Appendix C
List of Public Access Materials Received by the NRC Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste

  1. Letter to Jesse Huff, Department of Toxic Substances Control from Jeff Sickenger, Western States Petroleum Association, Brian E. White, California Chamber of Commerce, Stephen P. Piatek, Western Independent Refiners Association, Jot Condie California Manufacturers Association, and Robert W. Lucas, California Council for Environment and Economic Balance. Re: Waste Classification (April 30, 1998, 22 pp).
  2. Letter to Jan Radimsky, California Department of Toxic Substances Control from Thomas J. LeBrun, County Sanitation Districts of Los Angeles County. Re: Proposed Hazardous Waste Classification (Sept. 4, 1997, 2 pp).
  3. Four Letters to Jesse Huff, Department of Toxic Substances Control from Robert W. Lucas, California Council for Environmental and Economic Balance. Re: Hazardous Waste Characterization (Nov. 17, 1997, 10 pp) (Jan. 8, 1998, 5 pp); Arsenic (Feb. 27, 1998, 6 pp); SERTs (April 24, 1998, 7 pp).
  4. Letters to Jesse Huff, Department of Toxic Substances Control from Joseph W. Massey, Institute of Scrap Recycling Industries, Inc. Re: Waste Classification/Management (Nov. 25, 1997, 5 pp); Letter to James Carlisle, Department of Toxic Substances Control from


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--> Appendix C List of Public Access Materials Received by the NRC Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste Letter to Jesse Huff, Department of Toxic Substances Control from Jeff Sickenger, Western States Petroleum Association, Brian E. White, California Chamber of Commerce, Stephen P. Piatek, Western Independent Refiners Association, Jot Condie California Manufacturers Association, and Robert W. Lucas, California Council for Environment and Economic Balance. Re: Waste Classification (April 30, 1998, 22 pp). Letter to Jan Radimsky, California Department of Toxic Substances Control from Thomas J. LeBrun, County Sanitation Districts of Los Angeles County. Re: Proposed Hazardous Waste Classification (Sept. 4, 1997, 2 pp). Four Letters to Jesse Huff, Department of Toxic Substances Control from Robert W. Lucas, California Council for Environmental and Economic Balance. Re: Hazardous Waste Characterization (Nov. 17, 1997, 10 pp) (Jan. 8, 1998, 5 pp); Arsenic (Feb. 27, 1998, 6 pp); SERTs (April 24, 1998, 7 pp). Letters to Jesse Huff, Department of Toxic Substances Control from Joseph W. Massey, Institute of Scrap Recycling Industries, Inc. Re: Waste Classification/Management (Nov. 25, 1997, 5 pp); Letter to James Carlisle, Department of Toxic Substances Control from

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--> Joseph W. Massey, Institute of Scrap Recycling Industries, Inc. Re: Regulatory Structure Update, Draft Concept paper RSU Task D.3, California's Non-RCRA Waste Classification System, Analysis and Proposed Revisions Dated Feb. 12, 1997 (Mar. 26, 1997, 4 pp); Letter to California Environmental Protection Agency from Jeffrey P. Neu, Hugo Neu-Proler Company. Re: Regulatory Improvement Initiative with attachments (Dec. 6, 1995, 16 pp). Letter to Jesse Huff, Department of Toxic Substances Control from David McKinley, Industrial Environmental Association. Re: DTSC RSU Waste Classification Proposal (Nov. 21, 1997, 2 pp). Four letters to Jesse Huff, Department of Toxic Substances Control from June Christman, Western Independent Refiners Association. Re: Response to Your July 28, 1998 Letter, RSU Task B.I.5 Discharges to Publicly Owned Treatment Works (Aug. 13, 1998, 6 pp); RSU - Limited Domestic Sewage Exclusion (May 18, 1998, 3 pp); Regulatory Structure Update (RSU) Waste Characterization (Mar. 10, 1998, 3 pp); RSU - Hazardous Waste Characterization Proposal and Limited Domestic Sewage Exclusion (Jan. 28, 1998, 4 pp). Letter to Jesse Huff, Department of Toxic Substances Control from V. Z. Froman, Department of the Navy, Commander Naval Base. (June 9, 1998, 1 p). Letter to Jesse Huff, Department of Toxic Substances Control from Jeff Sickenger, Western State Petroleum Association. Re: Waste Classification (Nov. 19, 1997, 3 pp, with 5 attachments). Risk-Based Criteria for Non-RCRA Hazardous Waste: A Report to the National Research Council Introducing Proposed Changes to the Definition of Hazardous Waste in the California Code of Regulations [prepared by Human and Ecological Risk Division and Hazardous Materials Laboratory of the Science, Pollution Prevention, and Technology Program, Department of Toxic Substances Control, Environmental Protection Agency, State of California. Feb. 27, 1998, 1494 pp.]. Cal/EPA DTSC also provided the following materials to the committee: (a)   The DTSC Waste Classification Proposal Summary & Highlights [Robert Stephens, Deputy Director, California Environmental Protection Agency, Department of Toxic Substances Control, Sept. 10, 1998, 34 pp]. (b)   Assembly Bill No. 2784 [Robert Stephens, Deputy Director, California Environmental Protection Agency, Department of Toxic Substances Control, 13 pp].

