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1A)F Glass <br /> Libbey-Owens-Ford Company <br /> June 15, 1982 Blind Subject: <br /> State of CalifJorn Lathrop - Solid Waste Disposal <br /> Dept. of Healt ervices <br /> 714/744 11P11 St t <br /> 9 <br /> Sacramento, 95814 <br /> Subject: Reclassification of Hazardous <br /> Waste as Nonhazardous <br /> Gentlemen: <br /> Pursuant to Section 66305, Chapter 30, Division 4, Title 22 of the California <br /> Administrative Code, we are requesting the reclassification of baghouse dust <br /> from hazardous to nonhazardous waste. This dust is generated during the <br /> transporting and mixing of raw materials in our glassmaking facility at 500 <br /> East Louise, Lathrop, California; it contains soda ash, which is listed in the <br /> code as a hazardous waste. <br /> We have submitted a typical sample of the dust to EAL Corporation in Richmond, <br /> California for analysis. Mr. Bert Christensen indicated that, using the pro- <br /> cedures outlined in the "Assessment Manual for Hazardous Wastes" (DOHS, <br /> June 1981), the solution prepared from the batch dust had a pH of 11. 5 (S.U.) . <br /> Since the California criterion for corrosive is pH 12.0 or greater, we believe <br /> that our batch dust should be considered nonhazardous and respectfully re- <br /> quest its reclassification as such. <br /> In this regard, we disposed of approximately 750 tons of batch dust on site <br /> during 1981. As the hazardous waste tax for this material is due on July 1, <br /> 1982, we are requesting that you handle our reclassification request expedi- <br /> tiously as the State Board of Equalization has been requested to defer our <br /> tax payment until your determination has been made and returned to us. <br /> If further questions arise on this matter, please call me at (419)-247-4287. <br /> Very truly yours, <br /> bcc: <br /> A. Waltner - Orrick, Herrington & Sutcliffe <br /> C. W. Davis, Jr. <br /> Charles F. Ifflan E. H. Sandrolini <br /> Executive Director G. W. Craft <br /> Corporate Engineering R. L. Mowery <br /> J. L. Crowley <br /> CFI:rmb W. W. Kohn <br /> W. Ganz <br /> T. J. Koralewski <br /> D. F. Schroeder <br /> nvironmental Files <br /> LX0, <br /> Engineering Files <br /> 1701 East Broadway Toledo,Ohio 43605 Telephone 419 247-3731 TWX 810-442-1739 Telex 28-6437 <br />