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0 <br /> SHIELDS NATIONAL INCORPORATED <br /> Rk <br /> September 16,1992 <br /> ENVIRONMENTAL HEALTH <br /> Ed Padilla PERMIT/SERVICES <br /> P.O. Box 2009 <br /> 1601 E.Hazelton Avenue <br /> Stockton, CA. 95201 <br /> Dear Ed, <br /> As per our conversation in your office on September 3, 1992 and in <br /> response to the letter dated 9/10/92 from Fred Kaufman, Program <br /> Manager E.H.D. , the pH values submitted for review on the <br /> application site permits, regarding the coal/lime ash produced by <br /> Cogeneration National Corporation, were misinterpreted and judged <br /> according to the corrosivity criteria based on the California Code <br /> of Regulations. <br /> The information provided within the Soil Suitability Testing Table <br /> lists pH values that were measured in conjunction with Method S:3.0 <br /> from the California Soil Testing Procedures ( developed solely for <br /> Agricultural purposes ) and not measure environmental levels of <br /> corrosivity. Method S:3.0 helps to determine and to track the pH <br /> of sails and is not in conjunction with the California Code of <br /> Regulations: Title 22; Division 4, Environmental Health. Chapter <br /> 30, Minimum Standards for Management of Hazardous and Extremely <br /> Hazardous Wastes. Article 11, Criteria for Identification of <br /> Hazardous and Extremely Hazardous Wastes. Section 66708. <br /> Corrosivity (pH) EPA Method 9045 and is not an approved EPA test <br /> method. Therefore, the pH results observed in our application, <br /> (Annual Exempt Disposal Area Permit for Application of Waste Ash <br /> to Land) , are not valid waste or hazardous criteria measurements. <br /> In filing the application for permitting, we submitted not only the <br /> required information but provided additional information for your <br /> benefit. It was felt, you would appreciate reviewing the tracking <br /> program, approved by Regional Water Quality Control Board, (Farmer <br /> Questionnaire) incorporated to show the buffer capacity of <br /> different soils and is used to measure the liming needs for the <br /> farmer. <br /> 8530 Wilshire Blvd., Suite 301 Beverly Hills, CA 9021 1 (310)659-5411 !(800) 422-7651 /FAX(310) 659-5504 <br />