ILLINOIS POLLUTION CONTROL BOARD
    December 14,
    1994
    IN THE MATTER OF:
    )
    )
    PETITION OF KEYSTONE STEEL
    )
    AS 93-7
    AND
    WIRE
    COMPANY
    FOR ADJUSTED
    )
    (Adjusted Standard)
    STANDARD FROM HAZARDOUS WASTE
    )
    FROM SPECIFIC SOURCES,
    35 ILL.)
    ADM. CODE 721.132
    )
    SUPPLEMENTAL OPINION
    AND
    ORDER OF THE
    BOARD
    (by E. Dunham):
    On October 24,
    1994, Keystone Steel and Wire Company
    (Keystone)
    filed a “Motion for Modification”.
    Keystone requests
    modification of the Board’s March 17,
    1994 order which granted
    Keystone a RCRA delisting adjusted standard for its facility in
    Bartonville, Illinois.
    Keystone is requesting that the adjusted
    standard be extended to include an additional site at the
    facility.
    On November 2, 1994, the Illinois Environmental
    Protection Agency (Agency) filed a response to the motion stating
    that it has no objection to the granting of the motion.
    On
    November 3,
    1994, the Board issued an order requiring Keystone to
    supply additional information in support of its motion.
    Keystone
    filed additional information with the Board on November 21,
    1994.
    On November 28,
    1994, the Agency filed a response to Keystone’s
    submittal of additional information, restating it has no
    objection to the modification.
    Keystone seeks modification of the adjusted standard due to
    the discovery of additional contaminated soil during the
    construction phase of the reinediation process.
    The newly
    discovered contaminated soil is located near the southeast corner
    of the planned staging pad area and is referred to as the
    “Staging Area Waste Pile”.
    The contaminated soils
    in the new
    area are similar in color, texture, and total metal
    concentrations to the K—062 listed hazardous waste sediments
    included in the adjusted standard.
    The concentrations of
    cadmium, chromium, lead and zinc are also similar.
    Lead is the
    predominate contaminate in the waste and is comparable to the
    concentration of lead found at other sites.
    The concentration of
    the waste differs in the amount of slag,
    rubble, railroad ballast
    and native soils mixed within the K—062 sediments.
    Keystone
    maintains that the contaminated material can successfully be
    treated under the same treatment method and standards provided in
    the adjusted standard.
    The contaminated soil in the staging area
    is estimated to be approximately 2,560 cubic yards covering an
    area approximately 29,200 square feet.
    In granting the adjusted standard delisting the waste, the
    Board found that Keystone demonstrated that the treated sediment
    does not exhibit the toxicity characteristic for which U.S. EPA
    listed K062 wastes and that there is no other reasonable basis
    that warrants retaining the treated sediment as RCRA hazardous

    2
    waste.
    (See 35 Ill.
    Adin. Code 720.122(a)
    and
    (d),
    721.111(a) (3),
    721.131, and 721.Appendix C.)
    Additionally, the Board found that
    Keystone demonstrated that the waste will be generated or managed
    in Illinois (35 Ill. Adm. Code 720.122(p)), and the adjusted
    standard was consistent with the federal RCRA program.
    (35 Ill.
    Adm. Code 720.122(q).)
    The Board finds that Keystone has demonstrated that the
    newly discovered waste are from the same or similar source and of
    characteristics similar to the wastes that are included in the
    original adjusted standard so that the same treatment method will
    be effective to achieve the standards originally adopted and
    herein made applicable to the waste in the new area.
    Finally,
    the Board finds that requiring a new adjusted standard procedure
    for the newly discovered waste is not necessary and would hinder
    the remediation at the site.
    The Board hereby grants Keystone’s motion for modification
    and adds the newly discovered site to the adjusted standard.
    To
    avoid confusion,
    the Board will reproduce the entire adjusted
    standard order with the modifications in this supplemental
    opinion and order.
    The order adds the Staging Area to paragraph
    1 of the adjusted standard.
    This supplemental opinion constitutes the Board’s
    supplemental findings of fact and conclusions of law in this
    matter.
    ORDER
    Pursuant to the authority of S’ection 28.1 of the
    Environmental Protection Act (415 ILCS 5/28.1
    (1992)), the Board
    hereby grants a RCRA delisting adjusted standard to Keystone Wire
    and Steel for the treated sediment from its Bartonville facility.
    The adjusted standard as modified is effective on the date of
    this order and is subject to the following conditions:
    1.
    Performance testing of the lime stabilization/Portland
    cement solidification process of the sediments located
    in the North Ditch, Mid—Mill Ditch,
    South Ditch-North
    Half,
    South Ditch-South Half,
    Surface Drainage Ditch,
    North Dredge Pile,
    South Dredge Pile, Lower South Ditch
    and the Staging Area:
    (Performance testing of the
    Retention Reservoir treatment project has already been
    documented.)
    The alkalinity of the sediment will be tested in each
    treatment cell following the initial mixing of
    quicklime and Portland cement.
    A treatment cell shall
    be no larger than 100 cubic yards in volume.
    Treatment
    will be considered acceptable if the alkalinity is
    within the range of 130,000 mg/kg to 192,000 mg/kg.