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--> (c)   Final Draft Reports. Intermedia Transfer Factors for Contaminants Found at Hazardous Waste Sites: Vinyl Chloride (VC) [40 pp], Trichloroethylene (TCE) [45 pp], and 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) [44 pp]. (d)   Additional and Replacement Information: CalTOX Technical Reports, modifications to create version 2.3, chemical parameters for TCE, TCDD, and VC (1-p memorandum and disk) [Ned Butler, DTSC Staff Toxicologist, Cal/EPA]. (e)   A Risk-Based Regulatory System: Revision of California Non-Resource Conservation and Recovery Act (RCRA) Waste Classification Regulation. DTSC, obtained from web site http://www/calepa.ca.gov/dtsc/rsu/hwtr0623.pdf [58 pp]. (f)   Introduction to Regulatory Structure Update and List of Tasks, includes Draft Concept Papers for Tasks D.1, D.2, D.3, and D.4, State of California, Environmental Protection Agency, Department of Toxic Substances Control, April 10, 1997; Unified Program: Questions and Answers, Unified Hazardous Waste and Hazardous Management Regulatory Program, Mar. 28, 1997 [48 pp]. Risk Assessment Strategy for the Hazardous Waste Identification Rule (HWIR) [Barnes Johnson, Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency, Washington, DC, 7 pp]. The following materials were received from the Toxics Assessment Group in support of Jane Williams of the California Communities Against Toxics: (a)   Letter to Members, Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste from Jody Sparks, Toxics Assessment Group; Jane Williams, California Communities Against Toxics, Gary Patton, Planning and Conservation League, Caryn Woodhouse, Taylor Bay Associates, and Bonnie Holmes-Gen, Sierra Club, dated Sept. 10, 1998, 9 pp]. (b)   Comments on the Draft Concept Paper (Task D4): Preliminary Proposal to Require the Federal Toxicity Leaching Procedure (TCLP) in lieu of the Waste Extraction Test (WET) [letter from Caryn Woodhouse, Taylor Bay Associates, to Dr. James Carlisle, DTSC, dated Jan. 2, 1996, 10 pp]. (c)   Comments on the Draft Concept Paper (Task D1 and D3): Evaluation of RCRA Listed Wastes and the RCRA Toxicity Characteristic [letter from Jody Sparks, Toxics Assessment

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--> Group and Caryn Woodhouse, Taylor Bay Associates, to Dr. James Carlisle, DTSC, dated Feb. 8, 1996, 10 pp]. (d)   Comments on the Regulatory Structure Update Program [letter from Jody Sparks, Toxics Assessment Group, to Jesse Huff, DTSC, dated Mar. 13, 1996, 4 pp]. (e)   Adequacy of DTSC Response to RSU: Comments in Jan. 16, 1996 Memorandum [letter from Jody Sparks, Toxics Assessment Group and Caryn Woodhouse, Taylor Bay Associates, to Dr. James Carlisle, DTSC, dated April 1, 1996, 19 pp]. (f)   Comments on the Draft Concept Paper, RSU Task #C.3: Soils: natural Contamination, Petroleum Contamination, Replacement [letter from Jody Sparks, Toxics Assessment Group and Caryn Woodhouse, Taylor Bay Associates to Jan Radimsky, DTSC, dated May 2, 1996, 6 pp]. (g)   Comments on the Regulatory Structure Update program: Laboratory Comparison Study [letter from Bonnie Holmes-Gen, Sierra Club, Jody Sparks, Toxics Assessment Group, Gary Patton, Planning and Conservation League, and Jane Williams, California Communities Against Toxics, to Robert Stephens, DTSC, dated June 20, 1996, 4 pp]. (h)   Comments on the Draft Concept Paper, RSU Task #D.3: Evaluation of California's non-RCRA Hazardous Waste System, Part A: STLCs and Protection of Water Resources, Aug. 17, 1996 [letter from Jody Sparks, TAG and Caryn Woodhouse, Taylor Bay Associates, to Jan Radimsky and Jim Carlisle, DTSC, dated Sept. 9, 1996, 6 pp]. (i)   Comments on the Draft Concept Paper, RSU Task #D.4: Extraction Test and the RSU Extraction Test Report by Hazardous Materials Laboratory [letter from Jody Sparks, TAG and Caryn Woodhouse, Taylor Bay Associates, to Jan Radimsky and Jim Carlisle, DTSC, dated Sept. 9, 1996, 15 pp]. (j)   AB 1220 Regulations - Impact of Deregulated Hazardous Wastes [letter from Jody Sparks, Toxics Assessment Group and Caryn Woodhouse, Taylor Bay Associates, to Members of the Integrated Waste Management Board and Members of the of the State Water Resources Control Board, dated Sept. 11, 1996, 3 pp]. (k)   Phase II RSU Extraction Test Project [letter from Jody Sparks, Toxics Assessment Group, Jane Williams, California Communities Against Toxics, Stephen Johnson, HEWM, and Caryn

