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W <br /> STATE OF,,CAUFORNIA—HEALTH AND WELFARE AGENCY PETE WILSON, Governor <br /> DEPAOTMENT OF HEALTH SERVICES <br /> 714/744 P STREET <br /> P.O. BOX 942732 <br /> SACRAMENTO, CA 94234-7320 <br /> (916) 322-3670 <br /> July 8 , 1991 <br /> Mr. Robert Graulich <br /> vice President-corporate communications <br /> The oxford Energy Company <br /> Oxford Energy Group <br /> 3510 Unocal Place <br /> Santa Rosa, CA 95403 <br /> Dear Mr. Graulich: <br /> REQUEST FOR CONCURRENCE WITH NONHAZARDOUS CLASSIFICATION OF RICE <br /> HULL ASH FROM WADHAM ENERGY COMPANY, [WASTE EVALUATION UNIT (WEU) <br /> FILE NO. 81] <br /> The California Department of Health Services (Department) has <br /> completed its review of Wadham Energy Company's October 3, 1990 <br /> request for concurrence with the determination that rice hull ash <br /> (ash) . currently generated by their Williams, California, facility <br /> is nonhazardous. This request was made pursuant to §66305(c) , <br /> Division 4, Chapter 30, Title 22, California Code of Regulations <br /> (22 CCR) . Based on the data and information provided, and the <br /> assessment of risk performed, the Department concurs with Wadham's <br /> determination that the rice hull ash currently being generated is <br /> nonhazardous. This determination applies only to the currently <br /> generated ash, not the ash which was previously generated and <br /> stored in piles at the facility. <br /> BACKGROUND AND CHRONOLOGY <br /> Wadham Energy Company, Inc. (Wadham) , an affiliate of oxford Energy <br /> Group (Oxford Energy) , operates a rice-hull-fired electrical co- <br /> generation facility located on Myers Road approximately five miles <br /> southwest of Williams in Colusa County, California. The facility <br /> is operated for Wadham by Operational Energy Company, an affiliate <br /> of Zurn Industries, Inc. <br /> On November 13 , 1989, the Department, acting upon a request made by <br /> Industrial Resource Recovery, determined that the ash from the <br /> Wadham facility was hazardous waste due to significant quantities <br /> of crystalline silica, and the potential threat to humans exposed <br /> to airborne respirable crystalline silica particles from the waste. <br /> On May 2, 1990, the Department, acting upon a request for <br /> concurrence made by Wadham, again determined that the ash was <br /> hazardous waste. The rice hull ash generated at that time <br /> contained an average of 16 percent crystalline silica. There was <br />