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IDEPARTMENT <br /> - OF <br /> �Eg <br /> CALIFORNIA—HEALTH AND WELFARE Ar* GEORGE DEUKMEJIAN, Gomnor <br /> P <br /> RTMENT OF HEALTh SERVICES DEC 4 1S <br /> 714/7" P STREET -ALT'-' <br /> P.O. BOX 942732 ENV'jl. r A L HIE' <br /> SACRAMENTO, CA 942147320 <br /> Fr <br /> i..itiV <br /> (916) 322-3670 November 30, 1989 <br /> Mr. Darrell D. Scott <br /> City of Tracy <br /> 3900 Holly Drive <br /> Tracy, CA 95376 Ar�, <br /> Dear Mr. Scott: <br /> WASTE CLASSIFICATION OF SLUDGE FROM WASTEWATER TREATMENT PLANT, <br /> CITY OF TRACY <br /> The Alternative Technology Division (ATD) of the Department of <br /> Health Services (DHS) has completed its review of the submitted <br /> analytical data for sludge from the City of Tracy wastewater <br /> treatment plant. Based on the information submitted, DHS concludes <br /> that the sludge generated from the wastewater treatment plant is <br /> classified as nonhazardous. <br /> The City of Tracy originally submitted a waste classification <br /> application to DHS for its sludge on March 7, 1988. The <br /> application was found to be deficient in a number of areas relating <br /> to sampling and the types of analytical testing required for proper <br /> characterization of the sludge. The specific deficiencies in your <br /> original application were called to your attention in a letter <br /> dated May 10, 1988, and signed by Mr. Stanford C. Lau. On <br /> September 19, 1989, DHS received from the City of Tracy a new set <br /> of analytical data for its wastewater treatment sludge. A total <br /> of eight sets of sludge data, labelled PI-4, B5, and B11-13, were <br /> submitted. Included in these sets of data were results from <br /> analytical testing for inorganic persistent and bioacumulative <br /> toxic substances pursuant to Section 66699, Title 22, California <br /> Code of Regulations (CCR) ; acute aquatic 96-hour LC,, pursuant to <br /> Section 66696, 22 CCR; and analyses for PCBs and semi-volatile <br /> organics. On October 30, 1989, Mr. Ron Pilorin of my staff <br /> contacted you by telephone, and followed with a letter to you dated <br /> November 6, 1989, concerning the validity of the aquatic bioassay <br /> in the new data set performed by CH2M Hill Environmental Laboratory <br /> and the need to repeat the bioassay due to a discrepancy in a <br /> testing parameter (water hardness) . As a result of the telephone <br /> conversation and subsequent letter, Dr. James Polisini of the <br /> California Department of Fish and Game, Fish and Wildlife Water <br /> Pollution Control Laboratory, contacted Mr. Pilorin by telephone <br /> on November 8, 1989. Dr. Polisini indicated that upon his review <br /> of the aquatic bioassay testing results with CH2M Hill <br />