Laserfiche WebLink
STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> a <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 \w.m <br /> 7 November 1990 ' " <br /> e ; iiLiY <br /> V <br /> V 1 <br /> 90 n <br /> Lw.6 N�9f I r _, i <br /> Mr. Lecil Colburn, Directorkvk .fj�a a <br /> Environmental Affairs <br /> Jim Walter Corporation <br /> P 0 Box 31075 <br /> Tampa, Florida 33607 <br /> CORRAL HOLLOW LANDFILL, SAN JOAQUIN COUNTY - CELOTEX WASTES (CASE NO. 1896) <br /> We have reviewed your letter of 19 October 1990 in which you propose a rationale <br /> for the disposal of Cel otex wastes at the Corral Hollow Landfill . You submitted <br /> the results of a single Waste Extraction Test (WET) analysis in which the extract <br /> was analyzed for lead with a detection limit of 1.0 mg/1 . Lead was not detected <br /> at the 1.0 mg/l detection limit. Next, you used a Maximum Contaminant Level <br /> (MCL) of 0.05 mg/l for lead as the water quality goal for ground waters beneath <br /> the Corral Hollow Landfill . You applied an attenuation factor of 500 to the <br /> water quality goal of 0.05 mg/1 . This resulted in an "acceptable" waste <br /> concentration of 25 mg/l . Since 25 mg/l is greater than the 1.0 mg/l detection <br /> limit, you reasoned that the wastes should be acceptable for disposal at the <br /> Corral Hollow Landfill . <br /> As an additional justification for the acceptance of Celotex wastes at Corral <br /> Hollow Landfill , you submitted a Material Safety Data Sheet (MEDS) which did not <br /> indicate the presence of lead in "Tuff-R Insulating Sheathing Products: Ar-mor <br /> Sheathing. " You also submitted laboratory reports from Applied Research and <br /> Development Laboratory (ARDL) and Suburban Laboratories. The ARDL test samples <br /> are labeled "DUST," "DUSTDL," "RIGID FOAM,'° "RIGID FOAMDL, " and "Insulation <br /> Saimnple.°' The ARDL "DUST" sample contained 0.19 mg/l of lead as identified <br /> through the Toxicity Characteristic Leaching Procedure (TCLP) . The TCLP extract <br /> also contained three volatile organic compounds. These include chloroform, 2- <br /> butanone and chlorobenzene. The MEDS also indicate that Tuff-R insulating <br /> sheathing consists of 15% proprietary chlorofluorocarbon. No discussion <br /> regarding the safe disposal of these compounds at Corral Hollow Landfill was <br /> included with your submittals. <br /> Our review of your submittals identified the following problems: <br /> 1. Attenuation - An attenuation value of 100 is allowed based on the fact <br /> that at least 30 feet of alluvial materials containing a significant <br /> clay content exist between the base of the landfill and the highest <br /> level of ground water. See Regional Board letter to "Owners and <br /> Operators of Class III Landfill Units," dated 3 November 1988 and <br /> revised 30 March 1989. Higher attenuation values must be justified <br />