BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
)
RCRA DELISTING ADJUSTED STANDARD )
?
STATE OF ILLINOIS
PETITION OF PEORIA DISPOSAL COMPANY) AS 08-10
(Adjusted
?
Standard
PolluloariSpntrol
B
oard
)?
(RCRA Delisting)
RESPONSE OF PEORIA DISPOSAL COMPANY TO
ATTACHMENT A TO THE HEARING OFFICER ORDER
ENTERED ON JULY 15,2008
NOW COMES Peoria Disposal Company ("PDC"), by its attorneys, Elias, Meginnes,
Riffle & Seghetti, P.C. and Brown, Hay & Stephens, LLP, and as and for its response to the
questions listed in Attachment A to the Hearing Officer Order entered on July 15, 2008, relating
to the RCRA Delisting Adjusted Standard Petition (the "Petition"), served pursuant to the
Hearing Officer Order entered on June 17, 2008, states as follows:
On July 15, 2008, the Pollution Control Board asked PDC to address issues raised in
Attachment A to the Hearing Officer Order entered on such date. Attached herewith as Exhibit
A is a document responding to Attachment A to the Hearing Officer Order entered on July 15,
2008, prepared by RMT, Inc., the consultant that prepared the Technical Support Document
(Exhibit 2 to the Petition). Exhibit A (with the attachments thereto) is incorporated herein as
and for the Response of PDC to the questions listed in Attachment A to the Hearing Officer
Order entered on July 15, 2008.
THIS FILING IS ON RECYCLED PAPER AS REQUIRED BY 35 ILL. ADM. CODE 101.202 AND 101.302(g).
"e0EIV
CLERK'S
OFFICE
ED
AUG 0 7 2008
ne of its attorneys
Respectfully submitted,
PEORIA DISPOSAL COMPANY,
Petitioner
By:
Dated: August 6, 2008
Claire A. Manning, Esq.
BROWN, HAY & STEPHENS,
LLP
205 S. Fifth Street
Suite 700
Springfield, Illinois 62701
Telephone: (217) 544-8491
Facsimile: (217) 544-9609
Email: cmanning@bhslaw.com
908-0656
Brian J. Meginnes, Esq.
Janaki Nair, Esq.
ELIAS, MEGINNES, RIFFLE & SEGHETTI,
P.C.
416 Main Street, Suite 1400
Peoria, Illinois 61602
Telephone: (309) 637-6000
Facsimile: (309) 637-8514
Emails: bmeginnes@emrslaw.com
jnair@emrslaw.com
2
THIS FILING IS ON RECYCLED PAPER AS REQUIRED BY 35 ILL. ADM. CODE 101.202 AND 101.302(g).
EXHIBIT
A
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
RCRA DELISTING ADJUSTED STANDARD
?
) AS 08-10
PETITION OF PEORIA DISPOSAL COMPANY ) (Adjusted Standard – Land)
)?
(RCRA Delisting)
TECHNICAL RESPONSES TO ATTACHMENT A
TO THE HEARING OFFICER ORDER ENTERED ON JULY 15, 2008
1.
Please describe any treatment operating guidelines Peoria Disposal Company (PDC) has
concerning curing times based on weather conditions.
PDC currently has no treatment operating guidelines concerning curing times based on
Weather conditions. Special condition X (E)(14)(e)(iv) of PDC's operating Permit, RCRA
Part B Permit Log No. B-24R (Part B), requires that: "At a minimum, for all wastes, unless
each container (roll-off box) is sampled separately, the treated batch must receive the same
amount of curing time as the sample that demonstrates compliance with the LDR
standard during the bench study of the waste." This condition ensures that field curing
time is at least that amount proven successful as part of the laboratory treatability study.
Part B special condition X (E)(14)(e)(ii) requires, in pertinent part, that "...a minimum of
two samples must always be analyzed to demonstrate compliance." This condition
requires a laboratory analysis that effectively demonstrates that no individual variable,
including but not limited to reagent proportions, process controls, mixing effort, curing
time, and/or weather conditions resulted in inadequate treatment. Proposed condition
3(b) of the Petition will likewise require that each treated batch be analyzed. Analyzing
each treated batch is an extremely rigorous quality control measure that will verify the
satisfactory control of all contributing process variables, including weather conditions.
The referenced Part B conditions are included herewith as Attachment 1.
2.
Please explain PDC's position on whether its shipments of electric arc furnace dust
stabilization residue (EAFDSR) that meet delisting levels would be subject to the Board's
"special waste" regulations, including manifesting requirements (35 Ill. Adm. Code
808,809).
It is PDC's position that EAFDSR meeting the delisting levels could be managed as an
Illinois "non-special waste." This position regarding the regulatory definition of delisted
wastes was so stated to the Illinois Environmental Protection Agency (IEPA) in a request-
for-guidance letter dated January 3, 2008. hi its response letter dated May 13, 2008, the
Page 1
IEPA agreed with PDC's position that successfully delisted waste may be managed as an
Illinois "non-special waste." Both letters are provided herewith as Attachment 2.
Non-special wastes are not subject to the manifesting requirements. That
notwithstanding, PDC maintains an extensive electronic database of all non-special wastes
shipped and received by its facilities, and requires bills of lading as hard-copy tracking
documents for each shipment. These documents become part of the facility operating
record and are available for and subject to IEPA inspection. It should also be noted that
copies of non-hazardous waste manifests, including those representing special wastes, are
no longer distributed to the IEPA.
3.
Please comment on the appropriateness of including a condition in the adjusted standard
language requiring that PDC, before transporting an initial load of delisted EAFDSR to a
given disposal facility, provide the Illinois Environmental Protection Agency (IEPA) with
a one-time written notification identifying that disposal facility. How many days before
transporting those initial loads to the respective disposal facilities can PDC reasonably
provide such notification?
PDC-would not object if the Board included such a condition in the adjusted standard.
Presumably, such a condition would be intended only to provide the IEPA with a record
of each disposal facility to which EAFDSR was shipped, and not for review and pre-
approval of proposed receiving facilities. As such, PDC believes that any such condition
should require notification no more than 15 days in advance of the first shipment. PDC
proposes the following language for the adjusted standard:
"PDC, at least 15 calendar days before transporting an initial load of delisted EAFDSR to a
given disposal facility, shall provide the Illinois Environmental Protection Agency (IEPA)
with a one-time, written notification identifying that disposal facility. The notification
submittal shall be addressed as specified in condition 5."
4.
Please comment on the appropriateness of requiring PDC to provide IEPA with written
notice of any "significant change" and the results of the bench-scale treatability testing
prior to operating full-scale treatment using the new chemical regimen.
a)
PDC's petition states that "significant change" would "mean the utilization of a
chemical treatment regimen containing different active ingredients." Petition at 18.
Please explain whether this definition of "significant change" should be a part of the
adjusted standard conditions.
b)
PDC has provided a "Reagent Constituent of Concern Evaluation" in its petition for
the current recipe. Please comment on how verification under proposed condition 3(b)
would ensure evaluation of potential constituents of concern (COCs) when changing
the chemicals used by PDC in the treatment process.
Page 2
Although PDC believes it would be equally appropriate and effective to maintain the
subject information as part of its operating record subject to IEPA inspection, PDC would
not object to a condition requiring notice to the IEPA of any significant change and the
results of the bench-scale treatability testing prior to operating full-scale treatment using
the new chemical regimen. Presumably, such a condition would be intended only to
provide the IEPA with a record of the technology modification demonstration and
treatability testing, and not for review and pre-approval of the demonstration. As such,
PDC believes that any such condition should require notification no more than 15 days in
advance of adopting the modification in the full-scale treatment process.
PDC believes it would be appropriate to define significant change as part of the adjusted
standard conditions.
Chemicals that PDC purchases as treatment reagents are of known and documented
chemical composition. To the extent possible, PDC would evaluate each chemical for its
potential to contribute COCs using MSDS sheets, product specification sheets, supplier
process knowledge, and/or laboratory analytical data provided by the chemical supplier,
all of which are typically available and provided. In the event that the absence of COCs
could not be verified by those means, PDC would arrange for laboratory analysis of a
representative sample for any constituents reasonably expected to be present at a
concentration of concern. This would be similar to the existing regulations that allow
generator knowledge to be used in evaluation of a decharacterized hazardous waste for
the presence of underlying hazardous constituents (35 M. Adm. Code 728.102). This
requirement would also be similar to the Part B condition regarding known-composition
waste products. Specifically, special condition X.(G)(6)(e)(5) (provided herewith as
Attachment 3) allows that: "Off-specification, unused or discarded commercial chemical
products may use a MSDS to determine the hazardous constituents present and
appropriate USEPA hazardous waste class, if applicable, in lieu of analytical results."
PDC proposes that the following language be added to proposed condition 3(b)of the
RCRA Delisting Adjusted Standard Petition of Peoria Disposal Company (Petition):
***
"Prior to adopting any significant change in treatment chemicals as part of the full-scale
treatment process, PDC shall evaluate each new chemical or chemical treatment regimen
for the presence of potential constituents of concern (COCs). The evaluation shall include,
but not be limited to the consideration of producer knowledge, MSDS sheets, producer
specification sheets, and/or producer- or PDC-supplied analytical data, as necessary to
identify any potential COCs reasonably expected to be present at concentrations of
concern in the EAFDSR resulting from a new chemical treatment regimen. The universe
of potential COCs that must be considered is the same as that considered for the Petition.
To eliminate a constituent from further evaluation, the concentration must be no greater
than the screening concentrations determined and modeled for the Petition as they appear
Page 3
in Tables 3a, 3b, 3c, and 8 of the Technical Support Document for the RCRA Delisting
Adjusted Standard Petition for PDC EAF Dust Stabilized Residue (TSD), which was
included with the Petition as Attachment 2. If the concentration of a potential COC in the
EAFSDR resulting from the proposed chemical treatment regimen is determined to be
greater than that analyte's screening concentration, or for any constituents detected but
not present on the previously referenced tables, PDC shall conduct a further evaluation,
which may include running the then-approved version of the DRAS model (or other
appropriate model or risk assessment method) with the inputs reflecting the EAFDSR
concentrations as treated with the proposed chemical. PDC may proceed with the change
in treatment chemical or chemical treatment regimen as part of the full-scale treatment
process only if the evaluation demonstrates that the treated EAFDSR does not exceed the
target human health and environment risk factors upon which the approved Petition is
based (see Section 6.3.2 of the TSD).
PDC, at least 15 days before adopting any significant change in the full-scale treatment
process, shall submit a report of the technology modification demonstration and bench-
scale treatability testing to the IEPA, addressed as specified in condition 5. The Board
recognizes that insofar as the submittal contains confidential business information (CBI)
regarding a specific proprietary chemical or chemical treatment regimen, PDC may redact
such CBI from its submittal to the IEPA.
For the purpose of this condition, significant change is defined as the utilization of any
new chemical or chemical treatment regimen containing active ingredients different from
those utilized in the full-scale, in-plant trials represented in the Petition."'
5.
Please comment on the appropriateness of including a condition in the adjusted standard
language requiring PDC to submit annually to IEPA the data (and/or a summary of the
data) collected pursuant to proposed condition 3(c). See 67 Fed. Reg. 1888, 1895 (Jan. 15,
2002) (Heritage Environmental Services, LLC delisting,
9113(4)).
Although PDC believes it would be equally appropriate and effective to maintain the
subject information as part of its operating record subject to IEPA inspection, PDC would
not object to the inclusion of such a condition. PDC estimates that the subject data would
fill a minimum of two banker's boxes per year, but would be willing to submit the data in
its entirety or any subset or summarized version to which the IEPA would agree. PDC
proposes that the following language be added to proposed condition 3(c) of the Petition:
***
"PDC shall submit annually to the IEPA the data (and/or a subset or summary thereof to
which the IEPA agrees) collected pursuant to this condition. The data submittal shall be
addressed as specified in condition 5."
Page 4
6.
Hexachlorophene, which is a 40 C.F.R. Appendix IX constituent that is not a chlorinated
pesticide or herbicide, does not appear to be in PDC's analytical results. Please address
sampling and analysis for hexachlorophene.
Hexachlorophene is an unstable compound and is difficult to accurately analyze due to its
extraction inefficiency. Because of this problem, it is TriMatrix Laboratory's policy to
perform a gas chromatography-mass spectrometry (GC/MS) mass search and report their
findings as a narrative. A statement of qualification regarding TriMatrix's approach to
this compound was included in the case narrative on page 00013 of the TriMatrix data
validation package, included as Appendix N of the Technical Support Document for the
RCRA Delisting Adjusted Standard Petition for PDC EAF Dust Stabilized Residue (TSD),
which was filed with the Board as Attachment 2 to the Petition.
A mass search is performed by looking for the primary ion in the mass spectrum for
Hexachlorophene over the entire acquisition time for the sample. Ion 196 is used for this
search. If any peaks for that ion are present, a spectral comparison is made for each peak
and compared to the known mass spectra for Hexachlorophene. If there are no matches, as
was the case for these samples, TriMatrix Laboratories adds the narrative that was
included in their Statement of Data Qualifications (presented in Appendix N of the TSD).
Since this analyte is prone to poor extraction efficiency and erratic chromatographic
behavior, TriMatrix Laboratories has not been able to establish a firm reporting limit (RL)
nor determine a Method Detection Limit (MDL). As a result, they report it as either
present or not detected in the samples. If it was detected in a sample, TriMatrix
Laboratories would quantitate Hexachlorophene the same as they would for a TIC
(tentatively identified compound) . TriMatrix Laboratories found, after doing some
research, that this analyte is not included in the 8270C Appendix IX analyte list for many
laboratories due to these recovery issues.
Therefore, as indicated on page 0013 of the laboratory's Statement of Data Qualification,
Hexachlorophene was not detected in any sample analyzed.
7. PDC's Technical Support Document (TSD) (Petition Attachment 2) refers to two federal
delistings involving chemically-treated
EAF
dust: Heritage Environmental Services, LLC
(Heritage) on January 15, 2002 and Conversion Systems, Inc. (CSI) on June 13, 1995. TSD
at 4-9. Although the TSD refers to its Appendix C for more information on these
delistings, Appendix C does not contain the relevant material. Please provide the
information referred to at 4-9 of the TSD regarding the federal delistings for Heritage and
CSI.
These two delisting documents, along with the USEPA evaluation document discussed in
Section 1.4,
RCRA Hazardous Waste Delisting: The First Twenty Years
(USEPA 2002a), were
inadvertently omitted from Appendix C of the TSD. All three documents are provided
herewith in Attachment 4.
Page 5
8.
The "EPA RCRA Delisting Program Guidance Manual for the Petitioner" dated March 23,
2000, states that "a final list of constituents can be prepared to include only the metals
and organics from the 40 CFR 261.24 Toxicity Characteristics list plus all additional
constituents that were detected in the first sample when analyzed for totals
concentrations of constituents on the initial list." Manual, Appendix H, Attachment 2.
a) PDC detected dioxins and furans in EAFDSR samples but the constituents were not
included in the final list of COCs. In an email dated 1/31/08, Todd Ramaly of the
United States Environmental Protection Agency (USEPA) Region 5 commented on
excluding dioxins and furans from the final list of COCs: "we're not sure of this
conclusion and did not yet agree that DF are no longer an issue." TSD Appendix C.
Please describe any resolution PDC may have reached with USEPA concerning
dioxins and furans not being on the final list of COCs.
PDC treated dioxins and furans as a potential COC throughout implementation of the
Sampling and Analysis Plan. As a result, PDC analyzed each of the originally planned
samples for dioxins and furans. The risk modeling of the dioxin/furan analytical
results demonstrates that dioxin and furans will not exceed typical background levels
in
-
the environment. Based on this key information, RMT concluded that dioxins and
furans were appropriately excluded from the final list of COCs.
USEPA Region 5 (USEPA-5) was instrumental in providing tools and technical
expertise in evaluating dioxins and furans for the PDC EAFDSR Delisting Petition
effort, derived from federal delisting petition experience with the DRAS model and
alternatives. In neither the 1/24/08 conference call agenda nor the 1/24/08 minutes did
PDC or RMT request USEPA-5 concurrence that dioxins and furans should not be
considered to be a COC. As noted in the agenda, one purpose of the conference call
was to "present dioxin/furan data and discuss presentation in Petition." Mr. Ramaly's
e-mail that transmitted the comments, stated: "Laura, Here are some comments on the
minutes. Minor really ... some stuff I don't think was rigorously covered so I'm
suggesting we take it out." Mr. Ramaly and Ms. Laura Curtis of RMT discussed the
strike out and comment in a telephone call later on 1/31/08. Ms. Curtis stated it was
PDC's intent to present this information in order to move discussions forward on the
technical issues regarding the Excel file of the DRAS risk model that USEPA-5
provided in an email on January 14, 2008 and suggested she would insert the phrase,
"PDC reported..." into the sentence with the questioned phrase in order to clarify this
position. Mr. Ramaly indicated that he was satisfied with that addition.
In Mr. Ramaly's comments in the USEPA e-mail dated 1/31/08, he acknowledged the
1/24/08 minutes summary statement that USEPA-5 has not formally commented on
Illinois Delisting Petitions, though they are copied on the filing. Mr. Mark Crites of the
IEPA commented that although USEPA-5 does not formally submit comments, they
have in the past made informal communications to IEPA, and that the IEPA considers
Page 6
these communications while conducting their review of the Petition and while
preparing their comments to the IPCB regarding the Petition. It is our understanding
that this process occurred during the IEPA's review of the subject Petition.
In their "Response to RCRA Delisting Adjusted Standard Petition" (filed June 12,
2008), the IEPA had a number of specific, detailed comments regarding the risk
modeling that was conducted for dioxins and furans. Nowhere in their comments did
the IEPA question the conclusion that dioxins and furans should not be considered a
COC, although we suppose that IEPA concurrence would be contingent upon PDC's
responses to the risk modeling questions. PDC filed its responses to the IEPA's
comments with the IPCB on June 26, 2008. PDC's filing directly responded to all
comments included in the IEPA's June 12, 2008 filing.
In summary, Mr. Ramaly's note on the draft meeting minutes was merely an informal
comment and concurrence by all parties was neither an objective of the agenda nor an
outcome of the conference call. Therefore, there are no unresolved issues or conflicts
between USEPA-5 and PDC regarding dioxins and furans being excluded from the
final list of COCs.
b) Bis(2-ethylhexyl)phthalate was detected above both the Method Detection Limit
(MDL) and the Estimated Quantitation Limit (EQL), but was not included in the final
list of COCs. Although semivolatile organic compounds (SVOCs) are discussed
generally in the TSD at 4-6, there is no specific reference to bis(2-ethylhexyl)phthalate.
Please explain why bis(2-ethylhexyl)phthalate was not included in the final list of
COCs.
Thirty-five SVOCs were detected in the composite waste samples during the Delisting
Petition demonstration. Bis(2-ethylhexyl)phthalate was not included in the final list of
COCs because although it was reported at 0.34 mg/kg in sample R1-03 and at an
estimated value of 0.085J in sample R2-03, both values were substantially below the
DRAS v.2 risk-based value of 2,720 mg/kg and the lowest Illinois Tiered Approach
Corrective Action (TACO) Tier 1 Soil Remediation Objective of 3,600 mg/kg. When
bis(2-ethylhexyl)phthalate was compared to these screening values, along with its
calculated Toxicity.
Characteristic Leaching Procedure (TCLP) value to the DRAS
leaching value, bis(2-ethylhexyl)phthalate was appropriately excluded from the final
list of COCs. Please also note that bis(2-ethylhexyl)phthalate is considered a typical
laboratory contaminant and that the estimated concentration reported for R2-03 does
not have sufficient QA to dismiss the potential influence of a bis(2-
ethylhexyl)phthalate laboratory contaminant affecting this method detection value.
9.
In a communication record dated 1/24/08, PDC's consultant, RMT, summarizes the
agenda for a conference call between PDC, RUT, IEPA, and USEPA. One point states:
"With comparison to Illinois Tiered Approach for Corrective Action (TACO) screening
values and DRAS [Delisting Risk Assessment Software] v.2 values, the results from the
Page 7
SAP [Sampling and Analysis Plan] implementation provided supports analytical results
to exclude additional constituents of concern (COCs) other than the 14 metals listed in
the SAP/ QAPP [Quality Assurance Project Plan]." TSD Appendix C. In an email
response, Todd Ramaly of
USEPA
Region V commented on the draft by striking the above
sentence and adding, "[Laura – I don't think we discussed this last point during the call.]"
