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Mr. Kevin T. Haroff <br /> Page 12 <br /> Another option which may be pursued is treatment to render the ash <br /> nonhazardous. Any such treatment must be done at a facility which <br /> possesses a permit from the Department to treat hazardous waste. <br /> Treatment may be done on-site if Wadham obtains a permit or a <br /> variance from the Department. The ash may also be disposed at any <br /> site designated and permitted as a Class I hazardous waste disposal <br /> site in California. Treatment or disposal at a site other than one <br /> possessing a permit from the Department may be allowed if Wadham <br /> and/or the receiving facility obtain variances from the Department <br /> and if the treatment or disposal meets the requirements of all <br /> other regulatory agencies. options for pursuing a variance may be <br /> discussed with the Department's Region 1 (Sacramento) office at <br /> (916) 855-7700. The management of this ash remains subject to <br /> regulation by the Regional Water Quality Control Boards and other <br /> state as well as local agencies. <br /> With respect to the ash already disposed at the Colusa County <br /> landfill, the Department recommends that this ash remain in place. <br /> This recommendation is based on the fact that there are no <br /> Persistent and Bioaccumulative Toxic Substances in the ash at <br /> concentrations approaching limits established by the Department, <br /> and on research conducted by Fuller (1977) who suggested that <br /> particles less than two µm in diameter will not move through soil <br /> any faster than one to ten centimeters every 3,000 to 40,000 years <br /> (with larger particles moving even more slowly) . The Department <br /> does not think that the disposed ash represents a hazard to human <br /> health and safety, livestock, or wildlife, so long as it remains <br /> undisturbed in the landfill. We believe that attempts to remove <br /> the ash from this site would create problems of fugitive emissions <br /> and exposure. <br /> Questions concerning this determination may be directed to <br /> Mr. Richard Brausch at the letterhead address or telephone number. <br /> Sincerely, <br /> Gre lliams <br /> 9 <br /> Alternative Technology Division <br /> Toxic Substances Control Program <br /> ccs See Next Page. <br />