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Mr. Lecil M. Colburn -3- 28 February 1991 Analytical results on the latest sample taken of the Celotex waste are not in agreement with earlier information supplied by you. The Material Safety Data Sheet (MSDS) states that Celotex insulation contains approximately 15 % of a "proprietary chlorofluorocarbon". In our telephone conversation of 26 November 1990, you stated that the only chlorofluorocarbon used in the manufacture of Celotex is trichlorofluoromethane. Your TCLP analytical results for trichlorofluoromethane indicate that 0.16 mg of trichlorofluoromethane was present per liter of extract. This is equal to (0.16 x 20) or 3.2 mg trichlorofluoromethane per kg of waste, far less than the 15 % claimed in the MSDS. No information was provided in your letter as to the date or method of sample collection, even though our 19 November letter specifically required that detailed sampling information be provided. Was the 13 February 1991 TCLP analysis performed on a portion of the October 1990 stored sample? Long-term storage can result in the loss of volatile organic constituents from a sample, making the analytical results unrepresentative. Due to the inadequacies in your 20 February 1991 submittal, as detailed above, Regional Water Board staff is unable to determine whether the Celotex waste is a "designated waste" or a "nonhazardous solid waste", as required for the evaluation of the appropriateness of its disposal in the Corral Hollow Class III Landfill. Questions regarding this letter may be directed to me at (916) 361-5724. B. Marshack, D. Env. Senior Environmental Specialist Environmental/Technical Support Unit Land Discharge Section ,m cc: Jack Miller, California Integrated Waste Management Board, Sacramento Tom Horton, San Joaquin County Solid Waste Division, Stockton Ed Padilla, San Joaquin County Division of Health Services, Stockton