TSC Appendix C (email from Ramaly to Curtis dated 1/13/08). Please describe any
resolution PDC may have reached with USEPA concerning this approach to excluding
detected constituents as COCs.
As stated in the response to question 8.a), above, USEPA-5 was instrumental in evaluating
dioxins and furans for the PDC EAFDSR by providing the technical expertise from its
federal delisting petition work using its DRAS model and alternatives. In neither the
1/24/08 conference call agenda nor its minutes, did
RMT
or PDC request USEPA-5
concurrence that certain constituents should be eliminated as COCs. Mr. Ramaly's strike
out and comments in the USEPA email dated 1/31/08 were discussed between Mr. Ramaly
and Ms. Laura Curtis of RMT in a telephone call later on 1/31/08. Ms. Curtis stated it was
PDC's intent to present this information to move discussions forward on the technical
issues regarding the DRAS model and that she would insert the phrase, "PDC reported..."
into the questioned sentence in order to clarify this position. Mr. Ramaly indicated that he
was satisfied with that addition. Concurrence by all parties was neither an objective of the
agenda nor an outcome of the conference call.
Therefore, there are no unresolved issues or conflicts between USEPA-5 and PDC
regarding excluding detected constituents as COCs.
10. The values for dioxin and furan congeners and toxicity equivalency quotient (TEQ) in
Table 3a and Appendix L of the TSD do not seem to agree with the raw laboratory data
from Pace Analytical in Appendix N of the TSD. Please reconcile the raw data with the
summarized data.
The values for dioxin and furan congeners and TEQ values reported for total
concentrations in the Pace Analytical raw laboratory data reports of Appendix N are
incorrect because the results are reported on a dry-weight basis. A set of corrected
laboratory reports are provided herewith in Attachment 5. These will replace the
following reports from Pace:
•
January 14, 2008 for Project # 1065168
• January 16, 2008 for Project # 1064827
•
January 25, 2008 for Project # 1065459
During the data validation process (TSD Appendix M), the results reported by Pace were
found to be on an oven-dried, or "dry weight" basis. The results reported by TriMatrix for
their solid samples were on an "as is" basis (aka "wet weight"). Page 54 of the
EPA RCRA
Delisting Program Guidance Manual for the Petitioner,
dated March 23, 2000, states:
Page 8
"For each analysis performed on each sample, you should report the following information:
Basis for each analysis (e.g. wet weight, dry weight). We prefer that this basis is the state in
which the waste will be disposed, if allowed by the test."
In this case, the PDC EAFDSR material is disposed of "as is" and PDC does not oven-dry
the waste first. So, in accordance with the Guidance Manual and for consistency with the
other analytical run by TriMatrix Laboratories, RMT instructed Pace Analytical to
resubmit their summary reports to report the results on a wet weight basis rather than a
dry weight basis. This affected only the total concentrations (not the TCLP results) Pace
Analytical reported for the dioxins and farms. This is an easily resolved issue as Pace
Analytical had the moisture content for each sample, and the sample concentration can be
calculated either way. On February 1, 2008, RMT instructed Pace to revise its summary
reports and electronic data. RMT replaced the appropriate data in the summary tables
(see Appendix J, Laboratory Reports and Appendix L, Whole Database in Tabular Form of
the TSD), but inadvertently did not replace the Appendix N Pace Raw Laboratory Data.
RMT apologizes for any confusion it caused the reader.
11.
The TSD indicates the TEQ value of 160 ng/kg was used in the spreadsheet calculation
model for the dioxin fish ingestion pathway. Please comment on whether the higher value
of 220 ng/kg (Sample R5-01) reported in the Pace Analytical raw laboratory data should
be employed in the evaluation. If it should be, please provide revised input and results
and address the resulting carcinogenic risk "Fishing CR," "Fish Concentration Edible
Portion," and "Fishing DL" of the revised values. If PDC provides revised results, please
update the comparison with the table "Background Dioxin Concentrations in Fish Tissue"
presented in Appendix H of the TSD.
The value of 220 ng/kg is on a dry-weight basis. The 160 ng/kg analytical result is the
equivalent wet-weight result. As stated above in response to Board comment 10, all total
concentrations should have been reported on a wet-weight basis. Attachment 5 hereto
provides a set of corrected raw laboratory data reflecting the wet weight value of 160
ng/kg. As the correct input value was used in the modeling, the reported risk-based
model results ("Fishing CR," "Fish Concentration Edible Portion," and "Fishing DL") are
correct.
12. Based on the TCLP results of the dioxin/furan analyses, please comment on how the
highest value of 0.052 pg/L (TSD Appendix N, Sample R1-04, 1064827002, 12/07/07)
compares to the groundwater adult dermal pathway that was determined as a limiting
pathway by the DRAS v.2 analysis of 2.05 x 10-10 mg/L in Appendix H of the TSD. Also,
please compare how the detected TCLP value of 0.052 pg/L compares to the revised
"Fishing DL" in the dioxin spreadsheet calculation model.
The maximum observed TCLP concentration for dioxin TEQs for the PDC EAFSDR data
set was 0.040 pg/L for Sample R5-01 (4.0 x 10-" mg/L), which is less than the DRAS v.2
Page 9
delisting level (2.05 x 10- 10
mg/L) reflective of the groundwater adult dermal pathway
determined as a limiting pathway by the DRAS v.2 analysis. The TCLP dioxin TEQ
concentrations for samples R1-03, R2-03, and R8-03 were reported as 0.00 pg/L.
The reported level of 0.052 pg/L (5.2 x 10-
11 mg/L) questioned by the Board is for a Field
Blank identified as sample R1-04. A field equipment blank is used to assess the
equipment decontamination methods. This field equipment blank concentration, with a
reported TEQ of 0.052 pg/L is so small that according to Pace Analytical Project Manager
Scott Unze, it is most likely attributable to a laboratory contaminant from background.
Mr. Unze further stated that it is common to see similarly low levels in the laboratory and
that it may originate from the glassware. We note that the USEPA Primary Drinking
Water Standard (DWS) for dioxin is 30 pg/L (3.0 x 10-
8
mg/L), or more than 500 times that
detected in the field blank.
The Fishing Delisting Level ("Fishing DL") is based on total waste concentrations, i.e., on a
mg/kg basis. It is not appropriate to compare the Fishing Delisting Level to a leachable
(i.e., TCLP) concentration.
13.
Please provide all of the pages from each of these DRAS runs: 2/20/08 (Arsenic) and
2/19/08 (Screening Levels to Identify COCs). See TSD Appendix H.
All of the pages from the 2/20/08 DRAS run for Arsenic are provided herewith in
Attachment 6. This DRAS model run was performed for arsenic only with a target risk of
1 x 10-4.
All of the pages from 2/19/08 DRAS run (Screening Levels to Identify COCs) are also
provided herewith in Attachment 6. Please note that the DRAS sheet entitled, "Pathways
Exceeding the Delisting Limits" indicates that the following constituents required
additional evaluation:
• SVOCS: Benzo(a)anthracene shows actual TCLP concentration as 1.05E-03 mg/L
and the lowest limiting TCLP concentration as 1.31E-04. Benzo(a)pyrene shows
actual TCLP concentration as 2.30E-05 mg/L and the lowest limiting TCLP
concentration as 8.06E-06. The semivolatile organic compounds (SVOCS)
subsection of Section 4.4 in the TSD explains that neither benzo(a)anthracene nor
benzo(a)pyrene were detected in the TCLP analyses. An evaluation of the raw
data provided no evidence of the PAHs in any of the TCLP samples. As a means
of demonstrating that these two SVOCs are appropriately excluded as constituents
of concern, notwithstanding the MDL being higher than the exceedingly low
screening levels, a comparison of the MDLs to the Illinois Tiered Approach for
Corrective Action (TACO) soil remediation objectives for industrial/commercial
properties (35 IAC 742 Appendix B, Table B) was made and indicated that these
detection limits are well below those TACO screening criteria. According to Table
3a, the TACO value for benzo(a)anthracene is 1,560 mg/kg versus the 0.021J mg/kg
Page 10
value in Sample R1-03. Similarly, the TACO value for benzo(a)pyrene is 156
mg/kg versus the 0.017J mg/kg value in Sample R1-03.
•
Mercury shows actual total concentration as 1.50 E+00 mg/kg and the limiting total
pathway concentration as 9.01E-02 mg/kg. The fish ingestion pathway result in
DRAS v.2 is a recognized error by USEPA-5 and, as such, the mercury total
concentration was compared to the provisional concentration of 9.35 mg/kg
provided by USEPA in an email dated January 24, 2008, found in Appendix C of
the TSD.
•
Arsenic shows actual total concentration as 3.70 E-03 mg/L and the limiting Total
pathway concentration as 9.36E-04 mg/L. Arsenic TCLP was identified as a COC
and additional risk-based evaluations are discussed in Section 6.3.3 of the TSD.
14.
In a communication record dated 1/24/08, RMT summarized the agenda for a conference
call between PDC, RMT, IEPA, and USEPA. One point states: "PDC requested
discussing how to handle . . . altering delisting criteria acceptable by the Agency (i.e.,
arsenic concentration based on 1 x 10-5 risk). It was decided that a conference call on
1/28/08, after the Agency call on 1/25/08 would be scheduled for the purposes of providing
the path forward and technical answers regarding the DRAS model." TSD Appendix C.
Please describe any resolution PDC may have reached with USEPA or IEPA concerning
altering the delisting criteria for arsenic.
In the noted discussion with IEPA and USEPA-5 on January 29, 2008, a portion of time
was set aside to discuss the appropriate target risk for arsenic. Mr. Ramaly shared that the
DRAS model is a tool for risk-based modeling and a beginning point but not necessarily
the only measurement available for decision making. Mr. Ramaly shared additional
information throughout the delisting process regarding options for deriving alternative
arsenic levels, e.g., values similar to the drinking water maximum contaminant level
(MCL) value, the most stringent regulatory limit set for arsenic in the different media.
Nothing has been formalized regarding the DRAS but he shared that site-specific
conditions could justify, and the USEPA has allowed in past delistings, a target arsenic
aggregate risk in the lx 10
4 to 1x10-6
range as being protective of human health and the
environment. In the delisting granted to Heritage Environmental (see Attachment 4
hereto), USEPA-5 granted a delisting specifying an arsenic concentration of .0936 mg/L,
which provided an aggregate risk of 1 x 10-
4
. This ended the guidance discussion
provided by USEPA-5, and Mr. Ramaly stated it would be PDC and RMT's responsibility
to evaluate and propose a demonstration to show an arsenic concentration at an aggregate
risk other than 1x10-
6
as being protective in this delisting.
As stated above in our response to Question 8.a), it is our understanding that the IEPA
considered their communications with USEPA-5 when developing its "Response to RCRA
Delisting Adjusted Standard Petition" (filed June 12, 2008). The IEPA's June 12 response
expresses no concerns regarding risks due to arsenic.
Page 11
Therefore, there are no open issues or pending resolutions either USEPA or IEPA have
with PDC concerning altering the delisting criteria for arsenic.
15.
PDC's
proposed adjusted standard language specifies TCLP concentrations not to be
exceeded for 14 metals. Unlike the federal delisting for Heritage, however, PDC's
proposed language does not contain a delisting level for total mercury. See 67 Fed. Reg.
1888, 1895 (Jan. 15, 2002).
a) Please quantify the contribution from mercury to the aggregate hazard index.
The aggregate hazard for the surface pathway estimated from the DRAS v.2 model
effort, which relies on total metal concentrations, was greater than the 1.0 threshold.
Mercury, at its maximum observed concentration of 1.5 mg/kg, is the primary
contributor to the estimated aggregate noncarcinogenic hazard. As noted in Section
4.3 of the TSD, USEPA-5 provided information that the DRAS v.2 model had
calculation errors that result in significantly overstating the surface pathway hazards,
which results in significantly understating the safe delisting levels for mercury.
As a result of those errors, USEPA-5 recommended relying on provisional DRAS v.3
outputs (provided by USEPA-5 and included in Appendix H of the TSD) to address
mercury. The DRAS v.3 model basis incorporates current regulatory and scientific
position regarding mercury uptake into biological tissues, not included in DRAS v.2
used as the basis for the Heritage delisting petition. As such, the modeled hazard
quotient attributable to mercury in the DRAS v.2 model should be disregarded in light
of this new information. Replacing the DRAS v.2 hazard quotient (HQ) with a DRAS
v. 3-derived mercury HQ in the surface pathway results in an aggregate hazard of well
below 1.0, with a corresponding delisting level for total mercury of 9.35 mg/kg. The
maximum observed mercury concentration contributes 0.16 to the overall aggregate
hazard of 0.52. It should be noted that this aggregate hazard of 0.52 for all constituents
is well below the maximum aggregate hazard of 1.0.
b) Please comment on the appropriateness of including a delisting level for total
mercury.
PDC does not find inclusion of a delisting level for total mercury appropriate for the
following reasons:
•
A comparison of maximum observed total mercury concentrations (1.5 mg/kg) to
the provisional DRAS v.3 delisting level (9.35 mg/kg) indicates that mercury in the
EAFDSR will not result in an unacceptable aggregate hazard for the surface
pathway.
•
The proposed TCLP limit for mercury of 0.025 mg/L addresses the leaching
potential (TCLP) and also provides information on protection of the fish ingestion
pathway for total mercury. An estimated maximum TCLP value that corresponds
Page 12 .
to the provisional DRAS v.3 total mercury concentration of 9.35 mg/kg is
0.47 mg/L when applying the 20x rule of thumb (recognizing the twenty-fold
dilution from total to TCLP values due to the TCLP test methodology). By
proposing the more conservative LDR-based delisting limit of 0.025 mg/L for
mercury TCLP, protection of the surface runoff pathway and an acceptable fish
ingestion risk scenario is assured.
• The maximum observed total mercury concentration, 1.5 mg/kg, is over six times
less than the maximum DRAS v.3 allowable total concentration for mercury of
9.35 mg/kg for the proposed annual volume of waste.
Therefore, adding a delisting level for total mercury is neither necessary nor more
protective than the proposed delisting levels.
16.
PDC premises its dioxin modeling for the fish ingestion pathway on disposal in the
Indian Creek Landfill. The proposed adjusted standard language, however, does not limit
disposal of EAFDSR to that landfill. Please consider re-running the model using the
default generic values for a less site-specific analysis. If PDC wishes to use site-specific
information in its modeling, rather than the default generic values, please consider either
providing site-specific modeling for all the potential Illinois landfills at which the
EAFDSR might be disposed, or limiting the proposed adjusted standard language to only
those disposal facilities for which site-specific modeling was performed.
RMT has revised the risk modeling for dioxin using input data determined to be
applicable for any permitted Subtitle D landfill in Illinois. The revised risk modeling is
provided herewith in Attachment 7.
17.
References in the proposed adjusted standard language to the "mechanical mixer" and the
"K061 stabilization process described in its Petition" (see proposed condition 2) could
encompass the stabilization process that PDC has used for the past 19 years. Please
comment on the appropriateness of more narrowly-tailoring the adjusted standard
language to PDC's "new proprietary stabilization technology," subject to proposed
condition 3(b). Petition at 2. As appropriate, please propose amendatory language
PDC understands the potential for misunderstanding the intent of the proposed language
and does not object to amending the language of proposed condition 2. Please know that
it was and remains PDC's intent to utilize the new proprietary stabilization technology,
unless and until it is modified in accordance with proposed condition 3(b). PDC proposes
that condition 2 be modified by adding the following text as the first sentence, with the
balance of the existing text remaining unchanged:
Page 13
"This adjusted standard is provided only for K061 wastes treated using PDC's new
proprietary stabilization technology described in the Petition, unless and until it is
modified in accordance with condition 3(b)."
18.
Proposed conditions 3(c)(1) and (2) each refer to "another round of verification sampling
and analysis." Please clarify whether these additional rounds would include testing for
all COCs or only for those that exceeded the delisting concentrations in the prior round.
If PDC is proposing the latter approach, please explain how PDC will verify that over-
treatment has not increased the solubility of other metals that may be amphoteric.
PDC proposed limiting the constituents analyzed after further treatment to only those that
exceeded the delisting level in the prior round because of the low probability of over-
treatment given the knowledge gained from the initial analysis, i.e., once batch-specific
constituent concentrations and extraction pH data are known, optimizing reagent
proportions for effective re-treatment is relatively simple and yields a very high initial
success rate. However, PDC would not object to analyzing all 14 metals in each round of
testing. As stated in the summary section of the TSD, it is PDC's intent that: "The
proposed conditional exclusion, when applied using the methods and procedures
discussed herein, creates a fail-safe system that ensures that only EAFDSR meeting the
proposed delisting levels will be disposed as a non-hazardous waste." In keeping with
that intent, PDC proposes that proposed condition 3(c) be modified as follows, where
underlined text denotes new language:
***
"...All
verification analyses shall be conducted on a composite sample that effectively
represents the entire batch as did the initial sample, and include analysis for all 14
constituents identified in condition 4."
19.
PDC states that its proposed adjusted standard language requires that the delisted
EAFDSR be disposed of in a lined landfill with leachate collection in Illinois that is
"licensed, permitted, or otherwise authorized to accept the delisted waste in accordance
with all applicable RCRA Subtitle D requirements." Petition at 19. Please explain what
types of landfills other than permitted landfills PDC believes would be able to accept the
delisted EAFDSR.
The subject, potentially misleading language was borrowed from adjusted standard
exclusions recently approved by the USEPA (see, for example, 72 FR 31189 [June 6, 2007]
in re: delisting exclusion granted to Ford Motor Co.). The intent of using relatively recent
USEPA rules as sources for proposed language was to ensure that the PDC proposal was
compatible with similar, contemporary adjusted standards. While it may be possible
under federal rules for a state(s) to authorize landfills to accept industrial process wastes
Page 14
other than by permit, it is not possible in Illinois and PDC does not object to modifying the
Petition accordingly.
While the narrative discussion of the proposed adjusted standard conditions includes the
subject language, proposed condition 2 itself effectively excludes non-permitted landfills
in its existing form. If desired, the Board could modify proposed condition 2 as follows to
better reflect Illinois regulatory requirements, where underlined text denotes new
language and struck-through text denotes replaced language:
***
"...The
EAF dust stabilized residues shall be disposed of pursuant to the Board's non-
hazardous landfill regulations found at 35 Ill. Adm. Code 810-815, and disposed of in a
lined landfill with leachate collection and all necessary
authorizations EPA-issued
permits to receive the non-hazardous EAF dust stabilized residues."
Dated: August 6, 2008
Laura B. Curtis
Project Manager
RMT, Inc.
Page 15
BEFORE THE ILLINOIS POLLUTION CONTROL
BOASCEIVED
CLERK'S
OFFICE
IN THE MATTER OF?
AUti 0
7 2008
STATE
OF
ILLINS
RCRA DELISTING ADJUSTED STANDARD ) AS 08-10
?
Pollution
Control
Board
PETITION OF PEORIA DISPOSAL COMPANY) (Adjusted Standard – Land)
)?
(RCRA Delisting)
AFFIDAVIT OF FILING BY FEDERAL EXPRESS and
SERVICE BY U.S. MAIL, FIRST CLASS
PLEASE TAKE NOTICE that on August 6, 2008, I filed with the Clerk of the Pollution
Control Board of the State of Illinois the instrument(s) entitled RESPONSE OF PEORIA
DISPOSAL COMPANY TO ATTACHMENT A TO THE HEARING OFFICER ORDER
ENTERED ON JULY 15, 2008, and this Affidavit, by sending an original and four copies of
same to the Clerk, of the Pollution Control Board via Federal Express for overnight delivery.
Pursuant to prior communications with the Clerk of the Pollution Control Board, PDC filed one
original and four paper copies of this Response, except that only the original Response includes a
paper version of Attachment 5 thereto, while the copied Responses include CD-ROM versions of
Attachment 5 thereto.
I further certify that on this date I served RESPONSE OF PEORIA DISPOSAL
COMPANY TO ATTACHMENT A TO THE HEARING OFFICER ORDER ENTERED ON
JULY 15, 2008, and this Affidavit, by placing one copy of each document in the U.S. Mail, First
Class postage prepaid, addressed as listed below. The copies of the Response include CD-ROM
versions of Attachment 5 thereto.
