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Current environmental testing is performed by the <br /> generator, <br /> Cogeneration National Corp. , and is in order with The California <br /> Code of Regulations: Title 22; Division 4. Environmental Health. <br /> Chapter 30 Minimum Standards for Management of Hazardous and <br /> Extremely Hazardous Wastes, Article 11 Criteria for Identification <br /> of Hazardous and Extremely Hazardous Wastes Section 66708. The test <br /> for Corrosivity(pH) EPA Method 9045, which is an approved EPA <br /> method, acknowledges interferences that may exist when measuring <br /> the pH of lime or calcareous materials and is part of the monthly <br /> testing program. All pH test results obtained from the beginning <br /> of plant operation are less than 12.5 and do not indicate the <br /> material to be hazardous. <br /> The ash generated at Cogeneration National Corporation is a mixture <br /> of Calcium Oxide/ Hydroxide, Calcium Sulfate, Aluminum Trioxide and, <br /> Silicon Dioxide. The Material that contributes to the high pH <br /> levels is Calcium Oxide/Hydroxide. Standard Material Safety Data <br /> Sheets distributed by the major chemical manufacturers and <br /> distributors such as CHEMSTAR Inc. and Mallinckrodt indicate the <br /> pH of pure Calcium Oxide at Standard Temperature and pressure (25 <br /> deg.C) is 12.44. Calcium Oxide and Calcium Hydroxide handled by <br /> CHEMSTAR Inc. and Mallinckrodt or any other manufacturer are not <br /> treated or handled as a hazardous material. The lime ash generated <br /> at Cogeneration National Corporation, is approximately 35% Calcium <br /> Oxide. Therefore, even if the lime/ash were all calcium hydroxide <br /> it would not be able to achieve hazardous criteria. <br /> I appreciate all the time and patience in reviewing this matter and <br /> we will continue to comply with your request to cease and desist <br /> the ash application to land in San Joaquin County until your <br /> department is assured of the safety of this material, by <br /> California's Toxicology Board, as was our understanding at the last <br /> meeting. <br /> Feel free to call : 800-422-7651 with any questions you may have <br /> on this matter. <br /> Yours <br /> B n <br /> ` cc: red aufman, Program Manager <br /> P.O+S.D.E.F.- Sithe Energzes,Inc. <br /> Ralph Hayes & Sons, Inc. <br /> Graydon Nichols, Victoria Island Farms <br /> Zuckerman Mandeville, Inc. <br /> Pierre H.Perret, Mainstone Corporation <br /> Vernon L.Scott, Correla Farms <br />