    3
    Where the measured alkalinity is within the range of
    115,000 mg/kg to 130,000 mg/kg or 192,000 mg/kg to
    215,000 mg/kg, the sample also will be analyzed for
    TCLP lead.
    Sample where TCLP analysis is performed
    will be considered passing if the TCLP value for lead
    does not exceed 0.246 mg/i.
    2.
    Verification testing of the tested sediments located in
    the Retention reservoir and all of the other waste
    management units.
    Verification testing will consist of
    sampling roll—off or other containers a minimum of 20
    cubic yards in size (“containers”)
    of the treated
    sediment during the removal of the sediments
    from the
    waste management units.
    The sampling frequency shall
    be as follows:
    a)
    For Day
    1 of treated sediment excavation and
    removal, every container will be sampled with
    a
    minimum of sixty
    (60) containers being sampled on
    Day
    1, the Day 1 sampling frequency shall carry
    over into succeeding days until sixty
    (60)
    containers have been sampled.
    Each sample will be
    analyzed for alkalinity.
    Every third sample in
    addition will be analyzed for TCLP cadmium,
    chromium,
    lead and zinc.
    b)
    After Day
    1, but not before sixty
    (60) containers
    have been sampled, every tenth container will be
    sampled.
    Each sample will be analyzed for
    alkalinity.
    Every second sample in addition will
    be analyzed for TCLP cadmium, chromium,
    lead and
    zinc.
    C)
    Samples where only alkalinity is measured will be
    considered passing if the alkalinity is within the
    range of 130,000 mg/kg to 192,000 mg/kg.
    Samples
    where only alkalinity is measured and where the
    alkalinity is within the range of 115,000 mg/kg to
    130,000 mg/kg or 192,000 mg/kg to 215,000 mg/kg
    will then be subject to TCLP analysis for cadmium,
    chromium lead and zinc.
    Samples where TCLP
    analysis is performed will be considered passing
    if the TCLP values are less than the delisting
    values as follows:
    ANALYTE
    TCLP
    LEVEL
    Cadmium
    0.082 mg/i
    Chromium
    1.64
    mg/i
    Lead
    0.246 mg/i
    Zinc
    115
    mg/i

    4
    d)
    The sediments
    in all containers where the
    alkalinity lies outside the range of 115,000 mg/kg
    to 215,000 mg/kg, and the TCLP values exceed the
    levels given in item
    (c) will be retreated and
    resampled.
    e)
    Following Day 1,
    if any sample fails to meet the
    criteria outlined in
    (c), the subsequent sampling
    frequency for containers will revert to Day
    1
    sampling schedule.
    IT IS SO ORDERED.
    Section 41 of the Environmental Protection Act,
    (415 ILCS
    5/41
    (1992)), provides for appeal of final orders of the Board
    within 35 days of the date of service of this order.
    The Rules
    of the Supreme Court of Illinois establish filing requirements.
    (See also 35 Ill. Adm. Code 101.246, Motion for Reconsideration.)
    I, Dorothy N.
    Gunn, Clerk of the Illinois Pollution Control
    Board,
    hereby certify that the above supplemental opinion and
    order was adopted on the
    /~-~-
    day of
    ~-~-._•~‘
    1994, by a vote of
    ~
    A-
    Dorothy M./fGunn, Clerk
    Illinois ~j6llutionControl Board

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