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t'STATE OF CALIFORNIA—HEALTH AND WELFARE AGE DEPARTMENT OF HEALTH SERVICES 714/744 P STREET SACRAMENTO, CA 95814 (916) 324-1807 Mr® Harry W. Montgomery Director of Public Works City Hall Stockton, CA 95202 Dear Mr. Montgomery: 0 GEORGE DEUKMEJIAN, Govemor 9 S (9,ff � V a J 7- I LOCAL November 16, 1984 ICT In your letter of October 24, 1984, you requested that the Department reconsider the requirement of an aquatic bioassay for the Austin Road Landfill Gas condensate. In a June 19, 1984 letter from C. Leland Hall to Brad Parsons, the waste was chemically described, and a generation rate of 100 gallons per day was estimated. The waste condensate is hazardous by Article 9 of Title 22 of the California Administrative Code (CAC). That is, most of the identified components are listed in Article 9, Section 66680. The waste may be determined to be nonhazardous, however, by Article 11, Criteria for the Identification of Hazardous and Extremely Hazardous Waste, if all of the criteria listed therein are met. One of the criteria is aquatic toxicity. The aquatic. bioassay, as required by Section 66696, is a fast way to measure the aquatic toxicity of a waste. Its methodology is well accepted, and the results are both defensible and reproducible. Although your letter implies that there will be no Contact with aquatic ecosystems, and in any case, the condensate will be dispersed and diluted in the landfill, the possibility of migration through the subsoils or accidental discharge cannot be discounted. In addition to directly measuring effects on aquatic biota, the aquatic bioassay is a way to directly measure the toxicity of a complex mix- ture due to interactions among components in the mixture. An exemption from the aquatic bioassay cannot be granted since it is a requirement for passsing the toxicity criterion. If you have any 0