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Mr. Kevin T. Haroff Page 3 On March 12, 1990, representatives from Wadham and Oxford Energy again net with Department representatives to discuss additional issues surrounding the classification of the ash and to persuade the Department to classify the ash as nonhazardous based on new analytical results and different arguments. (The additional issues discussed at this meeting included: that a "no effect level" exists for exposure to free crystalline silica; that Wadham could not envision any exposure scenario that would exceed this level; whether or not the free crystalline silica particles are "friable" ; parallels between free crystalline silica and asbestos, for use of the one percent regulatory threshold; and a concern that many "naturally occurring" materials would be considered hazardous if the Department chooses to regulate free crystalline silica. None of the issues brought up in the previous December 12, 1989 meeting were pursued further at this meeting. ) At this meeting, Wadham distributed a report entitled "Preliminary Analysis and Interpretation of Laboratory Data on Rice Hull Ash from the Wadham Energy Facility in Williams, California, " prepared by ENSR Consulting and Engineering (ENSR) . The report included the analytical results of samples taken by Wadham on January 5, 1990, and analyzed by the laboratories of the RJ Lee Group (RJ Lee) and Southwestern Laboratories (SWL) . RJ Lee's analytical reports were dated January 30, 1990, and March 3, 1990, and SWL's analytical report was dated January 9, 1990. Throughout this time frame, Wadham had, on several occasions, expressed its intent and announced its plans to ship quantities of the ash to "commercial users" of the ash. ANALYTICAL RESULTS Wadham's November 22, 1989 application contained 38 analytical reports from SWL quantifying free crystalline silica by x-ray diffraction in ash samples collected at the Williams plant between June and August 1989. Wadham also submitted 11 SWL reports concerning particle size. These reports reflected screening tests conducted between July 14, 1989, and November 21, 1989. An additional report from Resource Materials Testing, Inc. , dated August 7, 1989, was submitted with the application. On December 27, 1989, the Department received six additional SWL reports regarding particle size. The first 38 SWL reports show free crystalline silica content ranging from 0.3 to 45.5 percent. Based on these data, the mean free crystalline silica content is approximately 16 percent. The concentration of free crystalline silica at the 80 percent upper confidence limit is calculated to be 18.8 percent. The 80 percent lower confidence limit is calculated to be 13.2 percent. SWL reports previously submitted by IRR indicated a mean free crystalline silica content of 18 percent in the Wadham ash. e