Service list:
United States Environmental Protection Agency
Office of Solid Waste and Emergency Response
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
THIS FILING IS ON RECYCLED PAPER AS REQUIRED BY 35 ILL. ADM. CODE 101.202 AND 101.302(g).
-Lyfiii Buhl
Regional Administrator
United States Environmental Protection Agency, Region 5
7 WesvJackson Boulevard
ChiCagbfIL 60604
William D. Ingersoll
Manager, Enforcement Programs
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Dated: August 6, 2008
Respectfully submitted,
Nair
Attorney for Petitioner
Claire A. Manning, Esq.
Brown, Hay & Stephens, LLP
205 S. Fifth Street
Suite 700
Springfield, Illinois 62701
Telephone: (217) 544-8491
Facsimile: (217) 544-9609
Email: cmanning@bhslaw.com
908-0657
Brian J. Meginnes, Esq.
Janaki Nair, Esq.
Elias, Meginnes, Riffle & Seghetti, P.C.
416 Main Street, Suite 1400
Peoria, Illinois 61602
Telephone: (309) 637-6000
Facsimile: (309) 637-8514
Emails:
bmeginnes@emrslaw.corn
jnair@emrslaw.com
THIS FILING IS ON RECYCLED PAPER AS REQUIRED BY 35 ILL ADM. CODE 101.202 AND 101.302(g).
Attachment 1
Part B Permit Conditions Referenced in Response No. 1
O
Revised: October 2007
ILD000805812
Page X-9
b.
Until such time as the analyses demonstrates compliance with LDRs, the treated
waste shall be stored. Wastes subject to different land disposal restrictions may be
homogeneously mixed prior to treatment or may be segregated and remain
segregated until it is demonstrated that the wastes have each passed the treatment
standards applicable to that waste as specified in Condition 14.e.i. below. These
management procedures shall be used to segregate the waste into separate batches.
A separate determination shall be made for each batch.
c.
The container, tank or waste pile may contain waste generated over more than one
day of operation.
d.
Once the samples required for the demonstration have been obtained from a
container, no new wastes may be added to any container(s) in that batch.
e.
The Permittee shall demonstrate compliance with the LDRs in accordance with
the steps listed below:
A representative sample (i.e., a grab sample) shall be collected from the first
and last container of each batch. The demonstration of compliance with the
Land Disposal Restrictions for the mixture of waste codes shall be based on
the most stringent treatment standard for each of the pertinent parameters.
ii.
The samples from the first and last container shall be analyzed separately to
demonstrate compliance with the land disposal restrictions. A minimum of
two samples must always be analyzed to demonstrate compliance.
iii.
If the treatment standard for any of the constituents is exceeded:
1.
Treated waste which fails to meet the requirements shall receive
additional treatment (this may consist of additional curing time and/or
reintroduction into the treatment facility for further stabilization).
Waste which receives additional treatment may only be disposed in the
landfill after it has been demonstrated that the residue meets the proper
treatment standards.
2.
Wastes which fail to meet the requirements after treatment or additional
curing, shall be reintroduced into .the treatment facility for further
stabilization. PDC shall conduct an investigation of these wastes to
determine the cause of the failure. A plan shall then be developed and
implemented to prevent and/or minimize future excursions.
Revised: October 2007
ILD000805812
Page X-10
iv. At a minimum, for all wastes, unless each container (roll-off box) is sampled
separately, the treated batch must receive the same amount of curing time as
the sample that demonstrates compliance with the LDR standard during the
bench study of the waste.
f.
Wastes.which carry only the D006 or D008 waste code or a combination of these
two waste codes are not subject to the testing requirements in E.14.e(i) through
(iii) above but may follow the sampling frequency in condition X.G.3 below. If a
demonstration fails, all waste carrying the waste code would then be subject to the
verification process required by E.14.e.until the waste code(s) are requalified for
the relaxed testing requirements. In order to requalify, a minimum of twenty (20)
consecutive samples, collected in accordance with special condition X.E.15.e.(i)
through (iii) of the approved Part B Permit, must meet the applicable treatment
standards on the initial analysis. In addition, an investigation must be conducted
to determine the cause of the failure. Any corrective action taken to prevent a
recurrence must be documented in the operating record. This could include a new
bench scale study, disqualification of a wastestream from the relaxed
requirements, etc.
g.
Wastes which carry the K061 waste code are not subject to the testing
requirements in E.14.e(i) through (iii) above but may follow the sampling
frequency in Condition X.G.3 of PDC's approved RCRA permit application Log
B-24R providing the pH F (final pH value of the TCLP extraction process)
parameter of each batch is within the range of 9.0 pH units through 11.2 pH units.
All batches which fall outside of this range must be subject to the testing
requirements of E.14.e(i) through (iii).
15.
The Permittee shall demonstrate compliance for the treated waste subject to the
Adjusted Standard identified in 35 IAC 721 Appendix I (originally issued by the
Illinois Pollution Control Board on February 4; 1993) by following the requirements
specified in the exclusion. Waste that fails to meet the delisting criteria may be subject
to Section 39(h) of the Environmental Protection Act.
16.
The Permittee shall treat all wastes subject to the relaxed testing requirements specified
in Conditions X.E.14.f or the adjusted standard in E.15 above using the paddle wheel
mixer as opposed to the backhoe/mixing box method.
17.
All wastes which failed the gate control paint filter test shall be tested by the
penetrometer test (after stabilization). No wastes which fails to possess a load bearing
capacity of at least 2.0 tons per square foot (TSF) may be disposed.
Attachment 2
Agency Correspondence Regarding Waste Classification
Peoria Disposal Company
January 3, 2008
Mr. Stephen F. Nightingale, P.E.
Permit Section Manager
Illinois Environmental Protection Agency
Bureau of Land
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Re: Peoria Disposal Company #1
ILD000805812/1438120003
RCRA Part B Permit, Log No. 24
Dear Mr. Nightingale:
Further to a recent discussion with Mr. Mark Crites of your Section, PDC is hereby requesting
guidance regarding the regulatory definition of certain wastes managed by PDC after treatment
at the above referenced facility. Specifically, PDC currently ships for disposal to its Indian
Creek Landfill in Hopedale, Illinois, both delisted and decharacterized treatment residues. In the
interest of enhancing operating efficiency and simplifying recordkeeping, PDC desires to
manage the delisted residues as non-special wastes. While it is clear that decharacterized
residues may not be managed as non-special waste due to the exclusion at Section 3.475
(c)(1)(D) of the Illinois Environmental Protection Act ("Act"), we believe that delisted residues
are outside the scope of the categories listed in Section 3.475 (c)(1) and, as such, may be
certified as non-special waste pursuant to Section 22.48 of the Act. The basis of that belief is set
forth below.
Section 3.475 of the Act specifies that industrial process wastes and pollution control wastes are
defined as special waste unless, pursuant to that Section, any such waste is certified to not be any
of the categories listed therein. Subdivision 3.475 (c)(1)(D) specifies that non-special waste may
not be:
***
(D) an industrial process or pollution control waste subject to the waste
analysis and recordkeeping requirements of Section 728.107 of Title 35 of
the Illinois Administrative Code under the land disposal restrictions of Part
728 of Title 35 of the Illinois Administrative Code;***
P.O.
Box
9071
?
4700 N. Sterling Ave.
Peoria, IL
61612-9071
?
Peoria, IL 61615-3647
(309) 688-0760
?
100% recycled paper
?
Fax: (309) 688-0881
Mr. Stephen F. Nightingale, P.E.
November 16, 2007
Page 2
Therefore, decharacterized wastes, which remain subject to the waste analysis and/or
recordkeeping requirements of Part 728 of Title 35 of the Illinois Administrative Code (35 IAC),
may not be certified as non-special wastes. Specifically, decharacterized wastes may contain
underlying hazardous constituents as defined
in
35 IAC 728A 02, which require treatment to
meet the universal treatment standards of 35 IAC 728.148 and Table U of that Part. Even in the
absence of underlying hazardous constituents, decharacterized wastes are subject to the
notification and certification requirements of 35 IAC 728.107.
Delisted wastes, however, are not subject to the waste analysis and recordkeeping requirements
of 35 IAC 728.107. Specifically, upon granting of an adjusted standard by the Illinois Pollution
Control Board ("Board") and provided any conditions imposed by the Board order are met, a
waste from a particular generating facility is excluded from the list of hazardous wastes in
Subpart D of 35 IAC Part 721 and, provided it is not hazardous by operation of Subpart C of 35
IAC Part 721, is not subject to RCRA hazardous waste management requirements. One such
waste is delisted F006 waste treated by PDC (Board order AS91-3 identified in 35 JAC 721,
Appendix I, Table D). Because the F006 waste treated by PDC in accordance with the
referenced Board order is excluded from the hazardous waste lists and does not exhibit a
characteristic of a hazardous waste, it is clearly not subject to any of the 35 IAC Part 728
requirements, which apply only to hazardous wastes that are restricted from land disposal. As
such, we believe the delisted waste is eligible for certification as a non-special waste, provided.
no other excluding conditions set forth in Section 3.475 (c)(1) of the Act exist.
We are hopeful that our stated understanding of the referenced statutes and regulations meets
with Agency agreement and will look forward to your guidance. If you have any questions
regarding this request or if
any
additional information is desired, please contact me at (309) 676-
4893, ext. 1551, or by e-mail at
rwelk@pdcarea.com.
Sincerely,
PEORIA DISPOSAL COMPANY
Ronald J. We
Facility Director
Peoria Disposal Company
♦11,
11'
el
100% recycled paper
R 6
?
e
•
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GRAND AVENUE EAST,
P.O. Box 19276,
SPRINGFIELD, ILLINOIS
62794-9276 - ( 217) 782-3397
JAMES R.
THOMPSON CENTER,
100
WEST RANDOLPH, SUITE 11-300, CHICAGO,
IL 60601 — (312) 814
-6026
ROD R.
BLAGOJEVICH, GOVERNOR DOUGLAS
P.
SCOTT, DIRECTOR
217/524-3300
May 13, 2008
Peoria Disposal Company
Attn: Ronald J. Welk, Facility Director
P.O. Box 9071
Peoria, Illinois 61612-9071
Re:?
Letter regarding waste classification
1438120003 – Peoria County
Peoria Disposal Company #1
ILD000805812
PS08-016
RCRA Permit File
Dear Mr. Welk:
This letter is in response to your letter of January 3, 2008 in which you request the concurrence of
Illinois EPA to your determination of the regulatory status of certain wastes managed by Peoria
Disposal Company (PDC) after treatment in the Waste Stabilization Facility (WSF) at the above-
referenced facility. Specifically, you believe that:
1.
?
Waste treated to remove hazardous waste characteristics is not eligible for the exclusion
provided at Section 3.475 (c)(1) of the Illinois Environmental Protection Act (Act)
because
it is
still subject to the requirements of 35 Ill. Adm. Code 728, and fails the test at
Section 3.475(c)(1)(D) of the Act.
Waste initially bearing the waste code F006 that is treated to meet the delisting granted to
PDC in Illinois Pollution Control Board (IPCB) order AS91-3 is eligible for the exclusion
provided in Section 3.475 (cX1) of the Act because once this waste meets the delisting, it
is no longer subject to 35 Ill. Adm. Code 728, and therefore passes the test at Section
3.475(c)(1)(D) of the Act as well as the other tests in Section 3.475(c)(1).
Illinois EPA agrees
:
with both of these determinations. With respect to Item 2 above, we note that
IPCB's ruling in AS91-3 (dated March 11, 1993), on page 4, IPCB specifically states:
.. Those wastes that do qualify are subject to the non-hazardous solid waste disposal
regulations of 35 III. Adm. Code 810 through 815, rather than the Illinois RCRA
regulations of 35 Ill. Adm: Code 703 and 722 through 728. [emphasis added]
ROCKFORD -
4302
North Main Street, Rockford, IL 61103 — (815) 987-7760 •
DES PLAINES -
9511 W. Harrison St., Des Plaines, IL 60016 — (847) 2944000 .
ELGIN — 595
South
State, Elgin, IL
60123 — (847) 608-3131 • PEORIA — 5415 N.
University St., Peoria, IL 61614 — (309) 693-5463
BUREAU OF LAND - PEORIA -
7620 N.
University St., Peoria, IL
61614 — (309) 693-5462 • CHAMPAIGN — 2125
South First Street, Champaign, IL 61820 — (217) 278-5800
SPRINGFIELD -
4500 S. Sixth Street Rd., Springfield, IL 62706 — (217)
786-6892 • COLLINSVILLE -
2009
Mall
Street, Collinsville, IL 62234 — (618) 346-5120
MARION -
2309 W. Main St.,
Suite 116,
Marion, IL 62959 — (618) 993-7200
PRINTED ON RECYCLED PAPER
Page 2
Because of this statement, IPCB makes it clear that it does not intend the successfully delisted
waste to be subject to the requirements of 35 111. Adm. Code 728.107.
If you have any questions regarding this matter, please contact Mark L. Crites at 217/524-3269.
Stephen F. Nightingale, P.E.
Manager, Permit Section
Bureau of Land
SFN:MLC:rnls/082371s.doc
Attachment 3
Part B Permit Conditions Referenced in Response No. 4
Revised: October 2007
ILD000805812
Page X-14
expected to be present in their waste. A certification statement must be
submitted as part of the application to support this claim.
2.
Petroleum contaminated media and debris from LUST sites are temporarily
exempt from full TCLP analysis and the generator may limit analyses to
flashpoint, paint filter test and TCLP lead.
3.
Non-commingled hazardous wastes received at a treatment facility may be
analyzed in accordance with Condition 7.
4.
RCRA empty containers are exempt from testing requirements.
5.
Off-specification, unused or discarded commercial chemicals products may
use a MSDS to determine the hazardous constituents present and appropriate
USEPA hazardous waste class, if applicable, in lieu of analytical results.
6.
Identical waste streams being generated by industrial processes at multiple
generator sites may use the results from the representative initial analytical
sampling from one representative site for all sites. The generator must
certify that the waste generation process and the raw materials used in the
process were identical at each location. Specifically, the following waste
streams have been approved:
i.?
sand blasting residue from IDOT bridges.
"ii. pit sludge from Iowa DOT maintenance shop
Each load of pit sludge shall be tested for flashpoint, pH, TOX and total
benzene. If the total benzene is above 10 mg/1, a TCLP analysis for
benzene shall be performed. Additional parameters may be
incorporated if the practices generating the wastes are changed."
This condition may be modified to include other identical waste streams
from industrial processes on a case-by-case basis. The modification request
must include documentation that the processes generating the waste are
identical and the QA/QC procedures are in place to insure the consistency of
the waste stream.
7.
In the event hazardous waste is accepted for.treatment, the Permittee may
accept a certification as identified in Attachment #4 indicating a waste does
not contain a particular TCLP
cciiistituent lieu
of analysis for
Attachment 4
Agency Correspondence Regarding Waste Classification
■
RCRA Delisting — First Twenty Years
■
Heritage Environmental Delisting (Nucor)
■
Conversion Systems Inc. Delisting (CSI)
RCRA Hazardous Waste
Del fisting:
The First 20 Years
Program Evaluation
U.S. Environmental Protection Agency
Office of Solid Waste
June, 2002
RCRA Hazardous Waste Delisting:
The First Twenty Years
Office of Solid Waste
June 2002
530-R-02-014
RCRA Hazardous Waste Delisting: The First Twenty Years
EXECUTIVE SUMMARY
?
«
1
»
PURPOSE
«
1
»
THE HAZARDOUS WASTE DELISTING PROGRAM
«
1
»
METHODOLOGY OF THE EVALUATION
«
2
»
DESCRIPTIVE STATISTICS
«
2
»
ECONOMIC IMPACTS OF THE DELISTING PROGRAM
«
2
»
ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM
«
3
»
CONCLUSIONS
«
3
»
CHAPTER ONE: EVALUATION OF THE DELISTING PROGRAM
?
«
4
»
1.1 PURPOSE
«
4
»
1.2 PROGRAM EVALUATION AND GPRA
«
4
»
1.3 THE HAZARDOUS WASTE DELISTING PROGRAM
«
5
1.4 EVALUATION OF THE DELISTING PROGRAM
«
8
»
1.4.1
Why Evaluate the Delisting Program
?
«
8
»
1.4.2
What are the Outcomes and Impacts of the Delisting Program?
«
10
»
1.4.3
Is the Delisting Program Fulfilling Its Goals?
«
10
»
1.5 METHODOLOGY OF THE EVALUATION
«
10
»
1.5.1 Creating the Database
«
11
»
1.5.2 Assessing the Data
«
11
»
CHAPTER TWO: RESULTS OF THE EVALUATION
?
«
13
»
2.1 DESCRIPTIVE STATISTICS
«
13
»
2.1.1
Total Quantities of Waste Delisted
«
15
»
2.2
ECONOMIC IMPACTS OF THE DELISTING PROGRAM
«
16
»
2.2.1
Administrative Costs
0 16
2.2.2
Costs of Treatment and Disposal
0 17
»
2.2.3
Net Cost Impacts
«
22
»
2.3
ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM
«
22
»
2.3.1
Environmental Releases
«
23
»
2.3.2
Recycling
«
24
»
2.3.3
Opportunity Costs to EPA
«
25
»
2.4
DISTRIBUTION OF IMPACTS
«
25
»
2.4.1 Geography
25 >>
2.4.2 Small Businesses
«
26
»
2.4.3 Industries Affected
«
26
»
CHAPTER THREE: RECOMMENDATIONS AND CONCLUSIONS
?
«
28
»
3.1
RECOMMENDATIONS
«
28
»
3.1.1
Regulatory Impacts Analysis
«
28
»
3.1.2
Evaluation of the Listing Program
«
28
»
3.2
CONCLUSIONS
«
28
»
EXECUTIVE SUMMARY
PURPOSE
This report documents an evaluation of the outcomes and impacts of the hazardous waste
delisting program, conducted by the United States Environmental Protection Agency under the
Resources Conservation and Recovery Act (RCRA). The report describes the rationale for
conducting a program evaluation, the results and outcomes of the delisting program, and other
findings and issues raised in this evaluation.
This evaluation was undertaken as part of EPA's implementation of the Government
Performance and Results Act (GPRA) of 1993. That statute requires federal agencies to include
program evaluations in the strategic planning process.
THE HAZARDOUS WASTE DELISTING PROGRAM
The Resource Conservation and Recovery Act, which guides EPA's hazardous waste
management programs, provides for a process to remove, or "delist", a waste generated at a facility
from the list of hazardous wastes. This delisting process is initiated by the generator (person who
creates the waste), who prepares a petition for delisting the waste. The petition provides
information about the waste, including its chemical composition, to demonstrate the rationale for
delisting the waste. The petition is reviewed by the appropriate regulatory agency (either EPA or
a state hazardous waste regulatory agency which has been authorized to grant delisting petitions)
to determine whether the waste should continue to be listed as hazardous.'
EPA's Office of Solid Waste decided that the delisting program would be a good candidate for
evaluation. After consultation with staff and management in both headquarters and the regional
offices, OSW decided that this evaluation would be most useful if focused on the
outcomes
and
impacts
of the federal delisting program, rather than focus on the mechanisms for conducting
delistings. Therefore, this study examines how the program has functioned, and what has been
gained by the operation of the delisting program. This "big picture" focus also results in findings
that provide useful information for assessing the future direction and management of the delisting
program. This report looks at three different categories of outcomes of the delisting program:
Cost savings and aggregate economic impacts
Impacts of delisting on the environment
Impacts of delisting on the RCRA hazardous waste management program
See Section 1.3 for more detail on the full process of the regulatory determination.
« 1 »
METHODOLOGY OF THE EVALUATION
EPA assembled a database listing all the delisting applications granted by the EPA (not including
those granted by state governments) between calendar years 1980 and 1999. Some of the
information had been kept by the delisting program, either in paper files or in the Delisting
Petition Data Management System. This database had been discontinued in 1995. Other data
was taken from the
Federal Register
notices announcing each proposed and final delisting granted.
Data elements in the current database include:
►
Name and address of petitioning facility
►
Date petition submitted and final decision reached
►
Date delisting became effective
►
Waste volume, matrix, form, quantity, and source
►
Chemical test results for wastes
►
RCRA waste codes
►
Management of wastes before and after delisting
Using the database, we calculated total volumes of waste delisted. We also estimated the cost of
administering the program, and cost savings that have been realized through delisting.