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--> Woodhouse, Taylor Bay Associates, to Robert Stephens, DTSC, dated Oct. 25, 1996, 8 pp]. (l)   Phase II RSU Extraction Test Project [letter from Jody Sparks, Toxics Assessment Group, to Robert Stephens, DTSC, dated Dec. 12, 1996, 2 pp]. (m)   Comments on the Draft Concept Paper, RSU Task #D.3: California's non-RCRA Hazardous Waste System - Analysis and Proposed Revisions [letter from Jody Sparks, Toxics Assessment Group and Caryn Woodhouse, Taylor Bay Associates, to Jan Radimsky and Jim Carlisle, DTSC, dated April 3, 1997, 17 pp]. Waste Classification [Michael Lakin, ICF Kaiser, representing the Western States petroleum Association, California Chamber of Commerce, Council for Economic and Environmental Balance, California Manufacturers Association, Western Independent Refiners Association, 25 pp]. (a)   Proposed Presentation on Waste Classification (unabridged) [Michael Lakin, ICF Kaiser, 50 pp]. (a)   Discharges to POTWs [Linda M. Shadler, Supervising Civil Engineer, County Sanitation Districts of Los Angeles County, 4 pp]. (b)   Selenium Chemistry in POTWs [Brent C. Perry, Project Engineer, County Sanitation Districts of Los Angeles County, Aug. 3, 1998, 4 pp]. Reference Materials for National Academy of Sciences Public Meeting, NRC Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste [Charles A. White, Director of Regulatory Affairs, Waste Management, Sacramento, CA, 5 pp]. Review of Cal/EPA's proposed "Risk-Based Criteria for Non-RCRA Hazardous Wastes" [Paul W. Abernathy, Consultant to Mercury Technologies International/Advanced Environmental Recycling Corporation, Hayward, CA, 7 pp]. Comments submitted by Victor Hanna, representing the City of Los Angeles, Bureau of Sanitation, to NAS committee on Sept. 10, 1998, 1 p. Waste Classification - Focus on Real Risk [letter from Brian E. White, Air & Waste Management, California Chamber of Commerce, to Jesse Huff, Director, DTSC, dated Mar. 9, 1998, 4 pp]. Comments on Draft Concept Paper for RSU Task D-3 [letter from Michelle Corash, Morrison & Foerster, dated May 1, 1997; cover letter from Brooke Ashworth, Environmental Analyst, Morrison &

