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• .i'm alter corporation Post Office Box 31075 TAMPA, FLORIDA 33631-3075 March 28, 1991 Jon B. Marshack, D. Env. Senior Environmental Specialist Environmental/Technical Support Unit Land Discharge Section California Regional Water Quality Control Board Central Valley Region 3443 Routier Road, Suite A Sacramento, CA 95827-3098 Re: Waste Material for The Celotex Corporation Tracy, California Facility Corral Hollow Dear Mr. Marshack: r ENVIRQNNII 4 I Jit �-"i Your letter of February 28 recognizes that the concentration of lead and trichlorofluoromethane are below the soluble designated levels that would apply to Corral Hollow landfill. Your letter also indicates that the soluble designated level for chloroform is 0.023 mg/l. Attached you will find laboratory test results from Anlab showing that no chloroform was detected with a detection level of 0.02 mg/1 utilizing EPA method 601. The samples that have been taken over the past few months were taken in accordance with EPA sampling protocol and delivered immediately for analysis, therefore, they are representative of the entire waste stream generated at the Celotex facility. You have also raised the question as to why the MSDS shows the product manufactured at the Celotex plant contains approximately 15% trichloro- fluoromethane and the analytical results of the waste material only indicates 0.16 mg/1 present. It would not be expected to find that the waste material contains 15 % trichlorofluoromethane in that the majority of the waste generated is material from trimming the edges of the formed board and proper sizing utilizing mechanical saws. Trichlorofluoromethane in the product is essentially encapsulated in the closed cell structure of the material itself. The material collected from sizing and trimming of edges would not be expected to contain closed cells as the finished product would.