DESCRIPTIVE STATISTICS
Over the 20-year period from 1980 through 1999, delistings were granted to a total of 136
separate waste streams, generated at 115 separate facilities. By far the most common waste code
for which delistings were granted is F006, an electroplating waste, found in 51 delisted waste
streams. Over this period,
a cumulative total of 45 million tons of waste has been excluded
from subtitle C requirements;
over 80% of that volume is wastewater.
ECONOMIC IMPACTS OF THE DELISTING PROGRAM
The reduced social costs associated with the delisting program are derived through calculating the
administrative costs of operating the delisting program, and the offset of lowered costs of waste
treatment and disposal.
The total administrative costs associated with this twenty year period of the delisting program
ranges from $107 million to $226 million. The costs to petitioners is between 70-85% of that
total. The costs of running the program, while large, are far outweighed by the cost savings
achieved, however. From the inception of the delisting program through the year 2000,
cumulative net cost savings attributable to the delisting program range between $1.2 billion and
$2.4
billion.
Even if no further delistings are ever granted, the delisting program will save over
$105 million each year, from wastes that have already been removed from Subtitle C regulation.
« 2 »
ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM
An complete investigation into previously delisted wastes was outside the scope of this program
evaluation. However, given a strict risk assessment process (which has been made progressively
more accurate), the Agency has little reason to believe that these streams are causing
environmental problems. The Agency has also taken steps to limit the possibilities for harmful
environmental releases in the future, and to facilitate review of the consequences of disposal of
delisted waste streams.
Another issue of concern is the impact of delisting on recycling. It seems logical that delisting
might inhibit recycling in some cases, and promote it in others. We found anecdotal evidence of
both impacts, but were unable to identify clear trends in either direction.
CONCLUSIONS
The findings of this evaluation distinctly demonstrate the significant
economic
impacts of the
delisting program: reductions in deadweight loss to the economy totaling over $100 million each
year. Continued efficiencies and refinements in the delisting petition review process should only
improve those results. The
environmental
impacts are not as clear, although EPA does not
have reason to suspect that delisted wastes are causing environmental problems.
As one of the first program evaluations undertaken by the RCRA program in response to GPRA,
there is also clear value to this evaluation study itself. Not only has it helped the RCRA program
understand the process of program evaluation, it has also helped us understand the nature of the
value of a program. The analysis demonstrates that benefits can take many forms, not just risk
reduction. A program like delisting demonstrates its value in terms of reduction in economic
losses, and concomitant improvement in human welfare.
« 3 »
CHAPTER ONE:
EVALUATION OF THE DELISTING PROGRAM
1.1 PURPOSE
This report documents an evaluation of the outcomes and impacts of the hazardous waste
delisting program, conducted by the United States Environmental Protection Agency under the
Resources Conservation and Recovery Act (RCRA). The report describes the rationale for
conducting a program evaluation, the results and outcomes of the delisting program, and other
findings and issues raised in this evaluation.
1.2 PROGRAM EVALUATION AND GPRA
This evaluation was undertaken as part of EPA's implementation of the Government
Performance and Results Act (GPRA) of 1993. Under that statute,
program evaluation
has been
defined as "an objective and formal assessment of the results, impact, or effects of a program or
policy." 2
Program evaluations also may examine the implementation, operations, and/or
processes of programs.' A program evaluation will draw conclusions about the effectiveness of
the design, implementation, and/or impacts of a program. The term
program
here includes the
usual connotation of a set of staff activities with a defined goal or purpose; the term may also
include a policy initiative, an investment project, or even a change in procedures.
Why conduct a program evaluation? Evaluation is clearly a good practice for effective
management, whether public, private, or non-profit. Among the advantages of conducting
evaluations are
►
Assessing the impact of programs and policies
►
Documenting that functions have been carried out and outcomes reached
Documenting a lasting record of the program
►
Assisting with decisions about program continuation, expansion, and future funding.
Although the GPRA statute does not require a specific schedule of program evaluations, the law
clearly presumes they will be conducted. The committee report accompanying the legislation, as
well as the legislation itself, speaks specifically of the role of program evaluations in the annual
cycle of performance planning and reporting. Guidance from the Office of Management and
Government Performance and Results Act of 1993: Report of the Committee on Governmental Affairs, United States
Senate, to Provide for the Establishment, Testing, and Evaluation of Strategic Planning and Performance Measurement in the
Federal Government, and for Other Purposes,
p. 32.
3
See, for example, U.S. Office of Management and Budget, Circular A-11 , §210.11: "Program Evaluations
and Strategic Plans," 1998.
« 4 »
Budget' directs agencies to prepare a planned schedule of program evaluations. According to
the GPRA, the 5-year strategic plan should contain a "description of the program evaluations
used in establishing or revising general goals and objectives." The legislation also guides the
agency to include a schedule for future program evaluations to be conducted. An October, 1998
memo from Sallyanne Harper, then Chief Financial Officer of the EPA, documents the Agency's
expectation that programs will conduct program evaluations as part of GPRA implementation,
and provides basic guidelines for conducting such evaluations.
1.3 THE HAZARDOUS WASTE DELISTING PROGRAM
EPA uses a formal assessment process to deter
mine whether certain industrial wastes should be
placed on a list of "hazardous wastes." These determinations include wastes from specific
industrial processes or particular chemical formulations. Any waste that meets the listing
description (regardless of its specific chemical composition) is a
listed
hazardous waste, and is
regulated under RCRA Subtitle C. Those regulations include requirements for specific waste
handling procedures, from generation through storage, treatment, and disposal.
Congress and EPA recognized, however, that listing wastes incurs the possibility of regulating
wastes which do not truly pose a threat to human health or the environment. A facility may
have a process or raw material that produces a waste with different attributes than others in the
listed group. In other cases, waste treatment techniques may remove or destroy hazardous
constituents. For example, a facility in Indiana was granted a petition to delist wastewater
treatment sludges from an electroplating process, after demonstrating that concentrations of
specific constituents in the the sludges were not large enough to present significant risk from
disposal.
The RCRA statute' and regulations, therefore, also provides for a process to remove, or "delist", a
waste generated at a facility from the list of hazardous wastes. This delisting process is initiated by
the person generating the waste, who prepares a petition for delisting the waste. The petition
provides information about the waste, including its chemical composition, to demonstrate the
rationale for delisting the waste. The petition is reviewed by the appropriate regulatory agency
(either EPA or a state hazardous waste regulatory agency which has been authorized to grant
delisting petitions) to determine whether the waste should continue to be listed as hazardous.6
This determination is subject to notice and comment before a final decision is made.
U.S. Office of Management and Budget, Circular A-11, §210.11: "Preparation and Submission of Strategic
Plans," 1998.
§3001(f).
'The process is explained in regulations at 40 CFR 260.20 and 260.22, and in
Petitions to Delist Hazardous
Wastes: A Guidance Manual,
Office of Solid Waste, 1993.
« 5 »
To gain a better understanding of the operations of the delisting program, this study employed a
tool called a
program logic model.
A program logic model is a kind of input/output model of a
program's operations. Figure 1 presents a simplified logic model of the waste delisting program.
The steps in the delisting process are shown down the center of the diagram. These steps
represent
►
inputs,
►
outputs
(work processes and results), and
outcomes
(final results of the outputs)
of the delisting processes. In addition to these steps, the model also shows:
►
objectives:
desirable attributes of the process, outputs, or outcomes.
►
contextual variables:
factors exogeneous to the Agency's performance of outputs that can
affect the degree to which process objectives are successfully met.
The following is a description of the delisting program, using these terms of program logic.
INPUT:
Hazardous waste generators prepare petitions and send them to the EPA.
Process objective:
Ensure that generators are aware that a waste can be delisted if
they can demonstrate that it should not be regulated as a hazardous waste.
OUTPUT 1
Agency staff review the applications for completeness, according to criteria
in the delisting manual'.
Process objectives:
The review should be speedy; petitioners should not be left
waiting too long for a decision.
Contextual Variables:
The speed of the review and decision process is dependent
on a number of variables, including the complexity of the applications submitted,
time needed for the petitioner to submit additional materials, and the budget and
FTE time available for the task. Other factors outside of EPA control, which can
affect the degree of achievement of the objectives, include the nature and extent
of public comments on proposed delisting decisions, and any legal challenges that
might ensue.
OUTPUT 2
The next output is a decision to either reject or accept the delisting
petition; that is, the decision is to either retain the hazardous status of the waste, or give it
a new non-hazardous status. This initial decision is subject to notice and comment, and
then a final decision is reached and published.
7
USEPA Office of Solid Waste, "Petitions to Delist Hazardous Wastes: A Guidance Manual", March 1993.
« 6»
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Figure 1
Process objectives:
The decision should be supported by sound analysis, well-reasoned
and well-documented.
OUTCOME 1
From that decision follows the first
outcome
in the process: The waste is
either retained in Subtitle C regulation, or allowed to exit Subtitle C regulation.
Process objective:
Wastes that are allowed to exit Subtitle C regulation do not
pose significant risk to human health or the environment.
« 7»
Contextual Variables:
The risk assessment is sufficiently conservative to cover
actual post-delisting waste management. Management of delisted wastes should be
no more risky than the management scenarios assessed.
OUTCOME 2
If the waste is allowed to exit Subtitle C regulation, a secondary
outcome
follows: resources previously devoted to managing that waste as hazardous can be freed up
for other uses.
1.4 EVALUATION OF THE DELISTING PROGRAM
1.4.1 Why Evaluate the Delisting Program?
The delisting program has faced changes recently, which makes it a good candidate for
program evaluation. Among these changes:
►?
Responsibility for review of petitions and issuing decisions on delistings was delegated to
EPA's regional offices in October, 1995. Until that point, these functions had resided in
the Office of Solid Waste (at EPA headquarters) since the beginning of the program. This
change suggests that a process evaluation might be appropriate, comparing the
implementation of delisting by headquarters and regional offices.
In 2000, responsibility for national coordination of the delisting program was also
delegated from OSW, this time to the Region 6 delisting staff. This change in program
operations also tends to recommend a process evaluation.
In 1999, EPA proposed revisions to the "mixture" and "derived-from" rules, which provide
another way to remove low-risk wastes from Subtitle C regulation. EPA is also working on
a Hazardous Waste Identification Rule (HWIR), with regulatory standards identifying
wastes that are low-risk. This regulation, once fully implemented, will provide an
alternative means for industry to have these wastes removed from Subtitle C regulation.'
In light of this initiative, it seems reasonable to conclude that EPA should gain a better
understanding of the delisting program, in order to better understand how it might work
with HWIR. Will delisting be redundant? What roles will delisting and HWIR play, and
how can EPA use the tools together to get more effective environmental regulation?
8
See http://www.epa.gov/epaoswer/hazwaste/id/hwirwste/index.htm for more information on I-IWIR
and the mixture and derived-from rules.
« 8 »
What might be the best type of evaluation for the delisting program?
There are three basic types of program evaluations:
1) Formative
evaluations are conducted in the early stages of development (or implementation) of
a program. They are intended to get an early indication of any problems with the program, and
the likelihood of success.
2)
Process
evaluations focus on the operations and implementation of a program.
3)
Outcome
evaluations focus on the results, consequences, or products of a program.
The type of evaluation performed depends on the situation of the program, and the type of
information that will prove useful to program managers.
The delisting program, having been carried out for 20 years, is probably not a candidate for a
formative evaluation. The delegations of responsibility to Regional staff advanced the possibility
of a process evaluation, looking at changes in delisting functions and operations. A process
evaluation would also seem to be of limited usefulness, since EPA's Inspector General has recently
completed a study of the process and operations of the delisting program9.
After extensive consultation with managers and staff in both OSW and regional offices, OSW
decided that this evaluation would be most useful it if focused on the
outcomes
and
impacts
of the
federal delisting program.' Rather than focus on the mechanisms for conducting delistings,
therefore, this study examines how the program has functioned, and what has been gained by the
operation of the delisting program. This "big picture" focus also results in findings that provide
useful information for assessing the future direction and management of the delisting program.
There is a great deal to be learned through this evaluation. By examining the outcomes of the
program, EPA gains an understanding of what impacts the program has on industry, on waste
management, and on the economy overall. The evaluation also provides RCRA managers with
information to make decisions about the delisting program itself, and about interactions with
other deregulatory initiatives (e.g., HWIR). This information should be useful as EPA continues
working to tailor regulatory requirements to meet the risks addressed.
9
USEPA, Office of Inspector General, RCRA Hazardous Waste: RCRA Delisting of Hazardous Waste,
Report # El DSB7-11-002108700001, June 1998.
'Although some states are authorized to delist wastes, this evaluation focuses on EPA's
program.
« 9 »
1.4.2 What are the Outcomes and Impacts of the Delisting Program?
The principal outcomes of the delisting program are the cost savings and economic impacts that
result from shifting wastes from Subtitle C management to less stringent Subtitle D management
standards. This report looks at three different categories of outcomes of the delisting program:
►
Cost savings and aggregate economic impacts
►
Impacts of delisting on the environment
►
Impacts of delisting on the RCRA hazardous waste management program
The report also examines the distribution of these impacts, on different industries, geographic
areas, and types of businesses.
1.4.3 Is the Delisting Program Fulfilling Its Goals?
In many cases, an important part of an outcome evaluation is an assessment of the performance of
a program against some kind of standard. Is the program making good progress toward strategic
goals and objectives? Are there any deficiencies in performance because of program
implementation?
For the delisting program, this is not an easy question. The delisting program doesn't have
strategic
goals, in terms of what it hopes to accomplish in outcomes; EPA does not set targets, for
example, of numbers of wastes to be delisted each year. Goals are operational and process-oriented
(as in the process objectives noted in section 1.3), but driven by the receipt of applications, not
by strategic goals. It is difficult to set goals for an essentially reactive program, which aims at
processing applications as they are received.
An overall goal for federal regulatory operations, however, is to maximize regulatory efficiency.
To do that, EPA attempts to make sure that the burden placed on the regulated entities is no
heavier than necessary to achieve regulatory goals of protection of human health and the
environment.
11
To the extent that the delisting program is promoting efficient regulation and
efficient use of resources, it is meeting that overall goal of federal regulation. Section 2.2 measures
how well EPA is meeting that goal.
1.5 METHODOLOGY OF THE EVALUATION
The
evaluation question
asks:
What are the economic, environmental, and programmatic impacts of
delistings?
The
evaluation design
uses a simple "before-and-after" framework to assess what
changes have come about as a result of the delisting program. The evaluation design rests on the
assumption that without the delisting, the waste would continue to be generated and managed
under RCRA Subtitle C.
"See "Regulatory Planning and Review", Executive Order 12866, September 30, 1993.
« 10 »
1.5.1 Creating the Database
EPA assembled a database listing all the delisting applications granted by the EPA (not including
those granted by state governments) between calendar years 1980 and 1999. Some of the
information had been kept by the delisting program, either in paper files or in the Delisting
Petition Data Management System. This database had been discontinued in 1995. Other data
were taken from the
Federal Register
notices announcing each proposed and final delisting
granted.
Data elements in the current database include:
►
Name and address of petitioning facility
►
Date petition submitted and final decision reached
►
Date delisting became effective
►
Waste volume, matrix, form, quantity, and source
►
Chemical test results for wastes
►
RCRA waste codes
►
Management of wastes before and after delisting
1.5.2 Assessing the Data
Using the database, we calculated total volumes of waste delisted. These volumes were calculated
using the following assumptions:
- We assumed that savings from delisting begin to accrue in the year after the exclusion
takes effect. This likely results in understatement of savings, since there could be some
savings in the same year as the exemption is granted.
We assumed that waste generation in the absence of the delisting would have continued
indefinitely at the same quantities.' This may lead to overstatement of savings, since
companies may have ceased generating these wastes or may have implemented pollution
prevention measures to reduce the quantity of waste generated. Conversely, it could lead
to understatement, since increased production might have led to increased quantities of
the wastes being generated13.
'This assumption was not made for wastes which were given "one-time" standard exclusions. These
delistings are granted to a quantity of waste generated in the past, and are not applicable to any subsequent wastes
generated. We did not assume that these wastes were generated or delisted in any other year.
"This assumption is especially tricky with one of the wastes, granted to Conversion Systems,
Inc. for K061. There may be much larger amounts of K061 that have been delisted since the original
amount, since the delisting was predicated on a particular treatment regimen.
« 11 »
- We assumed that after delisting, generators manage their wastes as if they were Subtitle
D industrial wastes. However, there may be state requirements for management of these
wastes, even in the absence of being listed as hazardous waste. To the extent that such
requirements exist, the costs savings from delisting are overestimated.
Using data on unit costs of waste management under Subtitle C and Subtitle D, we also calculated
the total cost savings attributable to delistings, on an annual basis and cumulatively. Results of
the analysis are presented in Chapter Two.
« 1 2 »
CHAPTER TWO:
RESULTS OF THE EVALUATION
This chapter presents the results of the data analysis, and conclusions from the data. It includes
basic statistics on delistings, the economic and environmental impacts of delistings, and some data
on the distribution of those impacts.
All of these statistics refer only to the federal delisting program. Incorporating the results of state
delistings would lead to different results for most of these categories.
2.1 DESCRIPTIVE STATISTICS
Over the 20-year period from 1980 through 1999, delistings were granted to a total of 136
separate waste streams, generated at 115 separate facilities". Table 1 below gives an overview of
the individual waste streams delisted.
As-generated process wastes make up fewer than 15% of the waste streams; the majority were
treatment residuals and wastewaters. Wastewater treatment sludges alone account for more than
half the waste streams. Although only 4% of the waste streams were wastewaters, they are large
volume wastes. 36 of the streams (26%) of the waste streams were not part of an on-going
process, but only generated one time.
Table 2 shows the most frequent waste codes present in delisted wastes'. By far the most
common code is F006, found in 51 waste streams. F019, F003, K071, and F005 Were also quite
common.
Delisted K061 waste streams were quite large, averaging 81,600 tons each. K071 wastes, on the
other hand, averaged only 1,800 tons per year.
' 4
One delisting was granted and then later revoked, so there were actually 137 wastes delisted.
"The numbers of waste streams appear higher than in Table 1 because many wastes carry multiple codes.
« 13 »
Table 1
OVERVIEW OF DELISTED WASTE STREAMS
Total
Wastewater
Process
WWT
Other
Contaminate
Type
of Waste
s
Wastes
Sludges
Treatment
t
d Media
Residuals
F001-F005
21
3
6
6
6
-
Solvent Wastes
(15%)
F006,F009,F019
69
3
60
5
1
Electroplating
(51%)
Wastes
F020-F028
9
2
7
Dioxin Wastes
(7%)
K048,K051
3
1
1
1
Petroleum
(2%)
K060,K062
10
2
2
6
-
Steel
(7%)
K071,K106
12
8
1
3
-
Chlor-Alkali
(9%)
Miscell
12
1
-
4
6
1
(9%)
TOTAL
136
6
19
74
34
3
(100
%)
%
of Waste
100%
4%
14%
54%
25%
2%
Streams
« 14 »
Table 2
MOST FREQUENT WASTE CODES PRESENT IN DELISTED WASTES
W1 ,,
■?
,cle
No. of Streams
Average Size of Stream (tons)
F006
51
4,500
F019
34 5,400
F003
16
14,000
K071
13
1,800
F005
12
13,800*
K062
8
19,200
F020
7
1,500
F002
7
19,700*
K061
6 81,600
K002-K008
25,400
*Figures for F005 and F002 exclude the single outlier wastestream described below in section 2.1.1.
2.1.1 Total Quantities of Waste Delisted
The waste quantities discussed in the previous section only show generation in a single year. In
the absence of the delisting program, however, these wastes would have continued to have been
managed under Subtitle C management. For example, in 1985, a waste stream of sluiced bottom
ash sludges was delisted; this waste is generated at an annual rate of 19,100 tons. Using the
assumption of continuous generation (discussed in section 1.5.2), this analysis estimates that an
aggregate total of 286,500 tons of this particular waste stream had been taken out of subtitle C
management through 1999.
Cumulatively,
a total of 45 million tons of waste has been excluded from subtitle C
requirements.
Over 80% of that volume is wastewater, with 32 million tons attributed to one
waste stream at one facility."
"This stream, the single largest volume waste delisted, consisted of scrubber effluent wastewaters.
« 15 »
2.2 ECONOMIC IMPACTS OF THE DELISTING PROGRAM
The reduced social costs associated with the delisting program are derived through calculating the
administrative costs of operating the delisting program, and the offset of lowered costs of waste
treatment and disposal.
