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ft <br />Mr. Ed Padilla <br />October 19, 1992 <br />Page Two <br />3. Data should be presented in a tabular format similar to Table 1 for the October, 1991 <br />tests, updated with a new column for each round of sampling data. <br />Reply: See reply to comment 1 above. <br />4. The significance of the Dilution Factor in the 24 March and 19 June sampling data is <br />not clear. <br />Reply: The Dilution Factor has been taken into account in the reporting limits. Please <br />refer to Page 3 of Weston's report under Notes. <br />5. The gas condensate is not toxic in any single constituent. However, the 24 March <br />analysis was very close to having hazardous levels of 1,4 dichlorobenzene (DCB), <br />(5,100 ppb reported -hazardous level 7,500 ppb). If the superposition of analogous <br />isomers of DCB is made and 1,2 DCB (3,000 ppb) reported is added to the 1,4 DCB <br />result, the condensate would be hazardous based on the 1,4 DCB TCLP. <br />Reply: First of all, we feel that the 24 March test was not a representative sample of <br />the condensate which we normally see. Tests of the condensate before and after this <br />period confirm that this was an unusually high result. Secondly, the opinion that the <br />5,100 ppb level of 1,4 DCB being "very close" to hazardous is subjective in nature, as <br />this only equates to 68% of the hazardous level. Lastly, and more importantly, 1,2 <br />DCB is NOT a regulated substance under either Title 22 or 40 CFR. Therefore, the <br />adding of the these two substances together and indicating that the condensate is <br />hazardous under the TCLP test is invalid. <br />Should you have any Further questions or wish to discuss any of items noted <br />above, please contact me at the above number. <br />Sincerely, <br />George E. Donlou <br />Manager of Biogas <br />Business Administration <br />Copy to: Mr. Mike Miller, City of Stockton <br />