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r <br /> TATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A ! , <br /> SACRAMENTO, CA 95827-3098 <br /> 19 November 1990 <br /> Mr. Lecil M. Colburn, Director <br /> NOV 2 1 1-9?� <br /> Environmental Affairs ��`�� ' `v <br /> Jim Walter Corporation '► <br /> P.O. Box 31075 <br /> Tampa, Florida 33631-3075 <br /> CHARACTERIZATION OF CELOTEX WASTES FOR DISPOSAL AT THE CORRAL <br /> HOLLOW CLASS III LANDFILL, SAN JOAQUIN COUNTY(CASE NO. 1896) <br /> Your 9 November 1990 response to Bill Marshall's letter of 7 November 1990 indicates <br /> that you may be unfamiliar with California's waste classification system. Our system <br /> is very different from that used by the U. S. Environmental Protection Agency under <br /> the Resource Conservation and Recovery Act (RCRA) of 40 CFR. In California, the <br /> Department of Health Services and the Regional Water Quality Control Boards <br /> classify wastes as 'hazardous', 'designated', 'nonhazardous solid', or 'inert', based on <br /> regulations contained in Titles 22 and 23 of the California Code of Regulations (CCR). <br /> Once classified, these wastes may be discharged to Class I,Class II, Class III or <br /> unclassified waste management units, respectively. Testing protocols and regulatory <br /> criteria used by EPA are not sufficient to classify wastes in California. <br /> To help you understand how wastes are classified under California statutes and <br /> regulations, I have enclosed copies of three pieces of information. The first is a copy <br /> of an information packet on waste classification which we have sent to all Central <br /> Valley Region Class III landfill operators. That packet summarizes the California <br /> system of waste classification and provides procedures for calculation of Designated <br /> Levels used by our staff in determining whether a waste poses a site-specific threat to <br /> ground and/or surface water quality. I have also enclosed two memoranda <br /> summarizing hazardous waste classification under Title 22 of CCR and a comparison <br /> of the federal Toxicity Characteristic Leaching Procedure (TCLP) and California's <br /> Waste Extraction Test (WET). I hope that these documents will help in clarifying the <br /> basis for our concerns regarding Celotex waste disposal at the Corral Hollow Landfill <br /> in San Joaquin County. <br /> The test information which you have supplied on the Celotex waste stream to date <br /> indicates that the waste is not likely to be classified as hazardous under either federal <br /> or state criteria. However, as can be seen from a review of the enclosed information, a <br /> waste does not need to be classified as "hazardous" for it to pose a site-specific threat to <br /> water quality. Our concerns over a potential threat to water quality have been raised <br /> by the Celotex waste analytical results and by the Material Safety Data Sheet, supplied <br />