2.2.1 Administrative Costs
A total of 906 delisting petitions have been submitted to EPA between 1980 and 1999. Table 3
provides a breakdown of the disposition of those petitions — those which were granted, those
which were denied, and those which never completed the full review process.
Each delisting petition submitted to EPA incurs a cost to the petitioner (to gather the necessary
data and prepare the petition) and to the government (for review of the petition and analysis of
the data). For petitions that
are incomplete, or that never
complete the review process,
these costs are lower.
Table 3
DELISTLNG ACTIVITY, 1980-1999
ST T'US
NUMBER OF
PETITIONS
PERCENT OF
TOTAL
WITHDRAWN
503
56%
DENIED
108
12%
REFERRED TO STATE
32
4%
INCOMPLETE
/
IN PROCESS
122
13%
RULE-MAKING PETITION/
DISMISSED*
26
3%
GRANTED
115
13%
TOTAL
906
100%
*These petitions were all listed as "dismissed," indicating that the
Agency staff decided that the petition did not warrant fitrther review .
EPA has previously estimated
the recordkeeping burden for
a petitioner as well as the
burden to the government for
review of a delisting
petition. 17 This report
estimated that the cost to the
EPA for reviewing a petition is
approximately $28,000. The
report estimated the cost to a
petitioner at approximately
$82,000.
18
Because an earlier
report to EPA19
suggested that
petitions sometimes cost as
much as $100,000 or more, we
'Supporting Statement for EPA Information Collection Request Number 1189.05, Identification, Listing, and
Rulemaking Petitions,
16 January, 1998.
18
We assumed that a petitioner incurs all the costs of preparing a petition, even for those petitions which
were withdrawn or mooted.
"Industrial Economics, Inc. "Final Analysis of Delisting Program Policies and Procedures", 17 February
1992.
« 16 »
conducted a sensitivity analysis and estimated petitioners' costs using that per-petition cost
estimate, as well.
Finally, we calculated the net present value of the aggregate administrative costs by applying a
discount rate. Discounting reflects the time value of money, in that the value of a dollar lost in
future years is greater than a dollar, since the capacity to invest and earn extra income is also lost.
The discount rate represents the displaced investments and consumption that could have been
made in the absence of spending these funds on preparing and reviewing delisting petitions.
Table 4 presents the administrative costs of conducting the delisting program'. The total
administrative costs associated with this twenty year period of the delisting program ranges from
$107 million to $226 million. The costs to petitioners ranges is estimated to be 70-85% of that
total.
Table 4
, CUMULATIVE ADMINISTRATIVE COSTS OF DELISTING PROGRAM
(millions of dollars)
Government
Costs
Petitioner
Costs
Total
discount
mate''
2% discount
rate'
Low-End
22.14
74.01
96.15
112.93
107.15
High-End
22.14
148.02
170.15
225.86
189.55
2.2.2
Costs of Treatment and Disposal
The most obvious and significant impact of the delisting program is the reduction in the costs of
waste management. Waste management costs under RCRA Subtitle C (hazardous waste
standards) are usually significantly more expensive than waste management under RCRA Subtitle
D (non-hazardous waste standards). Where these wastes were being managed more stringently
than necessary, these additional costs of waste management represent an unnecessary cost to the
economy. In economic terms, this is referred to as a deadweight loss to the economy. By
reducing these unnecessary costs, the delisting program is restoring value to the economy. These
resources can now be devoted to producing valued goods and services.
20
Discount rates are used to adjust the raw costs for the time value of money; the present value of cost
savings is higher than the nominal value of those savings in prior years. Two different discount rates are used in the
table to render the costs comparable over the twenty-year period of the study. There is not a clear consensus on
the appropriate discount rate to use in a study like this; EPA guidance suggest using a lower rate of 2-3%,
representing the social rate of return on investments, and a sensitivity analysis using a higher rate of around 7%,
which tends to reflect returns to the private entities concerned (in this case, the firms paying waste management
costs). See USEPA,
Guidelinesfor Preparing Economic Analyses,
2000, Chapter 6.
« 17 »
Cost savings in treatment and disposal are determined by assessing the costs of treatment and
disposal for each waste stream for each year after the delisting became effective, under subtitle C
and under subtitle D. The analysis develops two scenarios: waste management in the baseline
scenario (with a delisting granted), and in a "without-delisting" scenario. Without delisting,
these wastes would have incurred the higher Subtitle C costs of treatment and disposal. The
difference between the costs in these two scenarios represent the cost savings in treatment and
disposal costs attributable to the delisting.
Waste Management Techniques
This requires first associating waste management techniques (treatment and disposal) under both
Subtitle D and Subtitle C. In many cases, these techniques were already specified in the delisting
petition or other records. In other cases (where not specified) customary practices under Subtitle
D were assumed for the waste streams. Unless other information was available, we assumed the
same disposal practice (e.g., surface impoundment, landfill, incineration) would be used pre- and
post-delisting.
Where not otherwise specified, required treatments under Subtitle C were assumed for pre-
delisting management. Land Disposal Restrictions (LDRs) typically required additional treatment
of wastes prior to land disposal, or encouraged a switch to an alternative technology. The
analysis takes the LDRs into account by assuming that treatment would be required prior to land
disposal once the relevant LDR took effect. If wastes were delisted prior to the effective date of
the relevant LDRs, we assumed (in the "without-delisting scenario") continuation of the existing
treatment up until that year, and then LDR requirements after that year. We identified the year
in which LDRs took effect based on the waste codes reported for each delisted waste stream The
earliest effective date was selected for wastes with multiple waste codes. For example, a waste that
included F005 in its list of waste codes was assigned an LDR effective date of 1986, even if other
waste codes reported for that waste stream had later LDR effective dates. In the absence of a
delisting, management under LDR standards was assumed to begin the year after the effective date
of the relevant LDR (e.g., the savings of avoided LDR management for a waste delisted in 1986
that includes F005 as a waste code were assumed to begin in 1987)21
Unit costs
Each type of waste treatment is likely to either increase the quantity of waste (e.g., waste
stabilization), decrease the quantity of waste (e.g., incineration), or have no appreciable effect
'The analysis assumes that cost savings begin the year after a delisting takes effect. For one-time delistings,
cost savings occur only in the year after the delisting takes effect. Because the delistings actually took effect earlier
than the following year, this assumption tends to understate the cost savings.
« 18 »
(e.g., neutralization). The residual factors shown in Table 1 indicate the residual quantity that
remains to be disposed of after treatment."
Estimates of the unit costs of different treatment and disposal technologies are taken mostly from
EPA's recent analysis of the proposed HWIR rule, and are reproduced in Table 5.2'
Table
5:
Quantity-Based Industrial
Hazardous
Waste Treatment and
Disposal Unit
Costs
Item
Waste Treatment
or Disposal
Nlethod
Residual
Factor'
s
470
tons/year
s 4,700-
_
tons/year
c 47,000
tons/year
s
470,000
tons/ ear
1
Deactivation
0.01
$820
$820
$200
$200
2
Liquid
Incineration
0.25
$301
$301
$301
$301
3
Neutralization
1.01
$270
$34
$4.48
$0.73
4
HTMR
0.0
$191
$191
$191
$191
5
Mercury Retort
1.0
$856
$856
$446
$194
6
Stabilization
1.5
$200
$150
$50
$23
7
Vitrification
1.5
$230
$230
$230
$230
8
Underground
Injection
$0
$0
$0
$0
9
Acid
Regeneration/
Recycling
$0
$0
$0
$0
10
Subtitle C
Disposal
$130
$130
$130
$57
11
Subtitle D
Disposal
$50
$50
$50
$50
(1999$ average cost per ton, depending on annual quantity treated by facility)
Source: U.S. EPA Office of Solid Waste, Economics, Methods,
&
Risk Assessment Division, Economic
Assessment of the USEPA's 1999 Proposed Hazardous Waste Identification Rule (HWIR), 29 October 1999
Exhibit IV-14.
'For example, stabilization results in an increase in the waste quantity to be disposed by a factor of 1.5.
23
11.S. EPA Office of Solid Waste, Economics, Methods, & Risk Assessment Division,
Economic Assessment of the USEPA's
1999 Proposed Hazardous Waste Identffication Rule (HWIR),
29 October 1999.
« 19>s
Other unit cost figures include:
Incineration':
Liquids (comparable fuels)
$70/ton
Liquids (highly contaminated) $301/ton
Sludges (less contaminated) $320/ton
Sludges (highly contaminated) $630/ton
Solids (less contaminated)
$683/ton
Solids (highly contaminated) $1281/ton
Upgrading from surface impoundments (Subtitle I)) to Subtitle C storage tanks':
$0.40 /ton
These unit costs largely derive from 1999 estimates. Although the unit costs are adjusted for
inflation for each year in which they are applied, this formula does assume that unit costs remain
approximately the same over the twenty-year period of the study. Anecdotal evidence suggests
that costs of hazardous waste management techniques have actually fallen at a more rapid pace
than inflation. Waste management costs from the 1980's were actually higher than current
prices, even in real terms. These inflation-adjusted cost savings are therefore probably an
underestimate.
Assessment of Total Cost Savings
Using the aforementioned data and assumptions, each waste stream is assigned a cost of
management post-delisting under Subtitle D (as actually required) and under Subtitle C (as
would have been required in the absence of the delisting). Cost savings (the difference between
the actual scenario and the hypothetical without-delisting scenario) were then calculated for each
post-delisting year through 2000 (the first delistings took effect in 1985). 26
'Unit costs for incineration taken from from Exhibit 3-1ofAssessment
of the Potential Costs, Benefits, &Other
Impacts of the Hazardous Waste Combustion MA CT Standards,
USEPA, Office of Solid Waste, July 1999.
25
Unit cost for storage tanks based on estimate of costs (capital costs plus annual operation and
maintenance) for high volumes of waste, assuming 30-day storage period. Source:
Regulatory Impact Analysis:
Application of Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes;
USEPA, Office of Solid
Waste, April 30, 1998. Exhibit F-14.
'It is generally the practice to convert all prices to 1999 dollars, to account for lower prices in earlier
years. This practice works with the general assumption that prices of the particular commodity follow general
trends of inflation. However, our data suggests that prices of hazardous waste treatment do not follow the general
trend of inflation; in fact, prices are lower (even in nominal terms) than they were in earlier years. Therefore, we
have assumed 1999 prices for all years of the evaluation. In practice, this probably means that we are understating
the cost savings.
« 20 »
Table 6
Cost Savings per Year
(individual years, not cumulative)
Year
Cost Savings
1985
$749,040
1986
$5,096,626
1987
$19,492,938
1988
$22,126,162
1989
$42,180,857
1990
$51,866,658
1991
$69,882,661
1992
$73,683,088
1993
$78,043,510
1994
$78,592,062
1995
$78,817,442
1996
$96,974,128
1997
$164,566,547
1998
$98,126,193
1999
$98,126,193
2000
$105,400,863
Cumulative Net
Present Value
at 7% discount rate
$2,490,052,373
Table 6 presents cost savings for each
year, as well as aggregate cost savings.
The cost savings that accrue in 2000
- $105.4 million — will continue to
accrue every year — even if no
further wastes are ever delisted'.
Additional delistings will increase the
total cost savings. From the inception
of the delisting program through the
year 2000,
cumulative gross cost
savings attributable to the delisting
program range between $1.36 billion
and $2.49 billion.28
These cost savings are probably
underestimated, because of cost
savings not included. Besides savings
in treatment and disposal costs, there
are other costs which may also be
saved. Specifically, we have not
accounted for
Potential savings in
transportation costs. This
omission tends to
underestimate the cost
savings. Not only is
transportation of non-
hazardous wastes less
expensive per mile, but it is
likely that these wastes would
be transported shorter
distances, inasmuch as
industrial waste disposal
facilities are more widespread
than permitted Subtitle C
disposal facilities.
'Based on the assumptions of continuous generation of equal volume of the waste.
'All cumulative costs in this analysis are presented in real terms, using year 2000 dollars.
« 21 »
Potential savings in administrative costs, such as compliance with manifest requirements.
For some facilities, delisting may have reduced or eliminated the burden of Subtitle C
permitting requirements; the cost savings in those cases are significant. We did not
collect data which would enable us to quantify these savings.
2.2.3 Net Cost Impacts
Section 2.2.1 discussed the costs of administering the program, while section 2.2.2 discussed the
cost savings resulting from the program. The cost impacts of the delisting program are presented
in Table 7. The cost savings in treatment and disposal costs overwhelm the administrative costs
of conducting the program by an order of magnitude. In summary, over the twenty-year period
examined,
the delisting program has resulted in a net cost savings to society in the range of
$1.17 billion to $2.38 billion.
Table
7
CUMULATIVE COSTS, COST SAVINGS, AND NET COST SAVINGS
(millions of dollars)
Discount
Rate
Admin. Costs,
Low-End
Admin.
Costs, High-
End
Treatment
&
Disposal
Cost Savings
Net Cost
Savings,
Low-End
Net Cost Savings,
High-End
7%
$112.93
$225.86
$2,490.05
$2,264.19
$2,377.12
2%
$107.05
$189.56
$1,357.57
$1,168.01
$1,250.52
2.3 ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM
A program evaluation should provide information that is useful to help manage the program; even
a retrospective evaluation (such as this one) can help guide the program into the future. EPA
staff who work on delisting were consistently interested in exploring the
environmental
consequences of the delisting program.
A basic premise of the delisting program (see the process objectives in the program logic model) is
that delisted wastes do not pose any significant threat to human health or the environment, even
when not managed under the strict guidelines of RCRA Subtitle C. This goal is accomplished
through chemical analysis and fate and transport modeling of wastes, prior to granting a delisting.
In order to be delisted, this analysis must demonstrate that the waste:
►?
Does not meet the criteria for which it was originally listed.
Does not exhibit any of the hazardous waste characteristics.
« 22»
Does not exhibit any
other
factors (including additional constituents) which might cause
the waste to be hazardous.
A delisting determination is based on reasonable worst-case scenarios, to ensure that there is no
reason that the waste should remain under RCRA Subtitle C regulation.
Are there delisted wastes that nevertheless might pose environmental problems? Unfortunately,
an environmental assessment of previously delisted wastes was beyond the scope of this program
evaluation. We are able, however, to provide some qualitative assessment of the environmental;
impacts of the delisting program.
2.3.1 Environmental Releases
In 1997, a delisting had to be revoked when EPA discovered that our risk assessment assumptions
did not fully capture the risk possibilities of a waste stream.
29
The waste which had its delisting
revoked posed a greater threat of release of constituents than EPA originally estimated. This re-
assessment occurred because the waste was managed in a more alkaline environment than the
landfill transport models anticipated, resulting in a different release profile. EPA has already
reviewed previously delistings to determine if this alkaline environment could be a similar problem
with other waste streams, and concluded that this was a problem unique to the chemical
characteristics of this waste stream.
What is the likelihood that other delisted wastes are producing environmental releases of
concern? The fate and transport models that have been used in the program use very protective
assumptions in projecting exposure to constituents. It would seem that the opportunities for
damage are probably limited to
Significant changes in the waste characterization (volume, constituents,
constituent concentrations) from that reported in the original petition. Waste
generators are supposed to notify EPA if such changes occur; EPA efforts to check
up on previously delisted wastes have been minimal, but have not discovered such
changes.
•
Situations, like the revoked delisting, where there is some undiscovered flaw in the
waste and risk assessment methodology.
The Agency is taking steps to limit the possibilities for harmful environmental releases in the
future, and to facilitate review of the consequences of disposal of delisted waste streams. In July,
1998, EPA established a
conditional delisting
policy, to ensure that delisted wastes are managed in a
manner consistent with the risk evaluation that supports the delisting decision. At the same time,
the Agency established a
delisting reopener
mechanism, for immediate response to new
"The exclusion for this waste stream, number ARD006354161, was repealed on December 1, 1997. For
information on the action, see the Federal Register notice at 62FR Number 14-7, July 31, 1997.
« 23 »
information or data indicating conditions exist that may alter the Agency's position on the
approval of a delisting.
Although improving environmental quality is not the primary rationale for the delisting program,
it may provide some improvement in environmental quality, as well. There is anecdotal evidence
that some facilities have engaged in extra treatment of their wastes (beyond what is legally
required) in order to reduce the toxicity of their wastes in order to become eligible for delisting.
This additional treatment would provide some additional protection against release of
constituents to the environment.
Delisting may provide other environmental benefits, as well. In their review of the delisting
process, EPA's Inspector General noted that some companies function with an "environmental
programs budget." When the costs of waste management decline, these companies have
redirected these funds into other environmental projects.
In summary, EPA does not have evidence of releases or lack of releases from delisted waste
streams. However, given a strict risk assessment process (which has been made progressively
more accurate), the Agency has little reason to believe that these streams are causing
environmental problems. The Agency has also put additional measures in place to reduce the
likelihood of releases.
2.3.2 Recycling
Delisting wastes may have an impact on recycling quantities. Although such impacts are not
relevant to the delisting decision itself — which is exclusively risk-based — it is worthwhile
examining how delisting has affected recycling.
To some extent, the high cost of hazardous waste treatment and disposal under Subtitle C has
provided an incentive for firms to recycle wastes and to recover resources from wastes.
Intuitively, therefore, it would seem that delisting — which reduces the cost of treatment and
disposal — might have a negative impact on hazardous waste recycling. One particular delisting
may have been very significant in inhibiting recycling. That delisting, granted in 1995,
exempted 306,000 tons of chemically-stabilized electric arc furnace (EAF) dust. According to an
industry study', over 85% of the EAF dust generated in the US had been recycled, primarily for
zinc recovery. Such recovery accounted for approximately 30% of domestic zinc production,
before the delisting action. This study suggested that the delisting would divert those wastes from
resource recovery into chemical stabilization followed by disposal in Subtitle D landfills. As of yet,
EPA has not formally assessed the impact of this delisting on zinc recovery from EAF dust wastes.
Although the current database contains information on pre-delisting and (planned) post-delisting
waste management, there is no clear indication of other wastes that have been diverted from
recycling to waste disposal.
30
Arthur D. Little, Inc., "Electric Arc Furnace Dust — 1993 Overview" (Cambridge, July 1993).
« 24 »
On the other hand, many waste generators have told EPA that the "stigma" associated with
hazardous wastes impedes recycling, since treaters and recyclers are often unwilling to acquire the
liabilities associated with handling hazardous waste. Delisting wastes, therefore, may
increase
quantities recycled. We have information on one case where delisting apparently promoted
waste recycling. The delisting allowed the facility to convert a 12,000 ton waste stream of lagoon
sludges to be used as fertilizer. Prior to the delisting, the wastes were being incinerated.
2.3.3 Opportunity Costs to EPA
Another way of looking at the cost of the delisting program is through the concept of
"opportunity cost", i.e., alternative uses for the resources consumed in running the delisting
program. In this sense, the cost of staff time spent on delisting is to view it as "other regulatory
work" that is forgone in order to work on delistings. If EPA could have used those resources for
an environmental protection program, what additional protection could they buy?
Administrative costs of the program over 20 years range between 107-226 million dollars. EPA's
expenditures probably represent no more than 15-30% of that total, or 16 to 68 million dollars. If
spent on other hazardous waste programs, that could have represented a certain number of facility
investigations, enforcement actions, permits, or other regulatory actions. Assuming those actions
would have led to some degree of improvement in environmental quality, EPA has forgone such
improvements. Those improvements, of course, could only come at the expense of the billions of
dollars in social costs that delisting has saved, but it is worthwhile to be aware of the budgetary
tradeoffs made.
2.4 DISTRIBUTION OF IMPACTS
In addition to looking at the aggregate cost savings attributable to the delisting program, we can
also examine the distribution of those impacts. What are the economic impacts on specific
industries or areas of the country?
2.4.1 Geography
Geographically, the most federal delistings have been granted in in the southeast and
midwest (28 delistings granted in each of EPA Regions 4 and 5). The states most affected are
►
Ohio (10)
►
New York (9)
►
Tennessee (9)
►
Indiana (8)
►
Pennsylvania (8)
►
Alabama (7)
►
Arkansas (7)
« 25 »
This represents only the distribution of EPA-granted delistings; 18 states have been
authorized to grant delistings on their own.31
2.4.2 Small Businesses
It has been suggested that smaller business are prevented from obtaining delistings because of the
the high cost of preparing a petition.' This report has shown, however, that the savings in waste
management costs readily make up for the administrative costs of preparing a petition. At least
10% (12 of the 115) of the generators who have received delistings are Small Quantity
Generators (or less). Although this is not a perfect proxy for business size, larger firms tend to be
larger quantity generators.
