CORRESPONDENCE_1990 - 1992 - Laserfiche WebLink

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Mr.Lecil M.Colburn -2- 19 November 1990 by your company. During the last decade, monitoring activities at many of our Class III landfills have revealed elevated levels of volatile organic and other pollutants in ground waters. Adequate responses to the requests for additional information, contained in Bill Marshall's 7 November 1990 letter to you, are needed before staff of the Regional Board can determine whether constituents in the Celotex waste stream pose a threat to the quality of ground water beneath the Corral Hollow Class ffi Landfill. That determination will result in the classification of the Celotex waste as either 'designated waste' or 'nonhazardous solid waste' under Title 23 of CCR §2522(a)(1), with respect to the Corral Hollow site. The following is a restatement and further explanation of the five points raised at the end of Bill Marshall's 7 November 1990 letter: 1. Representative sample(s) of the waste proposed for disposal at the 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. The analytical information supplied to date is insufficient for use by the Regional Board in determining the appropriate classification of the Celotex waste stream. Samples of the waste must be tested for extractable lead per the 22 CCR§66700 WET procedure. That procedure requires EPA method 7421 be used to analyze the WET extract for lead. Analytical precision should be such that, at a minimum, 0.5 mg/l of lead may be detectable in the WET extract. Also of concern is information contained in the MSDS that polyisocyanurate foam insulation contains approximately 15 percent of a "proprietary chlorofluorocarbon." Chlorofluorocarbons are highly mobile pollutants in subsurface environments. If available to leach in sufficient concentrations from Celotex waste discharged to a Class III landfill, these pollutants could pose a serious threat to ground water quality. Many chlorofluorocarbons are suspected carcinogens. As little as a few parts per billion of certain of these compounds can render ground water unusable for domestic and municipal supply. Previous Celotex waste TCLP extracts have not been analyzed for chlorofluorocarbons, rendering the data from these earlier tests inconclusive for determination of the water quality threat posed by these waste constituents. Previous TCLP analytical results indicate that Celotex waste also contains chloroform. To ascertain whether these pollutants are available at sufficient concentrations to threaten ground water quality, representative samples of Celotex waste shall be subjected to the TCLP procedure (the WET cannot be used for volatile constituents), with the extracts analyzed by EPA Method 601, 502.2 or 524.2 (halogenated volatile organics). All chromatographic peaks should be identified and reported. At a minimum, the analytical effort should reveal concentrations of chloroform and the "proprietary chlorofluorocarbon" in the TCLP extract. Analytical detection limits should be comparable to those contained in EPA Method 601, 502.2 or 524.2 procedures. The identity of the "proprietary chlorofluorocarbon" shall be included.