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tC <br /> UNIFIED SAFETY CORPORATION OCT 191992 <br /> PERM iT/ <br /> October 15, 1992 <br /> Mr. Ron Piloran <br /> Dept. Toxic Substance Control <br /> 400 P. Street <br /> P. O. Box 806 <br /> Sacramento, Ca. 95812-0806 <br /> Dear Ron: <br /> .As per our telephone ppr-versation of October. 15, 1992, Shields <br /> National Inc. (S.N.I. ) "'is" requesting clarification on the test <br /> method used on coal/limestone ash. We were originally informed that <br /> the method to be used for PH was E.P.A. test 9045. However, <br /> subsequent information has arisen indicating the E.P.A. test 9040 <br /> method should be employed. This has left S.N.I. in a dilema as both <br /> our California Certified Labs have declined to test this material <br /> under E.P.A. 9040. It seems without a stabilizing solution that <br /> it is impossible to measure the PH in the ash in a manner that is <br /> duplicatable. Hopefully your phone call to California Hazardous <br /> Material Laboratory will shed a ray of light on what methology and <br /> roceedures that should be imlimeted for proper test results. <br /> It is Shields Nationals intent to help recycle this ash into a <br /> useful product. Please find enclosed information on our farm <br /> monitor questionnaire, ash analysis, and letters from Dr. Block on <br /> methodology. Also included is a letter declining the use of 9040 <br /> test method from Fruit Growers Labratories. <br /> It is Shields Nationals desire to help set industry standards that <br /> will benefit both the Co-generation Power Plants and the <br /> Agricultural industry, while meeting all government regulatory <br /> requirements. <br /> Thank you for your help in this matter. I hope that the meeting <br /> with Intergrated Services, Regional Water and the County <br /> Representatives goes well. <br /> Please feel free to call me at 800-422-7651 if I or my company can <br /> be of any service to you or your department. <br /> Yours rul , <br /> Br. <br /> .C. Ed adilla <br /> Dr Roland Meyers <br /> Rich Recor <br /> Brooke Berkie <br /> 8530 Wilshire Blvd.,Suite 301 Beverly Hills, CA 90211 <br /> (213)659-5776/(800)345-5776/FAX(213'659-5504 <br />