2.4.3 Industries Affected
We also reviewed the extent to which different industries have been impacted by the delisting
program. The following industries are of particular interest:
Plating and Metal Polishing/Coating: This industry has been a major beneficiary of
delisting, as F006 and F019 waste codes are the most common wastes to be delisted.
Chloralkali: This is a small industry, which only numbered about 20 firms overall in the
late 1980's. 12 wastestreams associated with this industry were delisted, related to 8 firms.
Blast Furnaces and Steel Mills: There were 12 delistings associated with this industry. At
least 1.5 million tons of K061 have been delisted, deriving from steel production at mills
using electric arc furnaces.
Pharmaceutical: Of the 45 million tons of waste delisted, 32 million tons are attributable
to one waste stream at a single pharmaceutical facility in the midwest. This waste,
consisting of scrubber effluents, is generated at a rate of nearly 3million tons per year.
Aluminum plating is another industry which received several delistings.
In general, the larger volume generators of hazardous wastes (e.g., chemical industry, metals) are
well represented in the set of delistings. One exception to this correlation, however, is the
petroleum industry; although a large generator of wastes, only 3 refineries got delistings. It is not
' I
The list of states fully or partially authorized to delist wastes is: New Jersey, Delaware, Kentucky, North
Carolina, Mississippi, Alabama, Georgia, Michigan, Illinois, Louisiana, Nebraska, North Dakota, South Dakota,
Wyoming, Utah, Colorado, Oregon, and Idaho.
'See USEPA, Office of Inspector General, RCRA
Hazardous Waste:
RCRA
Delisting of Hazardous Waste,
Report # El DSB7-11-002108700001, June 1998.
« 26 »
clear if there is a specific reason why this industry has not made more use of delistings. One
possibility is that there is either less variation among wastes in refineries, or the listing description
more precisely captures the hazardous nature of their wastes.
« 27 »
CHAPTER THREE:
RECOMMENDATIONS AND CONCLUSIONS
3.1 RECOMMENDATIONS
3.1.1 Regulatory Impacts Analysis
In reviewing Federal Register notices for delistings, we did not find any RIAs associated with these
regulatory actions. Often, these notices indicate that since the rules don't meet the criteria of
Executive Order 12866 (or predecessor applicable Executive Orders) as "significant regulatory
action", then "no assessment of costs and benefits is necessary."
Although such an assessment is not
required
by the Executive Order, it is often a good idea to
undertake such an assessment. It is always a good practice in making public policy to be aware of
the impacts of a regulatory action, whether required by Executive Order, or statute, or not at all.
This evaluation has demonstrated that such an analysis is particularly helpful for delistings, to
help understand the value of the program overall. As RCRA program management continues to
"fine tune" hazardous waste management requirements, assessing the impacts of delistings can be
valuable in the Agency's overall effort to better match risks with regulatory requirements.
3.1..2 Evaluation of the Listing Program
Delisting exists because our listing methodology captures a large category of wastes, and some
wastes are caught in the net which are not necessarily risky. The earliest EPA listings involved
risk assessment methodology which tended to be far more cautious than methodologies used
today. Therefore, it would seem, these early listings were more likely to have captured low-risk
wastes than the later listings, which used more precise and refined risk assessment methodology.
(Later risk assessments may been more conservative in some respects, especially in evaluating
indirect effects and ecological risks.) The methodology and results of this evaluation could be
very helpful in undertaking an evaluation of the hazardous waste listing program.
3.2 CONCLUSIONS
The findings of this evaluation distinctly demonstrate the significant economic impacts of the
delisting program: reductions in deadweight loss to the economy totaling over $100 million each
year. Continued efficiencies and refinements in the delisting petition review process should only
improve those results.
The environmental impacts are not as clear, although EPA does not have reason to suspect that
delisted wastes are causing environmental problems.
« 28 »
As one of the first program evaluations undertaken by the RCRA program in response to GPRA,
there is also clear value to this evaluation study itself. Not only has it helped the RCRA program
understand the process of program evaluation, it has also helped us understand the nature of the
"value" of a program. This evaluation have demonstrated that benefits can take many forms, not
just risk reduction. A program like delisting demonstrates its value in terms of reduction in
economic losses, and concomitant improvement in human welfare.
The delisting program has also helped refine standards for the RCRA hazardous waste
management program itself, by providing information and feedback on our listing descriptions.
Information received in delisting petitions has helped the Agency refine the "listing description",
that is, the characterization of the hazardous nature of a class of industrial wastes.
« 29»
Heritage Environmental Services LLC Delisting
\ 7704 PDC \ 01 DELISTING PETITION SUBMITTAL \ ATTACHMENT 4\ 02 HERITAGE.DOC 08/05/08
Excerpt from Nucor Steel
K061 exclusion from Table 2 – Wastes Excluded From
Specific Sources; 40 CFR Appendix IX to Part 261
Heritage Environmental Services, LLC, at the Nucor Steel facility
Crawfordsville, Indiana
Electric arc furnace dust (EAFD) that has been generated by Nucor Steel at its Crawfordsville,
Indiana facility and treated on site by Heritage Environmental Services, LLC (Heritage) at a
maximum annual rate of 30,000 cubic yards per year and disposed of in a Subtitle D landfill
which has groundwater monitoring, after January 15, 2002.
(1)
Delisting Levels:
(A)
The constituent concentrations measured in either of the extracts specified in Paragraph (2)
may not exceed the following levels (mg/L): Antimony-0.206; Arsenic-0.0936; Barium-55.7;
Beryllium-0.416; Cadmium-0.15; Chromium (total)-1.55; Lead-5.0; Mercury-0.149; Nickel-
28.30; Selenium-0.58; Silver-3.84; Thallium-0.088; Vanadium-21.1; Zinc-280.0.
(B)
Total mercury may not exceed 1 mg/kg.
(2)
Verification Testing:
On a monthly basis, Heritage or Nucor must analyze two samples of the
waste using the TCLP, SW-846 Method 1311, with an extraction fluid of pH 12 ±0.05 standard
units and for the mercury deteiminative analysis of the leachate using an appropriate method.
The constituent concentrations measured must be less than the delisting levels established in
Paragraph (1).
(3)
Changes in Operating Conditions:
If Nucor significantly changes the manufacturing process
or chemicals used in the manufacturing process or Heritage significantly changes the treatment
process or the chemicals used in the treatment process, Heritage or Nucor must notify the EPA of
the changes in writing. Heritage and Nucor must handle wastes generated after the process
change as hazardous until Heritage or Nucor has demonstrated that the wastes continue to meet
the delisting levels set forth in Paragraph (1) and that no new hazardous constituents listed in
Appendix VIII of Part 261 have been introduced and Heritage and Nucor have received written
approval from EPA.
(4)
Data Submittals:
Heritage must submit the data obtained through monthly verification testing
or as required by other conditions of this rule to U.S. EPA Region 5, Waste Management Branch
(DW-8J), 77 W. Jackson Blvd., Chicago, IL 60604 by February 1 of each calendar year for the
prior calendar year. Heritage or Nucor must compile, summarize, and maintain on site for a
minimum of five years records of operating conditions and analytical data. Heritage or Nucor
must make these records available for inspection. All data must be accompanied by a signed
copy of the certification statement in 40 CFR 260.22(i)(12).
P:\7709 PDC \ 01 DELISTING \ PETITION SUBMITTAL \ ATTACHMENT 4\ 02 HERITAGE.DOC 08)05/08
(5)
Reopener Language:
(A)
If, anytime after disposal of the delisted waste, Heritage or Nucor possesses or is otherwise
made aware of any data (including but not limited to leachate data or groundwater monitoring
data) relevant to the delisted waste indicating that any constituent identified in Paragraph (1) is at
a level in the leachate higher than the delisting level established in Paragraph (1), or is at a level
in the groundwater higher than the maximum allowable point of exposure concentration
predicted by the CMTP model, then Heritage or Nucor must report such data, in writing, to the
Regional Administrator within 10 days of first possessing or being made aware of that data.
(B)
Based on the information described in paragraph (5)(A) and any other information received
from any source, the Regional Administrator will make a preliminary determination as to
whether the reported information requires Agency action to protect human health or the
environment. Further action may include suspending, or revoking the exclusion, or other
appropriate response necessary to protect human health and the environment.
(C)
If the Regional Administrator determines that the reported information does require Agency
action, the Regional Administrator will notify Heritage and Nucor in writing of the actions the
Regional Administrator believes are necessary to protect human health and the environment. The
notice shall include a statement of the proposed action and a statement providing Heritage and
Nucor with an opportunity to present information as to why the proposed Agency action is not
necessary or to suggest an alternative action. Heritage and Nucor shall have 30 days from the
date of the Regional Administrator's notice to present the information.
(D)
If after 30 days Heritage or Nucor presents no further information, the Regional
Administrator will issue a final written determination describing the Agency actions that are
necessary to protect human health.or the environment. Any required action described in the
Regional Administrator's determination shall become effective immediately, unless the Regional
Administrator provides otherwise.
P: \ 7704 PDC \ 01 DELISTING \ PETTTION SUBMITTAL\ ATTACHMENT 4 \ 02 HERITAGE.DOC 08/05/08
Conversion Systems Inc. (CSI) Delisting
P: \7704 PDC \ 01 DELISTING \ PETITION SUBMITTAL \ ATTACHMENT 4 \ 03 CSI.DOC 08/05/08
Excerpt from CSI K061 exclusion at Northwestern Steel in Sterling, IL
from Table 2
–
Wastes Excluded From Specific Sources; 40
CFR Appendix IX to
Part 261
Conversion Systems, Inc.
Horsham, Pennsylvania
Chemically Stabilized Electric Arc Furnace Dust (CSEAFD) that is generated by Conversion
Systems, Inc. (CSI) (using the Super Detox
TM
treatment process as modified by CSI to treat
EAFD (EPA Hazardous Waste No. K061)) at the following sites and that is disposed of in
Subtitle D landfills:
Northwestern Steel, Sterling, Illinois after June 13, 1995.
CSI must implement a testing program for each site that meets the following conditions for the
exclusion to be valid:
(1)
Verification Testing Requirements:
Sample collection and analyses, including quality control
procedures, must be performed using appropriate methods. As applicable to the method-defined
parameters of concern, analyses requiring the use of SW-846 methods incorporated by reference
in 40 CFR 260.11 must be used without substitution. As applicable, the SW-846 methods might
include Methods 0010, 0011, 0020, 0023A, 0030, 0031, 0040, 0050, 0051, 0060, 0061, 1010A,
1020B, 1110A, 1310B, 1311, 1312, 1320, 1330A, 9010C, 9012B, 9040C, 9045D, 9060A, 9070A
(uses EPA Method 1664, Rev. A), 9071B, and 9095B.
(A)
Initial Verification Testing:
During the first 20 operating days of full-scale operation of a
newly constructed Super Detox
TM
treatment facility, CSI must analyze a minimum of four (4)
composite samples of CSEAFD representative of the full 20-day period. Composites must be
comprised of representative samples collected from every batch generated. The CSEAFD
samples must be analyzed for the constituents listed in Condition (3). CSI must report the
operational and analytical test data, including quality control information, obtained during this
initial period no later than 60 days after the generation of the first batch of CSEAFD.
(B)
Addition of New Super Detox
TM
Treatment Facilities to Exclusion:
If the Agency's review of
the data obtained during initial verification testing indicates that the CSEAFD generated by a
specific Super Detox
TM
treatment facility consistently meets the delisting levels specified in
Condition (3)„ the Agency will publish a notice adding to this exclusion the location of the new
Super Detox
im
treatment facility and the name of the steel mill contracting CSI's services. If the
Agency's review of the data obtained during initial verification testing indicates that the
CSEAFD generated by a specific Super Detox
TM
treatment facility fails to consistently meet the
conditions of the exclusion, the Agency will not publish the notice adding the new facility.
(C)
Subsequent Verification Testing:
For the Sterling, Illinois facility and any new facility
subsequently added to CSI's conditional multiple-site exclusion, CSI must collect and analyze at
least one composite sample of CSEAFD each month. The composite samples must be composed
P:\ 7704 PDC \ 01 DELISTING \ PETITION SUBMITTAL \ ATTACHMENT 4 \ 03 CSI.DOC 08/05/08
of representative samples collected from all batches treated in each month. These monthly
representative samples must be analyzed, prior to the disposal of the CSEAFD, for the
constituents listed in Condition (3). CSI may, at its discretion, analyze composite samples
gathered more frequently to demonstrate that smaller batches of waste are nonhazardous.
(2)
Waste Holding and Handling.'
CSI must store as hazardous all CSEAFD generated until
verification testing as specified in Conditions (1)(A) and (1)(C), as appropriate, is completed and
valid analyses demonstrate that Condition (3) is satisfied. If the levels of constituents measured
in the samples of CSEAFD do not exceed the levels set forth in Condition (3), then the CSEAFD
is non-hazardous and may be disposed of in Subtitle D landfills. If constituent levels in a sample
exceed any of the delisting levels set in Condition (3), the CSEAFD generated during the time
period corresponding to this sample must be retreated until it meets these levels, or managed and
disposed of in accordance with Subtitle C of RCRA. CSEAFD generated by a new CSI treatment
facility must be managed as a hazardous waste prior to the addition of the name and location of
the facility to the exclusion. After addition of the new facility to the exclusion, CSEAFD
generated during the verification testing in Condition (1)(A) is also non-hazardous, if the
delisting levels in Condition (3) are satisfied.
(3)
Delisting Levels:
All leachable concentrations for those metals must not exceed the following
levels (ppm): Antimony-0.06; arsenic-0.50; barium-7.6; beryllium-0.010; cadmium-0.050;
chromium-0.33; lead-0.15; mercury-0.009; nickel-1; selenium-0.16; silver-0.30; thallium-0.020;
vanadium-2; and zinc-70. Metal concentrations must be measured in the waste leachate by the
method specified in 40 CFR 261.24.
(4)
Changes in Operating Conditions:
After initiating subsequent testing as described in
Condition (1)(C), if CSI significantly changes the stabilization process established under
Condition (1) (e.g., use of new stabilization reagents), CSI must notify the Agency in writing.
After written approval by EPA, CSI may handle CSEAFD wastes generated from the new
process as non-hazardous, if the wastes meet the delisting levels set in Condition (3).
(5)
Data Submittals:
At least one month prior to operation of a new Super DetoxTMtreatment
facility, CSI must notify, in writing, the Chief of the Waste Identification Branch (see address
below) when the Super Detox
Tm
treatment facility is scheduled to be on-line. The data obtained
through Condition (1)(A) must be submitted to the Branch Chief of the Waste Identification
Branch, OSW (Mail Code 5304), U.S. EPA, 1200 Pennsylvania Ave., NW., Washington, DC
20460 within the time period specified. Records of operating conditions and analytical data from
Condition (1) must be compiled, summarized, and maintained on site for a minimum of five
years. These records and data must be furnished upon request by EPA, or the State in which the
CSI facility is located, and made available for inspection. Failure to submit the required data
within the specified time period or maintain the required records on site for the specified time
will be considered by EPA, at its discretion, sufficient basis to revoke the exclusion to the extent
directed by EPA. All data must be accompanied by a signed copy of the following certification
statement to attest to the truth and accuracy of the data submitted:
Under civil and criminal penalty of law for the making or submission of false or fraudulent
statements or representations (pursuant to the applicable provisions of the Federal Code, which
\ 7704 PDC \ 01 DELISTING \ PETITION SUBMITTAL \ ATTACHMENT 4 \ 03 CSI.DOC 08/05/08
include, but may not be limited to, 18 U.S.C. 1001 and 42 U.S.C. 6928), I certify that the
information contained in or accompanying this document is true, accurate and complete.
As to the (those) identified section(s) of this document for which I cannot personally verify its
(their) truth and accuracy, I certify as the company official having supervisory responsibility for
the persons who, acting under my direct instructions, made the verification that this information
is true, accurate and complete.
In the event that any of this information is determined by EPA in its sole discretion to be false,
inaccurate or incomplete, and upon conveyance of this fact to the company, I recognize and
agree that this exclusion of waste will be void as if it never had effect or to the extent directed by
EPA and that the company will be liable for any actions taken in contravention of the company's
RCRA and CERCLA obligations premised upon the company's reliance on the void exclusion.
\ 7704 PDC \ 01 DELISTING \ PETITION SUBMITTAL \ ATTACHMENT 4 \ 03 CSI.DOC 08/05/08
Attachment 5
Pace Analytical Corrected Raw Laboratory Data Reports
NOTE:
Attachment 5 to the original Response is filed separately, as it is voluminous.
Copies of the Response include CD-ROMs in lieu of paper versions of Attachment 5.
Attachment 6
Requested DRAS v.2 Run Data Sheets
Site and WMU Information
Delistinq Petition Number:
DL-
File Name:
Updated DRAS 2-19-08, Max values used
Petitioner's Name:
Peoria Disposal Company
Address 1:
4349 W. Southport Road
Address 2:
City, State:
Peoria,
Zip Code:
61615
Analysis Performed by:
RMT Inc.
Date of Analysis:
Feb-19-2008
Waste Description:
EAF Dust Stabilized Residue
Waste Code:
K061
WMU Type:
Landfill
Waste Volume (yd3):
95000
Active Life (years):
20
Risk Factor:
1.00E-06
HQ Factor:
1.00E+00
Select Chemicals of Concern to be Modeled (Steps 4 5)
Chemical Name
CAS Number
TCLP
Concentration
(mg/L)
TCLP
Detection
Limit
Total
Concentration
(mg/kg)
Total
Detection
Limit
Maximum
Contaminant
Level (MCL)
(mg/L)
Carcinogenic
Slope
Factor -
Oral (CSFo)
(kg-day/mg)
Carcinogenic Slope
Factor -
Inhalation
(CSFi) (kg-day/mg)
Reference
Dose - Oral.:
(RFD())
(mg/kg-day)
0.00E+00
TCDD, 2,3,7 8-
1746-01-6
0.00E+00
2.10E-04
0'.00E+00
3.00E-08
1,50E+05
1.50E+05
0.00E+00
00
Chloro-3-methylphenO1
A
59-50-7
3.85E-04
0.00E+00
7.70E-03
0.00E+00
•?
0.00E+00. •
0.00E+00
0.00E+00
0.00E+00
■
Acenaphthene
83-32 9
1.15E-04-
0:0-0E+00
2.30E-03
0:00E+00
o.poEtoo
o.00E+bo
0.00E+00
5.00E-02
Copper
.8.00E+01.
0:00E+00
1.60E+03
0.00E+00
1.30E+00
0.00E+00
0.00E+00
4.00E-02
Selenium
7782-49-2
3.80E-02
0.00E+00
9.00E+01
0.00E+00
5.00E-02
0,00E+00
0.00E+00
5:00E-03
Acenapthylene
208-96-8
5.50E704.
0.00E+00.:.;
.1.10E702
0.00E+00
0.00E+00
0:00E+00
0.00E+00
0:00E+00
0017:i
Zinc
7440-66-6.
4.10E+00
0.00E+00
1.20E+05
0000E+00
0.00E+00:
0.00E+00
0.00E+00
3.00E-01
Fluorene
.
86-1377.
4.65E-04-•
0.00E+00
9.30E-03
•
0.00E+90'
0.00E+00
0:00E+00
0.00E+00
4.00E-02
0.00E+0C.
nitroariiline 2-
88-74-4.
79:50E:04
0.00E+00
1.90E-02
0.00E+00
0.00E+00
0.00E+00
OME+00
3.00E-03
0.00E+00
Pyridine
1.1•0f86-1
1 05E-03
0.00E+00
2.1 OE-02
0.00E+00
0.00E+00
0.00E+00
0.00E+00
1.00E-03
icK
el
)0E+00
Bis(2-ethylhexyl)phthatai
117-81.-7
1.70E-02
pLoE+oo
3.40E-01
.0.00E+00
6.00E-03
1.40E-02
1.40E-02
2.00E-02
Results for Analysis: Updated DRAS 2-19-08,
Max values used?
01
Select Chemicals of Concern to be Modeled (Steps 4
Reference.
