, it is true that you may have to ship as hazardous waste = fixer solution intended for treatment off site. Recycling the same may be = possible depending again on how the local or state regulatory chooses to = interpret the regulation. One factor in their interpretation is whether = the off-site management will require the waste to be shipped across state = lines. I know that Minnesota allows the use of non-hazardous manifesting = for materials shipped within the state for management (for example, spent = fluorescent lamps shipped within the state require only a Bill of Lading = for documentation). 3) In all the cases I'm familiar with, the off-site management of special = wastes such as silver-bearing spent fixer does not require a Part B TSD = license. Again, this factor is dependent upon the "whim" of those doing = the interpreting. I suggest you review the Code of Silver Management put = out by the Silver Council. More and more regulatory authorities are seeing = the benefits of this performance-based standard. Hope this all is of some help. Good luck. Jeff Adrian Environmental Director The John Roberts Company



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