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Mr. Lech M. Colburn -2- 28 February 1991 determine the reason for the high detection limit. Patricia Bucknell of Anlab said that the October 1990 sample had been re-analyzed in November using a 0.001 mg/l detection limit. I asked her to send me a copy of the revised results by facsimile machine. That analysis, dated 13 November 1990, shows a WET lead result of 0.009 mg/l, below the Soluble Designated Level. The chloroform result contained in your latest submittal (Anlab analytical sheet dated 13 February 1991) shows that chloroform was not detected, with a detection limit of 0.10 mg/1. This value is higher than the 0.023 mg/l Soluble Designated Level. Your submittal indicates that Method 624 was used to analyze the TCLP extract. Our 19 November 1991 letter required the use of EPA Method 601, 502.2, or 524.2 with analytical detection limits comparable to Method Detection Limits for these methods. T hese methods have detection limits sufficiently low to indicate the presence of chloroform at levels below the Soluble Designated Level. You indicate in your letter that Method 624 was used because it provides "a more complete analysis" than the required methods. The detection limit for the analysis was far in excess of that requested in our letter. While Method 624 does provide additional data on non-chlorinated volatiles which are not included in the required methods, none of the waste constituents of concern is a non-chlorinated volatile organic chemical. Therefore, the potential for chloroform in Celotex waste to pose a water quality threat at the Corral Hollow Class III landfill cannot be assessed from the data submitted. The trichlorofluoromethane result of 0.16 mg/l is below the Soluble Designated level of 0.75 mg/1. 3) You claim in your letter that this latest sample is representative of the entire waste stream. However, no documentation has been provided to justify the representativeness of the sample data submitted with your 20 February 1991 letter. Our November 1990 letter to you required that representative samples be taken and justification be provided as to the representativeness of the samples. Without such documentation, the Regional Board is unable to ascertain whether the analytical results are truly representative of the Celotex waste stream as discharged to the Corral Hollow Landfill. In telephone conversations with you in late November 1990, you claimed that the variability in the Celotex waste is virtually nonexistent, due to stringent process controls at the manufacturing facility. No documentation of the uniform nature of the waste stream was contained in your 20 February 1991 submittal. Assuming normal rates of sampling and analytical error/variability, analytical results for any one sample cannot be considered representative of even an extremely uniform waste stream. August 1990 TCLP analytical results on Celotex insulation "dust" and "rigid foam" samples showed chloroform levels ranging from 0.006 to 0.120 mg/l, indicating considerable variability exists either in the waste stream or in sampling and analytical protocols.