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Jun-13-2006 12:28pm From-PILLSBURY-WINTHROP SHAW PITTMAN LLP 4154774834 T-768 P-004/008 F-763 <br /> STATE OF CALI[ORN1A—MMLYN AND WELFAF1 1.:!-ACy <br /> DEPARTMENT OF HEALTH SERVICES <br /> 714/7x4 P STREET a <br /> i <br /> ±ACRAMENTO, CA 95814 <br /> (9 16) 322-3670 <br /> June 13, 1968 <br /> Mr. Nick Andrusyshyn <br /> Operations Manager <br /> Schnitzer Steel' Products, Co. <br /> Foot of Adeline Street <br /> P.V. Box /47 <br /> Oakland, CA 94604 <br /> Dear Mr. .Andrusyshyn: <br /> The Department of Health Services has received the laboratory <br /> analyses characterizing Schnitzer Steel Products Co. (SSP) <br /> untreated and treated auto shredder waste. These data were <br /> published on Sequoia Analytical Laboratory letterhead with <br /> laboratory report dates between April 1 and May 41 1988. The data <br /> contained, in these reports represent the analytical results from <br /> samples collected over a six-week period (March 17 - April 22, <br /> 1988) by SSP and submitted to Sequoia Analytical Laboratory. The <br /> waste sampled is a new waste that reflects the process line changes <br /> (referred to as the K-20 treatment) initiated by SSP under the <br /> direction of George Trezek, Ph.D. , of the University of California <br /> at Berkeley. <br /> Samples of the untreated and treated auto shredder waste were <br /> analyzed for total and soluble metal concentrations, total PCB <br /> concentration, pH (treated only) and acute aquatic toxicity <br /> (treated only) . Based on the results published in the above <br /> mentioned reports for K-20 treated auto shredder waste, the <br /> Department has determined that the waste has mitigating physical <br /> and/or chemical characteristics which render it insignificant as *a <br /> hazard to human'_health and safety, livestock and wildlife pursuant <br /> to Section'' '66305(6) Title 22, ' California Code of Regulation (CCR) . <br /> Therefore, the waste is classified as a nonhazardous waste. <br /> In the event that your waste changes to the extent that the <br /> Department's determination can no longer be supported by the <br /> information submitted or for any of the reasons stated in Section <br /> 66305(1) , Title 22, CCR, sSP must immediately begin managing its <br /> treated auto shredder waste as a hazardous waste according to all <br /> provisions set forth in Chapter 30, Title 22 , CCR. <br /> The management and disposal of your waste remains subject to the <br /> requirements imposed by the regional Hater Quality Control Board <br /> and local regulatory agencies. <br />