CORRESPONDENCE_1990 - 1992 - Laserfiche WebLink

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Mr. Lecil Colburn -2- 7 November 1990 through a more detailed analysis by a qualified professional . 2. Waste Characterization - The use of an MSDS is unacceptable because MSDS do not reveal concentrations of lead in a product which would cause it to be a "designated waste. " TCLP results are acceptable as an indicator of organic compound leaching potential , however a WET analysis must be done for elements or non-volatile compounds of concern. The WET and subsequent analysis for lead completed by Anlab had a detection limit of 1.0 mg/l , which is too high to adequately characterize lead concentrations in the Celotex wastes. The California Code of Regulations, Title 22 requires that EPA Method 7421 be used for lead analyses on WET extracts. Method 7421 has a detection limit of 0.001 mg/1 . 3. Volatile Organic Compounds - Chloroform has a water quality goal of 0.5 to 5 micrograms per liter (ug/1 ) . Multiplying this goal by the 100-fold attenuation factor and dividing by the TCLP dilution, which is 20, results in "designated" levels of 2.5 to 25 ug/1 . Since chloroform was found at 120 ug/l , chloroform would make the Celotex wastes a "designated waste" at the Corral Hollow Landfill . None of the laboratory tests looked for chlorofluorocarbons, even though MSDS indicate that sheathing contains 15% chlorofluorocarbons. 4. Representativeness of Samples - No rationale was presented concerning the ability of the single sample from the Tracy Celotex wastes to adequately rep_rqj=jthe waste stream proposed for disposal at Corral Hollow. Also, no"discussion of the materials analyzed by ARDL and 4uburban Laboratories was presented. Therefore, it is impossible to Aermine how these analyses represent the Tracy waste stream. 5. Maximum Contaminant Levels - EPA has proposed a new MCL for lead. Should this new MCL, 0.005 mg/1 , be approved, your analysis must be revised. 6. Dilution in Laboratory Tests - The WET results in a ten-fold dilution of the extract. Therefore, when calculating a "designated waste" level , the product of the water quality goal and the attenuation must be divided by the dilution factor. A dilution factor of 20 must be used with TCLP results. In order for the Regional Board to approve the disposal of Celotex wastes at the Corral Hollow Landfill , we require that you do the following tasks: 1. Representative sample(s) of the waste proposed for disposal at Corral Hollow Landfill must be analyzed for lead, chlorofluorocarbons and chloroform. Analysis for lead must be by the WET and must use the required Title 22 analyses. An explanation of any deviations from the required analyses must be included.