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--> Foerster, to Roberta Wedge, NRC, dated Sept. 2, 1998, 7 pp]. Waste Deregulation [e-mail from David D. Miller, Vice President, California Association of Professional Scientists to Roberta Wedge, NRC, dated Sept. 9, 1998, 1 p]. Reclassifying Hazardous Waste [e-mail from Christopher J. Voight, Staff Consultant, California Association of Professional Scientists to Roberta Wedge, NRC, dated Sept. 9, 1998, 1 p]. Risk Assessment - A Science Based Approach. A Symposium (transcript of symposium, roster, and program). Held by Southern California Coalition for Pollution Prevention and the California Environmental Protection Agency, Department of Toxic Substances Control, May 16, 1997 [cover letter from Christopher Campbell, Executive Director, Southern California Coalition for Pollution Prevention to Roberta Wedge, NRC, Sept. 15, 1998, 202 pp]. Bolger, P.M., Carrington, C.D., Capar, S.G., and Adams, M.A. Undated. Reductions in Dietary Lead Exposure in the United States. U.S. Food and Drug Administration, Division of Toxicological Review and Evaluation, Division of Contaminants Chemistry and Division of Food Chemistry and Technology. 26 pp. Provisional Tolerable Exposure Levels for Lead [memo from Contaminants Team, Division of Toxicological Review and Evaluation, Department of health and Human Services, to Elizabeth Campbell, Division of Regulatory Guidance, dated Nov. 16, 1990, 10 pp]. Chaney, R.L., Mielke, H.W., and Sterrett, S.B. 1988. Speciation, Mobility, and Bioavailability of Soil Lead. Submitted to Environ. Geochem. Health. 23 pp. California Non-RCRA Hazardous Waste Classification Proposal [comments from Jon B. Marshack, California Regional Water Quality Control Board, Central Valley Region, to Roberta Wedge, NRC, dated Oct. 7, 1998, 8 pp]. Chaney, R.L., Sterrett, S.B., and Mielke, H.W. 1984. The potential for heavy metal exposure from urban gardens and soils. Pp. 37–84 in Proceedings of the Symposium on Heavy Metals in Urban Gardens, J.R. Preer, ed. Agricultural Experiment Station, University of the District of Columbia, Washington. Comments for NRC Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste [letter from Gordon E. Hart, of Paul, Hastings, Janofsky & Walker LLP, to Roberta Wedge, NRC, dated Oct. 9, 1998, 5 pp]. Department of Toxic Substances Control Responses to 86 Questions

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--> from the NRC Committee on Risk-Based Criteria for Non-RCRA Hazardous Waste, dated Oct. 9, 1998. 45 pp plus 7 attachments. Risk-Based Criteria for Non-RCRA Hazardous Waste, BEST-K-98-03-A, 10 Micron Exclusion [letter from Paul Neil, RTP Environmental Associates, Inc., to Roberta Wedge, NRC, dated Oct. 2, 1998, 2 pp]. Comments on Department of Toxic Substances Control: California Non-RCRA Hazardous Waste Classification Proposal [letter from Denis L. Brown, Texaco North American Production, to Roberta Wedge, NRC, dated Nov. 18, 1998, 2 pp]. Comments on Regulatory Structure Update [letter from Mark Posson, Lockheed Martin Corporation, to Peter M. Rooney, secretary for environmental protection, Cal/EPA, dated Oct. 9, 1998, 3 pp]. Comments on DTSC Hazardous Waste Classification System [from Jeff Sickenger, Western States Petroleum Association, Nov. 13, 1998, 70 pp]. Department of Toxic Substances Control Supplemental Questions and Answers (pertaining to extraction test methodology) [from DTSC Cal/EPA, dated Nov. 19, 1998, 2 pp]. There Are Two Basic Requirements for Hazardous Waste (HW): Management and Disposal [overheads for presentation by Michael Lakin, ICF Kaiser, Nov. 20, 1998, 12 pp]. Scenarios, Benefits and Costs [overheads for presentation by Kirk T. Larson, representing San Diego Industrial Environmental Association, Nov. 20, 1998, 11 pp]. SCE Comments to NAS Public Meeting on RSU Waste Characterization Project [comments from David Kay, Southern California Edison Co., Nov. 20, 1998, 2 pp]. Proposed California Waste Classification System [letter from Charles A. White, Waste Management, to Peter Rooney, secretary for environmental protection, Cal/EPA, dated Oct. 7, 1998, 37 pp]. Department of Toxic Substances Control Review Questions and Answers [letter and attachment from Robert Stephens, DTSC, Cal/EPA, to Rogene Henderson, chair, NRC committee, undated, 3 pp]. Silicon Valley Manufacturing Group comments to NRC committee [letter from Chris Elias, Silicon Valley Manufacturing Group to Roberta Wedge, NRC, dated Dec. 10, 1998, 8 pp]. Non-RCRA Hazardous Waste Criteria for Contaminated Soils and Soil Amendments [letter and attachment from Robert Stephens,

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--> DTSC, Cal/EPA, to Rogene Henderson, chair, NRC committee, and Roberta Wedge, NRC staff, dated Dec. 30, 1998, 2 pp, and letter response from Rogene Henderson to Robert Stephens, dated Jan. 22, 1999, 1 p]. Waste Classification - NAS Review [comments from A.S. Chater, Hugo Neu-Proler Company to Rogene Henderson, chair, NRC committee, e-mail dated Feb. 2, 1999, 2 pp]. Minor issues of clarification [questions from Roberta Wedge, NRC staff to Ned Butler, DTSC, and response from DTSC, dated Jan. 26, 1999, 2 pp].

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