Dose -
Inhalation
(RFC)
(mg/al')
Bio- concentration
Factor
(BCF) (Lfkg)
Soil Saturation
Level
(SO(LSAT)
(mg/kg)
Toxicity
Characteristic
Level (TC)
(mg/L}
Henry's Law
Coefficient (H)
(atm-m'imol-K)
Diffusion
Coefficient
in
Water (Dw)
(cm?/sec)
Diffusion
Coefficient in
Air
(Da)
(cm2/sec)
Solubility
(SOL) (Mg/L)
Landfill
Dilution
Attenuation
Factor
(DAFLF)
Surface Impoundment
Dilution Attenuation
Factor (DAFSI)
•
0.00E+00
0:00E+00
.
0.00E+00
0.00E+00
,.
1:60E-05
.
'6.81E-06
1.27E-02
1.93E-05
1.80E+01
1:90E+04
)7:
+ -
'
'---+?
.at.:E
)
•).
, 03
ff.00E+00
1.34E+02
0-00E+00
0.00E+00
2.50E-06
8.06E-06
6.96E-02
3:8'5E+03
1:80E+01
0:00E+00
E
.■?
+...0.-74..
:
).
u2
1, 20E4-04
6:00E-.02
6.07E+02
1..80E+02
0.00E+00
: 7A0E05
'7.19E06
4.21E02
3 80E+00
1.90E+0
4.50E+01
0.00E-:-
.
0.00E,00
0 008'1-00
0.
00E+00
5 C.
-
" 8.1::
,)!--
•
:N.
?
4;1
0
0.00E+00
1.00E+00
0.00E+00
0.00E+00
.0.00E+00
8.00E:06
8.00E-02
0.00E+00
7.01E+03
2:79E+03
+
00
'
.? 33P--
,
J4
F.+0(.;
':1E..,:-
:17
,,
,.
,:-..
'0.00E+00
'1.29E+02
0.00E+00
1.00E+00
0.00E+00
1.20E-05
1.03E-01
0.00E+00
1.16E+01
4.60E+00
0
-
:00E+00
1.00E+00
0.00E+00
0,00E+00
829E05
7.53E-06,•4.39E
Q2
3.93E+00
1.80E+01
0.00E+00
''
-
;:::"1.7,,
)
L
'''•02
0 00E-00
',.!.2i-01
`,.,..:,:
0.00E+00`;?:,
0.00E+00
•
0.00E+00
0.00E+00.
1.36E-05`,
1".17E-01
0.00E+00
2A9E+01
9.90E+00"
C' 00E+00j
.
02
0 00E+00
5 00
0 )
0 00E+00
8 00E-06
8
11-
,
8,
4.00E-02
0.00E+00
.9.00E+01
0.00E+00
7.30E05
7.88E06
3.63E02
1
98E+00
1.90E+01
6A0E+01
0.00E+'00
+r3
1.00E+'02
:,.
3.
.,
r.;
r
1
,
,
3
'
'',
.
I
5 c .:,8
?
'
HE '?
, ',
1
?
8..E+01
.08+01
3.00E-05
1.50E+01-- .
.0:00E+00
0.00E+00
:8.79E08
8.00E-06
7.30E02
2.94E+02
1.80E+01
0.00E+00
60E
3`-
0.00E+00:
0.00E+00
5.00E+00
: 6.86E03
1.08E05
9110E-02
1.00E+06
1.90E+01
3.90E+00
•
.?
.,?
,,,..,.,
•
).,+
i' OC;C:-
.: CA)
0.00,..-
2; 0
. „?
)
,.4.0L-.?
.,'
'
26E?
' '
,-,.:,')
,
.50E+01
2.00E-02
120E+02
3.10E+04
0.00E+00
1.10E-07
4.22E-06
1.32E-02
3.34E-01
1
90E+0
2.10E+05
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
o
Select Chemicals of Concern to be Modeled (Steps 4
::Time
to
reach
steady
state
(T1
(hrs)
Skin
Permeability
Coefficient
(KplaV) .
:(CM/nr)
Tau (T) (hrs)
Bunge
Coefficient (B)
(unitless)
Organic/
Inorganic
Bio- accumulation
Factor (BAF) (Ukg)
Chronic
Ecological
Threshhoid
(Aquatic TRV)
{mg/L)
Capcinogen/ ,
Noncarcinogen ,
'
Molecular
Weight
(MW)
(gm/mol)
Vapor
Pressure (Vp)
(atm)
Surface Water
Partition
Coefficient
(Kdsw) (L/kg)
1.1 OE--
3 80E+01
1.40E+00
. 8:10E+00
6.30E+02 ,
100E+00 :
9.15E+05
3.00E-08
. Carcinogen
3:22E+02
9,74E13
2.02E+05
:
?
CX)E-;
?
1
2 20E
:., f)0E10
.,
1 NE
.
10, :'
1
2.
:?
..-;
o.p0E+00
4.09E-02
6:50E-01 :
: 126E-01
1.00E+00
1.00E+00
0:.00E+00
Noncarcinogen
1.43E+02
1.08E05
2.78E+02
1
?
!-L
,
DE :
6:00E+00
:
:130E01
7.60E.01
-8.•:30E-01
1.00E+00 :
1.00E+00 :.
1 70E02
, .
Noncarcinogen
1.54E+02
4:93E06
167E4-02.
•:.F..7:77-+-
13?
; 4
1-E
-r!'
1
.1&
?
u •
r:: +0
:.:
'
0.00E '17
,oreinogen
O2
+00
0.00E+00
1:00E-03
:..0.00E±00
0.00E+00
0;00E+00
'1.003+00
9.00&03
Noncarcinogen
6.36E+01
0.00E+00
2.20E±01
7 90E-01
:? 30E-0
. t
. .
-0
1 .00E+1";::
1 00E+00
,?
,.
•
0,00E+00
1..00E-03
0.00E+00 •
":0.003+00
0.00E+00.
.
1.00E+00
5.00E.,01
•
Nonc.arcinogen
7,90E+01
0.00E+00
,4.30E+00
1.433 •
.?:Y:
...•7-02
F
.
cf
.,:i
c
623E+00
1.55E01
7.42E01.
1.00E+00
l 00E+00 .
1
.-ooptoo
0.00E+00
Noncarcinogen
1:52E+02
, 0.00E+00
?
::
0.00E+00
0.00E+00
100E-03
0.00E+00.
0:00E+00
'?
0300E+00:
'1.00E+00
1320E01 :
Noncarcinogen
,-.
6.54E+01'
0.00E+00:
6.20E+00
,..)?
■
:'OFF
?
[.;:
:,:
?
;••:)E.1,,::c:
...
5.40E+00
:1380E-01 :
9300E01
1.60Et00
1.00E+00
8.90E+01
4.00E-03 .,
Noncarcinogen
1.66E+02
8.17E-07
i?
5.78E+02
i::OF.-7..i
:?
.,...k.
C
arcinogen
2 fi
c.:17.
?
'i2
1:46E+00:
5.03E-03:
6.09E01 1.
6:03E-03
1.00E+00
1.00E+00
0300E+00
Noncarcinogen
1.38E+02
1.07E05
2.95E+00
2.40E
7 52
I
017 01
:
,.:::.:ncan,..?
.
L.,.
$.40E01
1.90E-03
2370E701
4.70E04
1.00E+00
1.00E+00
0:00E+00
Noncarcinogen
7.9'1E+01?
.
2 ;60E02
.3.54301
.:?
;.
?
L-
E+:?:.:
:1+00
1
?
[?
■?,
5.P. ',
1
.
00E+02
3.30E02•
2;10E+01
130E+01
1.00E+0
1 .00E+00
.:
3320E=02'
Carcinogen
: 3.91E+02
BA9E09
8.32E+03
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
1
Select Chemicals of Concern to be Modeled (Steps 4 5
Chemical Name
CAS
Number
TCLP
TCLP
Total
Total
Maximum
Carcinogenic Slope
Carcinogenic Slope
Reference
Concentration
Detection
Concentration
Detection
Contaminant
Factor - Oral (CSFo)
Factor - Inhalation
Dose -
Oral
(mg/L)
Limit
{mg/kg)
Limit
Level (MCL)
(k9-darling)
(CSFi) {kg-day/mg)
(RFDo)
(mg/L)
(mg/kg-day)
1-buty: pn, alats
Phanantbrane.
85-.01-8
2.75E-03
0.00E+00
5.50E702
0:00E+00
0,00E+00
0.00E+00
0.00E+00
0:00E4:00
C:Dr)al:
:•:1.00E.:1-•00
Chrysene:
218-01'::9
1:65E-03
0.00E+00
P,e117.1o(a':p‘ir
2,•,57
saai
3.30E-02
:0.00E4;00
0.00E+00
7.30E-03
3.10E-03
?
0100E+00'
00E+OC1
3.1
95-95-4
3.85E-04
0.00E+00
7:70E-03
0.00Et00
0.00E+00
0.00E+00
•OME+00
1.00E01
3.60E-01
0.00E+00
9.
3
0E.
Diethyl phthalate
84-66-2
?
2.85E-04
0.00E+00
5.70E03,
0.00E+00 .,
0.00E+00
8.00E-01
0.00E+011
1.00E+01
0.00E+00
2.00E=03
0.00E+00
2.00E-01
1.00E04
0.r20:.:?
•
4.90E-03
• •2:00E02::
0.00E+00
3.00E-01
0.00E+00
8.00E-02
Diniethyl phthalate
.2.30E-03
li?
(::1
13141:3
1.15E-04
0.00E+00
:0.00E+00.
0,00E1700
0.00E+00
.00E.
1326‘1+9
4.0.0E-04
0-.00E+00
8.00E-03
-0.00Et00
0.00E+00?0.00E+00
Fiticraniti&m,?
113Litylbenzylptithalate
0.00E+00?
2.70E-02,
1.50E+00
:•0.00E+.03,,
-•?
.•-••
85-68-7
1:35E-03
0.00E+00
0.00E+00
C 00F
0.00E+00
00
0 0,1'F
2.00E-03'.
?
0.00E+00
0.00E
4 :JC
••
?
4.90E03 •
Mercury
0.00E+00
3,:;r1zo ighi) peryl(-,;ne.
24-2
00E
N-Nitrosodiphenylamine
0.00E+00 ?
3.30E-03
0.00E+00
;ic'•F1-0;
_penzYl alcoho
100-51-6
5.00E-04
?
0.00E+00
?
1.00E-02
0.00E+00
0.00E+00
Toluene
108788.3
3.75E-04
0.06E4:10
7.50E,03.
0.00E00
:00E+00
0 00E+00
Results for Analysis: Updated DRAS 2-19-08, Max values used
02
Select Chemicals of Concern to be Modeled (Steps 4 5)
r
Reference
Bio-
concentration
Soil Saturation
Toxicity
Henry's Law
Diffusion
Diffusion
Solubility
Landfill
Surface Impoundment
Dose -
Factor (BCF) (Ukg)
Level
Characteristic
Coefficient (H)
Coefficient in Coefficient in
SOL) (mgIL)
Dilution
Dilution Attenuation
Inhalation
(SOILSAT)
Level (TC)
(atm-m3
/mol-K)
Water (Dw)
Air (Da)
Attenuation
Factor (DAFSI)
?
.
(RFC) (mg/m')
(mg/kg)
(mg/L)
(cm'/sec)
(crnzisec)
Factor
(DAFLF)
ODE
-
(2:00E+00
0.00E+00
0600E+00'• .?
0600E+00
4.23E-05?
7.47E-06
3.33E-02?
1.28E+00
1.80E+01
0:00E+00
5.00E+0 )
0.00E+00
1.03E+01.
2.00E+03.
d.boEi-oo
1.01E-07
7.13E:06
2.96E-02
4.00E+03
1.80E+01
0.00E+00
0.00E
(;C:E
2.00E-03
1.00E+00
c1.00.-Foo
1.05E-04
8:00E06
8 00E-02
0.00E+00
1.80E+01
0:00E+00
4
()01::-
0
-
.2.00E
-03
0.00E+00
9.30E+02.
0.00E+00
1,91E06
5.17E06
1.65E-02
2.69E+00
2.00E+01
1.30E+02.
0.00Eq.00
8.60E05
0.00E+00
0.00E+00
2.00E-01
7.10E-03
3.01E-05
1.09E-02
5.62E-02
7.45E+01
2.96E+01
0
nric::+
ir'.
JOE.
03F
5.26E-.
IF-02_
2.,0E 0'
2.00E-02
1618E+02:.
•
?
.0:00E+op..
0.00E+00
9,84E-07
6.35E-06
'3.12E-02
1.80E+01
1.00E+01
.)0E+00
0 00E+OG
I?
'::::";E÷C:1
3X10E-01
4.04E+00
0:00E+00-
0:00E+00'
••3.78E-07.
:938E7-06
6.89E-02
4.00E+04
1.90E+01
3.90E+00
c;
-00
+C.?1
1.43E+00
.627E+01
5.20E+02
•?0.00E+00
6.13E-03.
.-8:23E-06
9.72E-02?
5.26E+02
1.90E4-01
5.90E+00
0.00E+00-
0:o0Etpp.
0.00E+00
0.00E+00
5.14E+02 .•
0.00E+00
..3:80E+00
0.000()-
I:90E+03 ".
0.00E+00
-Jr
4.00E+02
0.00E+00
5:64E06:
5.48E07
1.21E-06
-7:03E06
.6.21E-06
6.35E-06.
2.48E-02
2.91E-02
2.56E-02
1.08E+03
?
2.30E+01
1.60E-03
?
1.90E01-
1.60E+03
6.20E+00
1.20E+03
1.10E+01
?
1.90E+01
Results for Analysis: Updated DRAS
2-19-08, Max values used
Select Chemicals of Concern to be Modeled (Steps 4 5
Time to reach
Skin
Tau (T) (hrs)
Bunge
Organic!
Rio- accumulation
Chronic
Carcinogen/
Molecular
Vapor
Surface Water
steady
state
Permeability
Coefficient
(B)
Inorganic
Factor (BAF) (1../kg)
Ecological
Noncarcinogen
Weight
(MW)
Pressure
(Vp)
Partition
(T*) (hrs)
Coefficient
(unitless)
Thresh
hold
(gm/mot)
(atm)
Coefficient
(Kpw) (cm/hr)
(Aquatic
TRV)
(Kdsw) (Likg)
(mg/L)
'5.60E+00
2.30E-01
1.10E+00
2.90E+00
.1.00E+00'
330E+03'
0.00E+00
Noncarcinogen
1.78E+02
1 57E+03
0.00E•.00
0.00E+r,
:1..00E+01
8.60E-01
2:20E+00
5.00E+01
1.00.E+00
6:03E+03
0:00E+00
Carcinogen
5.27E+02
1.21E-06
2.23E+04
Carcoogen
1.10E+01
7.00E-02
1.40E+00'
7.90E4)1
1:00E+00:
1.00E+00
0:00E+00'.
ticercinogen
•?
•
?
•
?
•
?
•
2.15E05
8.45E+01
0 00P+::
4,8pg-+po.
5.00E-03
2.00E+00
.3.20E-02
2.45E+03
Noncarcinogen
2.22E+02
2.17E-06
6.15E+00
3.20E+00
1:60E-03
1 30E+00., ..
3.70E-03
1.00E+00
1.00E+00
3.30E-01
Noncarcinogen
1.94E+02
2.17E-06
2:32E100
C. ÷
0.00E+00.
2.06Et01:
6.90E-01
2:04E+00:
1.00E+00
1.00E+00
2.00E-02
Noncarcinogen
1.68E+02
...Q.00E+00
0:00E+00
140E+04
..,......
.:
.6:50E-02 -
7.00E+00
6.90E+00
•?
1.00EiWO
-2.35E+03
1.90E-02
Noncarcinogen
3,12E+02
1.58E-08
1:03E+03
1
00
?
Ou
•?
.0.00E+00
1:00E-03
-0.00E+00
0.00E+00
. 0.00E+00'
T:02E:106
7.70E-04
Noncarcinogen
2.01E+02
2.63E-06
1.00E+05
2.00F -
..,4„.80E+00%
2.10E-02
•?1A0E+00,
1.40E-01
.00E+00.'..:.
1:00E+.00..•
'2.10E-01
Carcinogen
1.98E+02
1.32E-04
2.45E+01
9.60E-01
2.60E-03
4.00E-01
130E-03
1 00E4'00
1.00E+.00
3.75E-01
Noncarcinogen
1.08E+02
1.40E:04
7,65E-01
•
I
li
7.70E01..
4.70E-02
'1. 8 20E4)1'
5:60E-02
1.00E400•
1-.00E+00
1:30E-0.1
Noncarcinogen
171E-02.
1:05E+01
Results for Analysis: Updated DRAS 2 -
19-
08, Max values used
?
02
Select Chemicals of Concern to be Modeled (Steps 4 5)
Chemical Name
CAS:Number
TCLP
Concentration
(mg/L)
TCLP
Detection
Li
Mi
Total
Concentration
:(mg/kg)
.
Total
v
Detection
Limit
Maximum
Contaminant
Level
(MCL)
(mg/L)
Carcinogenic Slope
Factor - Oral (CSFo)
:
clay/mg)
(kg-
'
Carcinogenic Slope
Factor - Inhalation
(CSFi) (kg-day/mg)
Reference :
Dose -
Oral
(RFDo)
(mg/kg-day)
ilit?
11
0 00E
Anthracene
120=12-7
5.00E-04
Q:00E+00
1.0.0E,02
0:00E+00
0.00E+00
•.a:poE-Foo
3.00E-01
,--,
0 OtiE
,
AntiMony. :
7440-36-.0
2.10E402
.0.00E00:
3.90E+01
0.00E+00
6.00E:03
0.00E+00'
0.00E+00
4:00E-04
■
C 00E i
Barium
:
7440-39.-3
?
:
6.30E-01
0.00E+00
2.00E+02
0:00E+00:
2:00E+001:
0:00E+00 "
0.00E+00
.2.00E-01
Beryllium
7440E41-8:
3.40E-04:
:' 0:00E+00
2.30E-01
0.00E+00
4.00E-03 '
::0:00E+00
! 8:40E+00
2.00E-03
;
0
n0E+00
(!E.-0c:
' - 30
Acetone,
6764-1
1.25E-02 .
' 0.00E+00
'2,50EgYI
0.00E+00
0,00E+00
V
?
:
0.00E+00
0.00E+00
: 9..00E-01
Benzene
.._
.(iE?
'.)5
.
0,00E+00
3?
OE'.-0-
:
:
5.00E j3
5.50E-02
2.70E ...7
Results for Analysis: Updated DRAS 2-19-08, Max values used
Select Chemicals of Concern to be Modeled (Steps 4 5)
.;
?
Reference
Dose -
Inhalation
(RFC) (mg/m
3
)
Bio- concentration ;Soil
Factor (BCF)
(L/kg)
Saturation
Level
(SOILSAT)
(mg/kg)
Toxicity
Characteristic
Level (TC)
(mg/L)
Henry's. Law
Coefficient (H)
(atm-:ms/rnol-K)
Diffusion
Coefficient
in
Water (Ow)
1(cn'Osec)
Diffusion
Coefficient in
Air (Da)
(cm'/sec)
-Solubility
(p:',it.) (mg/L)
'
Landfill
Dilution
Attenuation
Factor
(DAFLF)
Surface Impoundment
Dilution Attenuation
Factor (DAFSI)
3.00E401
:o.opEt0Q
.6..10E+00
0.00E+00
1.46E-05::
!:77.74E,,06
3.24E-02 :
4.34E702
1.60E+01
.?
0:00E+00 :
3 00E-:..
,
2
.
-
'2E-02
'
0.00+o0
4.00E+01
o.00+oo
0.00E+00
0:00E+00
8:96E-06
7.73E-02
0.00E+00
3.43E+01
1.36E+01
,7?
,,
5 00E4-00
1
?
"4:4 t
- ,...
'
,
1.43E7031'
1..00E+00
- .0;00E+00
1.00E+02
,
?
.
0.00E+00
8.26E-06
7.14E-02
::
0.00E+00
;.2:78,E+01 ;
1.11E+01
,
?
4
. 00
00
0E+0
0,00E+00
K,F
2
0,001,-- ',
1
0::
.
F4.0
t
'
1:::8:00E06
:
:
:
:
420E+01
01,00E+00.
