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0 September 30 , 199 SHIELDS.LTR/TXTBK Page 2 This letter appeals the decision rendered in your Septem- ber 10 , 1992 letter and requests a one time approval to apply the 4 ,000 tons of non hazardous coal lime ash from the Sithe Energy plant to the Victoria Island Farm. We understand that this request is independent of the decision before you regard- ing continued application of rice hull ash from the Williams plant. Attached for vour review are three items which should dispel any concern your office may have regarding the pH of the coal lime ash. 1 . A letter from Ronald Block, Ph.D. distinguishes be- tween the various test methods and their proper use on liquid and solid materials. 2 . A letter from Ronald Block, Ph.D. which self certi- fies for Shields National that the ash material is not a hazard- ous waste. 3. Copies of the EPA test method 9045 results since July 1991 . These test results demonstrate that the pH for the ash has not exceeded 12.5 . Also, as you may have noted during the recent public meeting on September 24, 1992, Dr. Block testified as to the specific pathways of potential health risk. While there is not a potential health risk of ingestion or dermal contact, due to its small particulate matter, the potential risk of inhalation of ash materials may be at issue. Thus, the less amount of time our client is required to store the lime coal ash on site at Victoria Island, the better it is potentially for the envi- ronment. Shields National is seeking your approval to apply the lime coal ash as directed by the Regional Water Quality Control Board. Attached for your review is a copy of the Regional Board' s directive. If you should have any questions , do not hesitate to call. Very truly yours, BROOKE K. BIRKIE Attorney at Law BKB:jk Enclosures cc: Brien Piper, Shields National , Inc. Ed Stockton, Sithe Energy Steven A. Herum, Esq.