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C, �F ° * STATE.OF CALIFORNIA GEORGE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD, SUITE A a car SACRAMENTO, CA 95827-3098 RECEIVla— u u 10 October 1990 ENVIRONMENTAL HEALTH PERMIT/SERVICES Mr. Lecil M. Colburn, Director Environmental Affairs The Celotex Corporation Post Office Box 31602 Tampa, Florida 33631-3602 CORRAL HOLLOW LANDFILL, SAN JOAQUIN COUNTY (Case No. 1896) I have reviewed the results of a Waste Extraction Test (WET) on foam insulation. The test was performed by Anlab. Lead was the only metal analyzed. A minimum detection limit of 1 .0 mg/l was used. This detection limit is relatively high. At the nearby Forward landfill "designated" wastes are distinguished from "non- designated" wastes at an extractable lead concentration of 0.5 mg/l . The data submitted would not allow a determination of the acceptability of the wastes at Forward Landfill , where "designated" waste levels are defined for lead. If Anlab had run a test to determine total lead concentrations in the foam insulation, we would know if any lead is present. Can you tell us how lead enters the manufacturing process and becomes part of the Celotex product? Perhaps if we understood the origin of the lead wastes we could assist you in determining the threat to water quality from Celotex wastes. In any event, the leachable lead level in the wastes must be compared to environmental factors at the Corral Hollow site including geology and depth to ground water. Once this is done, attenuation factors may be developed in order to determine if leachable lead is a threat to ground 'Fater quality. Beneficial uses of ground water at the Corral Hollow site include domestic and agricultural uses. The "designated" waste analysis, which we were under the impression that Celotex would perform, must demonstrate that the attenuated leachate will not impair the most sensitive beneficial use for ground water. A recent FAX from Celotex, dated 2 October 1990, states "Celotex will perform the 'designated' waste analysis and then submit the proposed 'designated' levels for Regional Board review, . . . " The submittal we received on 8 October 1990 does not include a determination of "designated" levels for the Corral Hollow Landfill . It appears that the Regional Board's "Designated Level Methodology" and "Water Quality Goals" documents would be useful in determining designated waste levels for the Corral Hollow Landfill . Both of these documents can be purchased for $30. It is not mandatory that you use the "Designated Level Methodology" to