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SAN JOAQUIN COUNTY Q -% <br />U): < <br />JOGI KHANNA NI.D., M.P.H. <br />Health Officer <br />Cq � I F pR N\P <br />P.O. 11ox 2009 (1601 East Hazelton Avenue) • Stockton, California 95201 <br />(209) 468-3400 <br />November 20, 1990 <br />Lecil Colburn <br />Director, Environmental Affairs <br />Celotex Inc. <br />P. O. Box 31075 <br />Tampa, Florida 33607 <br />Re: Celotex Wastes, Corral Hollow Landfill, San Joaquin County <br />The California Integrated Waste Management (CIWMB) enforcement <br />officer listed celotex as a hazardous waste violation during the <br />state inspection on August 1, 1990 at the Corral Hollow Landfill. <br />The San Joaquin County Public Works Department has sent a letter <br />stating Celotex Inc. must receive regulatory approval by all <br />concerned agencies by October 31, 1990. On October 31, 1990, Mr. <br />Colburn contacted me stating he needed approval from our agency so <br />celotex wastes may be accepted at the Corral Hollow landfill. Mr. <br />Colburn was told that the Environmental Health Division (EHD) could <br />not make this decision since no testing information had been sent <br />to EHD and the Corral Hollow Landfill could not accept hazardous <br />wastes (Class 1) or designated wastes (class 2). Corral Hollow <br />landfill is a class 3 landfill and may only receive class 3 wastes. <br />Celotex wastes have to be classified as a non -hazardous waste and <br />a non -designated waste before Corral Hollow landfill can receive <br />this waste material. The California Regional Water Quality Control <br />Board will do the designated waste classifi.caticin as stated in <br />their letter of November 7, 1990. EHD at this time is concerned <br />about the classifying celotex waste as a non -hazardous waste as <br />outlined in California Health Safety Code Title 22, Article 11. <br />Nothing less than the complete and proper testing of the celotex <br />wastes under Title 22 can be accepted. <br />No rationale was presented on how a single sample from the <br />Midwest, tested over 4 years ago is representative of the Tracy <br />plant. No comparative analysis between the two celotex plants were <br />submitted. Stating that it is a "sister" waste is inadequate. <br />Also, no discussion of the materials analyzed by ARDL and Suburban <br />Laboratories were presented. EHD requested EPA test methods for <br />the Suburban Labs tests, we received a EPA Regulation 40CFR261.24 <br />which lists maximum concentration levels for contaminants for EP <br />toxicity. This section does not list EPA test methods that <br />Suburban Labs performed for your company. It is difficult to <br />follow the logic of different tests data when incomplete <br />information is submitted. <br />A Division of San Joaquin County Health Care Services 40 <br />