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Mr. Robert Graulich Page 2 evidence that, although only a small percentage of the crystalline silica was measured to be respirable particles, the remainder of the crystalline silica particles could become respirable due to waste handling. On October 3, 1990, Wadham submitted a request to the Department for concurrence with its new nonhazardous determination, based on data from newly generated ash which contained less crystalline silica. On October 12, 1990, representatives of the Department and Wadham met to discuss the new classification request. On October 22, 1990, representatives of the Department and Wadham met at the facility to discuss additional data and information needed to proceed with the evaluation of the request. Four samples were taken from the ash silo on this date [two were to be analyzed by Wadham, two by the Departments Air and Industrial Hygiene Laboratory (AIHL) ] . On October 25, 1990, four additional samples were collected by Wadham from the ash silo (two for Wadham, two for the Department) . On October 29, 1990, an additional four samples were collected by Wadham from the ash silo (two for Wadham, two for the Department) . On November 9, 1990, John Brantner, Ph.D. and A. Kimiko Klein, Ph.D. , of the Department's Toxic Substances Control Program, Toxicology and Risk Assessment Section finalized a determination that the inhalation exposure for respirable crystalline silica which is associated with one extra cancer occurrence in a million persons exposed is 0.028 µg/m3. On November 19, 1990, Wadham provided to the Department analytical results from the samples collected on October 22, 25, and 29, 1990. On November 21, 1990, the Department requested additional information from Wadham in order to complete the evaluation of Wadham°s request for concurrence. On November 28, 1990, Wadham acknowledged its receipt of the Department's request for additional information, and provided an action plan it proposed to follow in acquiring and providing the additional information. On February 7, 1991, the Department received the additional information it had requested from Wadham in the form of a report prepared by ENSR Consulting and Engineering (ENSR) entitled "Supplemental Analytical Report Regarding the Characteristics of Rice Hull Ash Produced at the Wadham Energy Facility in Williams, California."