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0 0 <br /> STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY EDMUND G. BROWN JR.,Governor <br /> DEPARTMENT OF HEALTH SERVICES <br /> 714/744 P STREET .m <br /> SACRAMENTO, CA 95814 <br /> (916) 323-6043 July 2, 1982 <br /> Mr. Charles F. Iffland <br /> Executive Director-Corporate Engineering <br /> LOF Glass <br /> Libbey-Owens-Ford Company <br /> 1701 East Broadway LiOF GLASS <br /> Toledo, Ohio 43605 0�p6Rih twam <br /> Dear Mr. Iffland: <br /> RECLASSIFICATION OF HAZARDOUS WASTE AS NONHAZARDOUS <br /> This is in response to your letter of June 15, 1982 requesting a reclassi- <br /> fication from hazardous to nonhazardous of baghouse dust from your glass <br /> making facility at Lathrop, California. <br /> In respect to the pH of the dust, as determined by EAL Corporation, the <br /> value of 11 .5 would indeed put the waste in the nonhazardous category <br /> insofar as corrosivity is concerned. Perhaps the more critical criterion, <br /> however, concerns the possible presence of persistent and bioaccumulative <br /> inorganic metal substances and fluorides in the waste. This criterion is <br /> set forth in Section 66699 in "Criteria for Identification of Hazardous <br /> and Extremely Hazardous Waste11, of Title 22, California Administrative <br /> Code, and in pp. 66-75 of the California Assessment Manual for Hazardous <br /> Wastes. The EAL Laboratories have both of these documents at hand. <br /> The metals (in friable or finely powdered state, or liquid mercury) and <br /> their compounds consist of antimony, arsenic, barium, beryllium, cadmium, <br /> chromium, cobalt, copper, lead, mercury, molybdenum, nickel , selenium, <br /> silver, thallium, vanadium, and zinc and their compounds (excepting barite, <br /> the sulfate of barium) . <br /> It may be that there is no possibility of any of these metals or their <br /> compounds, or fluoride salts being present in your baghouse dust. However, <br /> they are mentioned because we have found that these substances do some- <br /> times appear quite unexpectedly in significant amounts through concentra- <br /> tion of dusts, fumes or vapors containing very low concentrations of the <br /> substances in raw materials. <br /> On the assumption that it is your position that these metal substances are <br /> not present beyond the prescribed concentrations, we grant your request that <br /> the baghouse dust be classified as nonhazardous insofar as the Chapter 30, <br /> Division 4, Title 22 hazardous waste control regulations would otherwise <br /> apply to their handling and disposal . <br /> Sincerely, <br /> James L. Stahler, P,E. <br /> Regional Administrator <br /> Permits, Surveillance & Enforcement Section <br /> Hazardous Waste Management Branch <br />