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r �✓ Ions <br /> � ' <br /> The letter states that the Water Board reviewed the analytical data for the baghouse dust <br /> proposed to be disposed of at the Forward, Inc. Class II-1 landfill and stated that due to the caustic <br /> nature (pH of 11.5) and high selenium concentration (350 times the CAM hazardous level) this <br /> material was not suitable for disposal at the Forward Landfill. <br /> t s frca ,b cif � 4 his � rb C -Ft d Le <br /> t¢tIll eIIr01 <br /> The letter requested that the baghouse (aka batch) dust be reclassified from hazardous to <br /> nonhazardous waste. It was indicated that the dust is generated during the transporting and <br /> mixing of raw materials in their glassmaking facility and contains soda ash which is listed in the <br /> code as a hazardous waste. The letter stated that the analytical data indicated the batch dust had <br /> a pH of 11.5, less than the California criteria for corrosivity of 12.0 or greater and that based on <br /> this, they disposed of approximately 750 tons of batch dust on site during 1981. <br /> =,— <br /> =Pxomk-411111 <br /> ent of 0etifth <br /> The letter is in response to the request by LOF to reclassify the waste from hazardous to <br /> nonhazardous. The State DEH agreed that with respect to pH of the dust, the pH of 11.5 would <br /> classify the waste as nonhazardous; however, they mentioned their concern about the possible <br /> presence of persistent and bio-accumulative inorganic metals substances and fluorides in the <br /> wastef'baghouse dust." The letter concluded that on the assumption that it was the position of <br /> LOF that these metals substances are not present beyond the prescribed concentrations that they <br /> were granted their request to reclassify the "baghouse dust" as nonhazardous per Title 22 <br /> hazardous waste regulations at that time. <br /> as #roe 'a pang LSF O � r <br /> The letter states that the Lathrop LOF Glass facility uses the land disposal method for discarding <br /> the plant's solid waste material. The letter stated that an area of the plant grounds is set aside for <br /> this purpose and consists of approximately 18 acres. They summarized the discard materials and <br /> their composition of the"total fill by weight" as follows: <br /> plastic 3% <br /> metal strips 3% <br /> wood 2% <br /> scrap lass 20% <br /> lass batch dust 72% <br /> Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 13 <br />