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• Mr. Bevin T. Haroff Page 2 On October 2, 1989, the Department received a request from Industrial Resource Recovery (IRR) to classify this ash. IRR is a marketing firm which had, at the time of the request, a contractual relationship with Wadham. The Department responded to IRR on November 13, 1989, classifying the ash as hazardous waste (WEU File No. 1212) . By letter dated November 20, 1989, Wadham objected to the Department's determination on the basis that the request for classification was initiated by a party other than the waste producer and that Wadham believed the data used to make the determination was not representative of the currently generated ash. Wadham expressed its intent to submit new information supporting a nonhazardous waste classification. On November 21, 1989, the Department collected six samples of ash from various locations at the Wadham facility. These samples were split with Wadham personnel who witnessed the sampling. The Department's samples were delivered to its Air and Industrial Hygiene Laboratory (AIHL) in Berkeley, California, on the following day. On November 27, 1989, the Department received a request (dated November 22, 1989) from Wadham for concurrence with their nonhazardous waste determination pursuant to Section 66305 (c) , 22 CCR. On December 12 , 1989, representatives from Wadham and Oxford Energy met with Department representatives to discuss issues surrounding the classification of the ash. (The issues discussed at this meeting included: Wadham's contention that there were no particles with a size less than 38 microns in the ash; a possible relationship between mean aerodynamic diameter and respiration of the particles; the effect of changes in plant operation, specifically, incineration temperature's effect on size distribution of free crystalline silica particles and the Department classifying the ash at the request of a party other than the generator. ) On December 26, 1989, the Department acknowledged receipt of Wadham's November 27, 1989 application. On December 27, 1989, the Department received from Wadham six additional analytical reports from Southwestern Laboratories regarding particle size. On February 14 and February 27, 1990, the Department received from AIHL analytical results for the samples collected on November 21, 1989.