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r ; <br /> Mr.Lech M.Colburn -3- 19 November 1990 <br /> Trade secret information may be kept confidential by the Regional Board if requested <br /> in writing by Celotex Corporation. <br /> All analytical work must be performed by a California Department of Health Services <br /> certified laboratory. <br /> 2. Sampling protocol must be detailed so as to explain why the sample(s) is/are <br /> representative of the waste stream. <br /> Samples of Celotex waste analyzed by the above protocols must be representative of <br /> the waste stream proposed for discharge to the Corral Hollow Landfill. The sampling <br /> protocol and number of samples taken should be determined so as to assure the <br /> representativeness of the analytical data presented to Regional Board staff. It is <br /> recommended that sampling procedures follow EPA protocols as closely as possible. <br /> 3. Explanation/rationale for the use of greater than a 100 fold attenuation must be <br /> provided. A qualified professional must sign the report justifying the higher <br /> attenuation. <br /> Our guidance to Class III landfill operators permits the use of 100-fold attenuation for <br /> most waste constituents at facilities having the geologic conditions present at Corral <br /> Hollow. The use of higher than a 100-fold attenuation factor for lead, chloroform, and <br /> chlorofluorocarbons is permissible upon justification which is based on a sufficiently <br /> detailed, site-specific environmental fate analysis of the pollutants of concern. Such <br /> justification shall be made and approved by a qualified professional, as required by <br /> our Title 23 of CCR, Division 3, Chapter 15 regulations and by the California Business <br /> and Professions Code. <br /> 4. Evaluation of "designated waste" levels for all compounds which could threaten <br /> water quality must be provided. <br /> Your submittal should include the calculation of appropriate Soluble Designated <br /> Levels for lead, chloroform, chlorofluorocarbons, and any other Celotex waste <br /> constituents which have the potential to degrade water quality. Procedures for these <br /> calculations are provided in the enclosed information. <br /> 5. The proper dilution factors must be used in determining "designated waste" <br /> levels. <br /> As explained in the enclosed letter to Class III landfill operators, the dilution factor <br /> from the particular extraction procedure used is to be included in the Soluble <br /> Designated Level calculation. In the WET procedure, 50 grams of waste is placed in <br /> 500 milliliters of extraction solution, yielding a 10-fold dilution. This dilution factor <br /> should be used for Soluble Designated Levels calculated for lead and other non- <br /> volatile waste constituents for which the WET procedure is used. The TCLP utilizes a <br /> 20-fold dilution. The 20-fold factor would be used in calculating Soluble Designated <br />