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<br /> ase I Information Company
<br /> STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY MMDNO O.BROWN JR.,GO•...e• - -.
<br /> DEPARTMENT OF HEALT)l SERVICES
<br /> 714:7.►SIREET May 6, 1983 - __,
<br /> SACRAMENTO.CA 73414
<br /> (916) 323-6043 July 2, 1982
<br /> Mr. Robert Jones
<br /> BS
<br /> Regional,Water Quality Control Board Waste D i
<br /> Mr. Charles F. Iffland Vd Central ,'Vailey Region `(:
<br /> Executive Director-Corporate Engineering 3201 "SO Street
<br /> Lox Glass 612 Sacramento,' CA 94816
<br /> -Owens-Ford Company
<br /> 1701 East Broadway LbF Subject: Waste Disposal Site C o n r
<br /> �
<br /> Toledo, Ohio 43605 opow 01642L
<br /> Bear Mr. Jones:
<br /> Dear Mr. Iffland:
<br /> Our facility in Lathrop (San Joaquin County) utili the land disposal
<br /> RECLASSIFICATION OF HAZARDOUS WASTE AS NONHAZARDOUS method for discarding the plant's solid waste mat lat. An area of the
<br /> This is in response to your letter of June 15, 1982;requesting a reclassi- plant grounds is sat aside for this purpose-, it sists of approximately
<br /> fication from hazardous to nonhazardous of baghouse dust from your glass 18 acres. Discarded materials and their c Ition of the total fill
<br /> making facility at Lathrop, California. by weight include:
<br /> In respect to the pH of the dust, as determined by EAL Corporation, the Plastic (3,)
<br /> value of 11.5 would indeed put the waste in the nonhazardous category Metal strips 0%)
<br /> insofar as corrosivity is concerned. Perhaps the more critical criterion, Wood (2%)
<br /> however, concerns the possible presence of persistent and bioaccumulative Scrap glass (20%)
<br /> inorganic metal substances and fluorides in the waste, This criterion is Glass batch dust (72%)
<br /> set forth in Section 66699 In "Criteria for Identification of Hazardous
<br /> and Extremely Hazardous Waste", of Title 22, California Administra:ive The glass batch dust consists of the following chemical constituents
<br /> Code, and in pp. 66-75 of the California Assessment Manual for Hazardous (percentages are approximate and may vary, depending on the particle size
<br /> Wastes. The EAL Laboratories have both of these documents at handof raw materials received):
<br /> The metals (in friable or finely powdered state, or liquid mercury, and
<br /> their compounds consist of antimony, arsenic, barium, beryllium, cadmium. SiO2 49% Dolomite (M9CO3.CaCO3) 23%
<br /> chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selen;um, Na2CO3 199% Na2SO4 1%
<br /> silver, thallium, vanadium, and zinc and their compounds (excepting barite, Limestone (CaCO3) 6`X Fe203 2%
<br /> the sulfate of barium). •
<br /> This area may contain 10,000 - 20,000 tons of material at this time; the
<br /> It may be that there is no possibility of any of these metals or their anticipated disposal volume is 5-20 tons per week in the future. Because
<br /> compounds, or fluoride salts being present in your baghouse dust. However, of the relatively inert nature of the disposed materials, we trust that this
<br /> they are mentioned because we have found that these substances do some- site can be regarded as a Class III site, per California regulations.
<br /> times appear quite unexpectedly in significant amounts through concentra-
<br /> tion of dusts, fumes or vapors containing very low concentrations of the If you have any questions on this matter, please advise.
<br /> substances in raw materials.
<br /> On the assumption that it is your position that these metal substances are Very truly yours
<br /> not present beyond the prescribed concentrations, we grant your request that �D E,�/. it
<br /> the baghouse dust be classified as nonhazardous insofar as the Chapter 30, su�zn.fa •,yvya,�L4!
<br /> Division4, Title 22 hazardous waste control regulations would otherwise
<br /> apply to their handling and disposal. Thomas J. Koralewski
<br /> Sincerely, Senior Environmental Engineer
<br /> #,-.a fm
<br /> James L. Stahler, P.E.
<br /> Regional Administrator 1701 East BloadAay Toledo.ONO 43605 TmepnCne41924;-3731 TWx810.442.1739 Teex284437
<br /> Permits, Surveillance E Enforcement Section
<br /> Hazardous Waste Management Branch
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