Laserfiche WebLink
September 2, 1983 <br /> Project 116-1.4 <br /> - 4 - <br /> Our review of current State and Federal Regulations indicates that all of <br /> the materials listed in Table 1 are considered to be Group 1, Hazardous <br /> Wastes by the State Regional Water Quality Control Board and the State <br /> Department of Health Services. With the possible exception of the filter <br /> cake sludge from Proctor and Gamble Coampany, Sacramento, none of the <br /> waste materials are listed as hazardous by the United States <br /> Environmental Protection Agency. We have been unable to obtain pertinent <br /> waste classification details from the environmental staff at the Proctor <br /> and Gamble Company. <br /> Based upon the background information outlined above, recent <br /> classification of the FMC waste as non-hazardous by your agency and the <br /> decision made by the site owner to discontinue all future hazardous waste <br /> operations, we considered the Forward site to be outside the jurisdiction <br /> of EPA as set forth in the Resource Conservation and Recovery Act and <br /> Part B of the Hazardous Waste Application would not be required. When <br /> notified of our intention to discontinue hazardous waste operations, <br /> staff of the California Department of Health Services concurred with our <br /> interpretation of the Hazardous Waste Application requirements, but <br /> indicated that State hazardous waste classification criteria differed <br /> from current Federal regulations and the Forward site would continue to <br /> be regulated in accordance with the provisions of our DOHS Hazardous <br /> Waste Permit. <br /> We appreciate your cooperation in our attempt to resolve any <br /> misinterpretation of EPA requirements and if you require further <br /> information, please call. <br /> Respectfully Submitted, <br /> BETA ASSOCIATES, INC. (Acting as authorized Agent of Forward, Inc.) <br /> ack E. McCollough ( � <br /> Registered Geologist #1559 <br /> Certified Engineering Geologist #905 <br /> JEM:sh <br /> Attachment <br /> cc: Mr. Gregory Basso, Forward, Inc. <br /> Mr. John Stovall, Neumiller & Beardslee <br /> Mr. Lee Hall, San Joaquin Local Health District <br /> Mr. Gary Reents, California Department of Health Services <br /> Mr. John Marshak, California Regional Water Quality Control Board, <br /> Toxics Unit - <br /> Mr. Paul Yochum, FMC Corporation, Modesto <br /> GBeta c-_4ssociates �j <br />