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Mr. Robert Graulich Page 3 On February 11, 1991, a report entitled "Air Monitoring Operation; Wadham Energy Company; Williams Facility" was prepared by ENSR detailing the results of air monitoring conducted at the facility between the dates of September 6, 1990 and November 16, 1990. On March 27, 1991, representatives of the Department, Wadham, and ENSR met to discuss methods by which the risk posed by the ash might be quantified and assessed. On April 16, 1991, the Department received a report prepared by ENSR entitled "Estimated Health Risk Associated with Respirable Crystalline Silica in Rice Hull Ash Currently Being Produced at the Wadham Energy Facility in Williams, California." On May 23, 1991, the Department received a revised version of the ENSR report entitled "Estimated Health Risk Associated with Respirable Crystalline Silica in Rice Hull Ash Currently Being Produced at the Wadham Energy Facility in Williams, California. " On May 30, 1991, Dr. Klein finalized her comments on the April 16, 1991 ENSR report (the comments in this memo had previously been communicated to ENSR by telephone, precipitating the May 23, 1991 revised report) . On June 6, 1991, Dr. Klein finalized her comments on the May 23, 1991 ENSR report. On June 7, 1991, ENSR responded to Dr. Klein's comments and provided the information which she had identified as missing in her review of the report. ANALYTICAL DATA In previous applications and determinations, it was demonstrated that the ash does not exhibit any other criterion of hazardous waste except for toxicity pursuant to §66696 (a) (6) , 22 CCR and §25117, California Health and Safety Code (HSC) , and that the only constituent of concern is silica. In this request, Wadham provided analytical data to demonstrate two characteristics of the ash currently being generated: 1) The total concentration of crystalline silica within the ash (in weight percent) ; and 2) The weight percentage of crystalline silica with a particle size of less than 10 microns (i.e. , respirable particles) . Total Crystalline Silica: Wadham provided results from a total of 27 different ash samples (results of samples taken from different locations within the incineration process were combined in a ratio of 80 percent baghouse ash to 20 percent bottom ash) . The analytical work was performed by Southwestern Laboratories (SWL)