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LOF Glass <br /> Libbey-Owens-Ford Company <br /> August 22, 1983 <br /> Mr. Robert J s, Area Engineer <br /> F9 DO <br /> V <br /> Regional Qualit Control Board 6111 lJq <br /> Central Valley egion <br /> Y <br /> 3201 S Street L <br /> Sacramento, C 94816 14UG 2 6 1983 <br /> Subject: Waste Disposal Procedures SAF4 J10ACUM) LOCAL <br /> Dear Mr. Jones: HEAL-f1f DISTRICT <br /> In reviewing your letter of August 12, 1983, 1 became aware of our lack of <br /> communicating to you the nature of the glass batch (dust) material pro- <br /> posed for disposal at our Lathrop plant site. In previous correspondence, <br /> we had indicated that some of the dust contains selenium. All selenium- <br /> bearing dust, however, is being disposed of as a hazardous waste to IT <br /> Corporation. The majority of the dust for on-site disposal has the approxi- <br /> mate composition: <br /> Component Percentage <br /> Sand and Glass Dust 10-60 <br /> Dolomite 10-40 <br /> Soda Ash 15-25 <br /> Limestone 2-10 <br /> Rouge 1-3 <br /> Salt Cake 0. 5-2.0 <br /> Cobalt 0. -0. 25 <br /> A representative sample* of the dust was submitted to EAL Corporation in <br /> Richmond, California for analysis. Mr. Bert Christensen of the laboratory <br /> indicated that, using the procedures outlined in the "Assessment Manual for <br /> Hazardous Wastes" (DOHS, June 1981), the solution prepared from the sample <br /> was neither corrosive nor toxic according to California regulations. Using <br /> these independent laboratory results, we obtained an evaluation from the <br /> Department of Health Services that the waste is not hazardous. <br /> With this evaluation in mind, we requested your permission to dispose of <br /> this material at the Lathrop plant site on May 6, 1983. We have agreed <br /> that any dust containing selenium is hazardous, and on August 10, 1983 <br /> indicated that wood, plastic, and metal in the area will be removed to the <br /> local transfer station. We respectfully request, therefore, that you recon- <br /> sider your decision of August 12 which denies a Class III designation to the <br /> site. <br /> *The sample analyzed contained selenium because of the glass batch compo- <br /> sition at the time of sampling. Selenium is not generally used at the Lathrop <br /> facility, and batch dust composition would not be materially affected by its <br /> exclusion. The EAL analysis would be virtually identical if the selenium <br /> were not present. <br /> 1701 East Broadway Toledo,Ohio 43605 Telephone 419 247-3731 TWX 810-442-1739 Telex 28-6437 <br />