0:00E+00
‘:
0:00E+00:
5.08E-08
4-.39E.-01
0.00E+00
1.04E+02
4..14E+01
,00E+00
2.50E'-02
3 +00
1 00E+00
.:,.;
.1,/).;,..::
,.,],,
;::: .!2,.
:,
;.Y,F+0
0:00E+00 ::
4:92&.oi
.
1.00E4'05
0.00E+00
1.90E+01:
,3,90E-1.90?
.
2:88E"05
:1:15E:i05 : :
'1.20Er01:
1.00E+06
3 50E 0",i
2,4?,E-+01
+02
5,00E-01
5 4C:",,
(
1
L...;'. 05
1
l'''':.i X
01
1:75E+03
1,`,..;,,E+01
':;
.,`,,E+i..;',.)
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
3
Select Chemicals of Concern to be Modeled (Steps 4 5)
Time to reach:
steady state
(T*) (hrs)?
'
Permeability
Coefficient
(Kpw) (cm/hr)
Tau (T)(ht
Bunge
Coefficient (B)
(unitless)
Organic/
Inorganic
Sio- pOdUmolation
Factor (BAF) (L/kg)
Chronic
Ecological
Threshhold
(Aquatic TRV)
(mg/L.)
—
Carcinogen/
?
.
Noncarcinogen
Molecular
Weight
(MW)
(gm/mol)
Vapor
Pressure (Vp)
(atm)
Surface Water
Partition
Coefficient
(Kqsw) (L/kg)
t,,_
...:?
.
: 5.:50E+.00
: 2.61E701
.1.07E+00
7,3004?
: Noncarcinogen
1678E+02
3.35E-08 :
1 76E+03
7 20E+0
0,00E
±00
1.00E-03
i
0.00Et00
0:00E+00
1?
)0E. ! :21' ,
p.poEt
op:
1600E1-00 !:
, 1:50E401'
,J,?
i,, y ,I,
Noricarcinogeg.
2
?
C/::..:
1.22E+02
0.00E+00
4.50E+01
.?
:
0:00E+00
e e?
a
eee?
o e
e e e?
e e
e e e
?
e e
e e
?
e e
3690E-03
Noncarcinogen
137E+02 :
0.00E+00
4..10E+01
0.00E+00
: 9.0;1 E+00
::
0:00E+:00
7.90E+02
•?
4.70E-01
2.20E-03
1;50E+00
.
?
.
Noncarcinogen
I
?
12E?
-,"),:::
Noncarcinogen
5.01E+01 ,
2 99E-01
7.13E-02
5 30E-31
4 6, )t-:, 02
C.aromogen
7 8?
::
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
3
•
1.32,;649
.86=3Q6
-
iNkNiiirOstidiph'ehylarnine
Oral Reference Do.5e
;.1ritielation!Refel'ence
. „
DOse
0.02
117-84-0
Irihálaticin.Refererxe Dose
'RFC
rrig/m3
r,lax1r,-turrl?
:
78-59-1
Ci
.
raf:Par:Ciii.
c*pi:SIOpe Factor
CSFo
11(mg/kg-0,y)
CarcinogenIc
78::59-1
:.1ritialOtion-Referende-Dose
RFC
mg/rn3
02,
IsoOtitinine:
isop..ornne
IsOOhorop-e
Dilien'tdfdt,an.
i
2K-4.4-o
:IriragtrOti,Refei-ehOe,Doe•
•.•
RFC:
:0.04
Eut
yl.
bel
izyq•
NINitroSOilip-kriylernine
N Nosodipt
a6 2
Inhalation Carcinogenic
.
Slope
..
FaCtOr
.
Toluene
Thallium
7440-28-0
Q
8 3
Org
kRefere
-
ce:
Dose
-13F,Do?
oso
,on
Referenc,E
RFC
91'
0
ral:Referen
ce. Dose
g/?
3.da
.
mr
:Irifi6laiicitikReee9oe.Dose
.i.v1tIracene
Pyrerie
.129;0070..
gfp4
i
acO.Pk-;.,"..
'Parditi4
RFC.; .
List of COCs with Altered Chemical Properties
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
0
1
7440-39-3
eferenc_e
).0005
7440-31-5
`Larldfilli
Difution''Attenuation
.?
-
Factor
DAFLF
10
Acetone
Oral Reference Dose
RFDo
mg/kg-day.
Benzene
71-43-2
Oral.Oarcinogenic Slcipe Factor
CSFo
1/(mg/kg-clay)
'0
,
?
•?'
Benzene
714372:
Oref. Reference Dose
•
?
;.
•
RFDO::: •
mg/kg-day"
rr,r!
Acenaptithone
-183-32-9.
:Inhalation. Reference Dose
RFC
mg/m3
!C.?
-
Vanadium
744076272:
Or.af Refererice Dose
RFDo
mg/kg -da
nitroaiiiline
.88-74-4
'20ral-Refererice..Dose
RFDO-•
mg/kg-day
line 2-
88-7
inhaiation P.s;fe,a•ince
Napttnaierfe
•
?
•
?
.
Inhalation Caráinogenic Slope
"Factor
CSFi
1/(rrig/kgF.da#:
Bi(24etny.lnexyl)Phttialate
117-81-7
Inhalation Carcinogenic Slope-Factor
CSFi
.11(mpg7.da.y)
inhalation
1 CoOalt
7440-48-4
Inhalation
Carcinogenic Slope factOr
CSFi
1/(rng1lsg,-day)z.
CObakt
7440
.
=484
Inhalation Reference Dose
RFC
mg/m
-0:003
:0:001
.Q 004
0.055
`0:014
.000008,•
0.06
0:35
0.9
9.8 :
List of COCs with Altered Chemical Properties
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
2
List of COCs with Altered Chemical Properties
V:',.
?
3......,.
?
.
•?
04a
?
aro*,
.....
.
-A§I
,.
umber
.i.,?a?
mete?
odified$ .
:.,.-
_
?
-?
•?
.?
,?-
,,
Parameter ?
'
Thb"61.!•-.,'
P ararnet
,?
,
?
.‘,
Odifiect,,
•?
•••.,?
•
•
$1taldel..,'
_?
,
?•?,:,....
Done"
7
?? –
..at?
_
lii Dilution Attenu2i
.
vin
..-•,,..‘i..
'iAFLF
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
3
Limiting Pathways
Detection Limit
Analysis - Toxicityof Potitioned
•
Waste cannot be
confirmed if Detection:Limits
fall below maximum allowable concentration
Chemical
Name
CAS
Number
Maximum
Allowable TCLP
Concentration
(mgIL)
Maximum
Allowable
TCLP
I
Pathway
Maximum
Allowable
Total
Concentration
(mg/Kg)
Maximum
Allowable Total
Pathway
117-84-0
7,00E-02
G,[,.:,?
-.?
,?
(;1
.
0::-.i
2.57E-
?
l
TCDD,
2,3,7,81
i1;746016
:
2:•(:)5E,10
Groundwater.:Adult Dermal
7.56E-03':'
Soil
Ingestion
:
i
I iii
?
in
ChlOrti
:
3-methYlphetibl 4-
59,50-7
I
Not Applicable
Not
Applicable
.)ci"fooili
,.
132L
..t
,,
1?.
Silver : :
7440.-22=4.
-:3
64E+00
Groundwater ingestion
,?
..
4.93E+04
Fish Ingestion
,t9:! ,
'
i3.76Ei 03
Soil
Dibenz(a,h)anthracene
53-70-3:-.
3.80E05
Groundwater Adult Dermal :
1.56E+02
Soil Ingestion:.
0
?
,
132-64-9
.04E-01
t.:iii,.
2?
i :2
,
Soil ingestion
FluOranthene:
206-44-0'
1•61E400
Groundwater Child Dermal
.,
8:03E+05
Fish Ingestion:
:ii?
q- ' ,
!‘,:.-)1•
2.90E+0
`?
'?
.?
,
1
Benzo(b)flUoranthene
205-.99-2:1
7,29E05 :
- Groundwater Adult Dermal '
1:
56E+03
Soil Ingestion
Mercuni
71'3c-97-6
8.14E-0
!CI, !,
t
Benzbjghi)parylerie
.191-242
Not Applicable -
Not Applicable
lei-
r-4 i t ms od
ipt,,-‘.71,.,:::,
86-30-6
2.69F-01
G
tin.:,,,,,,,,r
1::
.
?'?
r
2.32E+1.
Air Volatile Inhailal ,
:.
Results for Analysis: Updated DRAS 2-19-08, Max values used
BrOmophenyl-phenyl
.
?
.?
.
: ether 4-
Detection Limit Analysis - Toxicity of Petitioned Waste cannot
be confirmed if Detection Limits
fall below maximum
allowable concentration
CAS?
Maximum?
Maximum Allowable TCLP?
Maximum?
Maximum Allowable Total
Number
Allowable
TCLP?
Pathway?Allowable Total
?Pathway
Concentration?
Concentration
(mg/L}?
(mg/Kg)
Chemical Name
Indeno(1,2,3-cd) pyrene
193-39-5
- 4111E-05
?
Groundwater Adult Dermal
1:56E+03
Soil Ingestion:
Anthracene
Arsenic.
PYrefie
Beryllium
•101-55-3
?
'. '1.22E+01:
7440L38z:2-
7440-31-5
7440-41-8
120-12-7?
2,50E+01
129-00 0
?
1.23F+00
.9.36E-04
8.80E-02
4,16E-01
Groundwater ChildDerrnal
Groundwater Child Derm;:.,
Groundwater Child.,Dermal
Groundwater Ingestion
Grounciwater.IngeStion
Groundwater
.
Ingestion
•MCL
MCL
NICL
•
7.21E+03
Fish
Ingestion
.1-
9".47E+01
Fish Ingestion
+05
Fish !noes
iir
4.78E+03
Fish ingestidn
rIgestiori
1.68E+02
Fish Ingestion
7.71 E+07
SOil IngestiOn
4.02E+03
Fish Ingestion
Soil Ingestion
3.00E-01
Air Volatile lnnalation
Toluene
Thallium
10
7440-28-0
". 57E+01
2.25E+02
‘!:7440-43-9
1.50E-01
87-04-1
6.42E+02
Limiting Pathways
Results for Analysis: Updated DRAS 2-19-08, Max
values used
?
q
2
Limiting Pathways
Chemical
,.:
Name ::
,?
CAS
Number
DetectionfLimit
Analysis
Maximum
Allowable
TCLP
Concentration
(mg
/L}
- Toxicity
of Petitioned
.
fall belOw maximum
allowable
Maximum Allowable TCLP:
Pathway
?
-
Waste:cannot
be confirmed if
Detection Limits
concentration
Maximum'
Allowable Total
Concentration
(mg/Kg)
MMaximum, Allowable Total
. Pathway
cenapntl
,
e
y
...
,
Methytnapthalene
2
: 91-57-6
Not
Applicable
Not Applicable
∎
214E4,02
■
Groundwater Ingestion •
3.85E+07
Soil ingestion
phenol
108-95-2,
Soil Ingestion
Safi
.
-
?
i
•?
i
80E-1;l1
..1
1-±?
,it::::tion
BeriZo(K)fluOrantherie-
'?
2070
.
-9
:?
1 :.01&03
H: GrtkerdWater.AdLilt Dermal :
, 1
56E+04
Soil Ingestion
Acerapthylene
208-96-8
Vanaditith
, '
-. -7440-62-2
3.02E+00.:
Groundwater Ingestion
1:28E+05
"Soil Ingestion
2.80E4-02
.?
i
::).22E .,-) l:
Fish ing.
Chromium .
1?
7440-47-4
:....85E+02•:":
MCL
4,77E+05,,!.
Fish
In
g
es
tion
Fl
?
::r
-
er?c,
3E +00
.:,
1;.?nt?
:i
pentaChlorophenOli •
,.87-86-5 -
2.79E-03
.Groundwater klültPermal
9.47E-.03
Soil Ingestion
nitroaniline 2-
88-74,4
2.03E+00
...:on
Innaiiir-
l\laphhalene :
91'720-3
3.72E-01 : :
"::Groundwater Inhalation
.
1.38E+03
Air Volatile Inhalation
Pv?
.ine
110.86-1
7.13E01
v
?
•
?
.. :
.1',estIon
1,2!3E-i-05
Soil Ingestio
Results for Analysis: Updated DRAS 2-19-08, Max values used?
1A3
Limiting Pathways
I Detection
Limit Analysis
-
Toxicity of Petitioned
fall
below maximum allowable
Maximum Allowable
TCLP
Pathway
Waste cannot be
concentration
Maximum
Allowable Total
Concentration
(mg/Kg)
confirmed if Detection Limits
-..
MaxtrnniniAllOwable Total
' '?
,Pathway
Chemical Name
CAS
Number
Maximum
Allowable TCLP
Concentration
(mg/L)
Nickel:..
:
7440-02-.0
:
2.83E+01
Groundwater. Ingestion- :.
.
1;30E+05
Fish Ingestion
f2; i
:?
thylhe.,
6.1t)E 02
''?
)e.-i?
.?,i
ingestion
Di+rOp utyl phthalate
. 84-74-2
,
1:55E+01
Groundwater Child
.-
Dermal n
, 3:60E+04?Fish ingestion i
Pher
anthrehe
8:.,?
(..'! .1 .
8
•
I?
bie
Cobalt:
' 7440-48,4,-:
7.51E+00 ::
GroundWater. Ingestion..
1.10E+04'
Air Particulate Inhalation
Chrisene
:?-01-9
1.398-02
Grou-.0
• ?
:.ii .1: De,rinal
:
.5
?
-l-05
Soil Ingestion
Benzo(a)pyrene
: 50-32-5?
:
8:06E705.:
Groundwater Adult Dermal
1.56E+02: -
Soil
Ingestion
.;:i
iloreph,
-?
i'
2,86E+01
..ii.Ar,
?
.?
-i
i ngestion
Lead:
...
•
743792-1 '
7.50E+01"
MCL :
::4,39E+.04 '
Air Particulate Inhalation
?
:
Diethyl phthiillate
84-66-2
6.91E+02
GfOu :(?
fa..er l'•,--.st.ioi)
ish Ingestion
Results for Analysis: Updated DRAS 2-19-08, Max values used
Groundwater Pathway Hazard Quotient
Petitioned
.
Waste Non-carcinogenic Hazard Quotient - Groundwater
Exposure.Pathways
Chemical Name
Waste
Stream
TCLP
Concentration
(mgIL)
Groundwater
ingestion
Pathway
Groundwater
Inhalation
Pathway
Groundwater
Dermal
Absorption
Pathway -
Adult
Groundwater
Dermal
Absorption
Pathway - Child
Groundwater
,Pathway
Aggregate
hazard Quotient
-._■
?
oety;
?
i:!.n..,-,;.::-
?
-
-
28E- 05
!.
4 22E-92
-:.?
:2E- •-.)-
TCDQ,:2,3;7,8-; .
4..0001
-
-
BE;n:(a)ar;
___
Chlor4t3=rhéthylpherior
4-
3:85E-04
f,,
-
9 09
z_n7
•
Silver :
7.50E704
1.95E-04
-
1:95E-04
ivitethyl [,)h
[hidwe
•?
.:
I 80E
Dibenz(6,h)anthracene
.?
,
2.60E06'
-
-..
04
.' 86E-03
4 54E
Fluoranthene
2.95E=03
: 1103E=04
:?
1 .
.48E-05
,
8.40E04
1..83E+03
1.95E-03 - -
Benzo(b)flOoranthene
4.00E-05
–
Benzo (ghi);perylerie
, 1.35E703
Indeno(1;2,3-cd):pyrene
:?
.
1:A0E-05
E ,..r)::y:
?
a:,,
Brornophenyl
T phenyl ether 4-
;..8:50E-05
..2:17ET06:
l :
321'E-06 :
' 6:99E-06
9:16E-06
t .
..
..?
,
)?
,,
26E-06
1.31E
?
,:
fThallium : :
9.30E03
-
8.53E702
-
8.53E-02 ::
rithracene
5.00E-04
2.47E-06
3
?
4E-07
0E-05
2.30E-0
Results for Analysis: Updated DRAS 2-19-08, Max values used
Groundwater Pathway Hazard Quotient
Chemical Name
Petitioned. Waste Ntm
.
..carcinogenic Hazard ;Quotient
- Groundwater Exposure Pathways
Waste Stream
TCLP
Concentration
(mg/L)
Groundwater
Ingestion
Pathway
Groundwater
Inhalation
Pathway
Groundwater
Dermal
Absorption
Pathway - Adult
Groundwater
Dermal
Absorption •
Pathway -Child
Groundwater
Pathway Aggregate
r Na;ard Quotient
Pyrene
3.30E03:
1.54E-0
2 . 77E-08
1:23E03
2.67E-03
2.83E03
timony
'2?
'IOE ';)2i
,' 08E-02
---
.-i?
8E-0`
..'
Arsenic
3.70E03
1
.
71E02
1.71E-02
—
3 Oft:
Tin
?
;
;7:.50E+00:
'3.33E-02...
.. ;
3:33E-402
Cadmium
.9.20E02
.163E01
1.53E-01
r.or;e
1.2tE ,
1.95E-05
.-.)E
,-;
?
,
1 :36F ?
'
Benzene
1.90E05 .:
7.03E06', ;
; 1.23E05-:
11 .04E06 ::..
2.27E06
2.15E05
?
692
1,44E?
'.
Methylnapthalene 2-,?
'
2.65E-04.
—
C:ipp( ;
3 302. D1
7 i
30E-03
7 r=.0E-,...!
Phenol -‘•
.?
::
2.10E-03
9.81E-06
444E-07-',-.
.
.
-.
1.08E-95?
.
f!, f
? 302-32
: 752-0?
'?
7
3F...
BeniO(k)fluoranthene
8.00E-04 i?
:
--L
Acera
i
:)Thy:s:,o
--
Vanadium; :
, 1.00E-02
132E-03•-
3.32E-03
Zinc
4.102
';
4
.
2-02
1 4.62 0..,
Chromium
9.50E;.02
4
.
38E07
4.38E07
luc,
: rerh?
4 65E-aL
1 63E-05
3
?
:!.?
i...5
T.', 3H-i 05
1?
.52-0,
Pentachlorophenol
.?,
3.15E04
1.55E-06
; -,7.86E05
....
1 71E-04
1 86E-04?
......2j
Results for Analysis: Updated DRAS 2-19-08, Max values used
Chemical Name
Benzo(a)pyrene
1:2:30E-05
Lead?
3.60E-01:
17.1te;r.y,
4 .13E-C1.,7
1;3
5.52E-01:
5.01E-01.
'2.64E-02
5.69E-02
?
1.11E+00
Groundwater Pathway Hazard Quotient
Petitioned Waste
Non-carcinogenic Hazard
Quotient
-Groundwater'
Exposure Pathways •
Naphthalene'
Nickel
Cobalt
Waste Stream
TCLP
Concentration
(mg(L)
9.50E-04,
6.90E02
6.00E-03
5.50E-01
Groundwater
Ingestion
Pathway.
Groundwater
Inhalation
Pathway
Groundwater
Dermal
Absorption.
Pathway - Adult
Groundwater
Dermal
Absorption
Pathway - Child
---
Groundwater
Pathway
Aggregate
Hazard Quotient
4.69E-04
2 5 " •
6.66E-05
4.16E-03
5.16E-05
1.12E-04
4.34E-03
1.62E-':,
•
2.44E-03
2A4E-03
1.19E-03
7.99E-05
1.67E04
3.63E-04
4.43E-04
7.32E-02
7.32E-02
5.40
'I .35E-0E:
1
All Waste Constituents
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
03
Petitioned
Waste Carcinogenic Risk - Groundwater Exposure Pathways
Chemical
Name
Waste Stream
Groundwater
Groundwater
Groundwater Groundwater Groundwater
TCLP
Ingestion
Inhalation
Dermal
Dermal
Pathway
Concentration
Pathway
Pathway
Absorption
Absorption
Aggregate Risk
(mgIL)
Pathway -
Pathway -
Adult
Child
D
thalte
4.00L-11
2.60E-06
2.95E03'
1.35E-07
4.56E-09
3.85E-04
7.50E-04
1.05E-C2
1.15E04
4.00-04
1.44E.e.08
3.09E-10
4E13 •?
'5.84E=.07
:96E07
8.52E-08
3,49E-06
2.98E-07
2.00E-07
6.98E-07
EenZo(b)fiL(OrAnthene
4.00E-05
2.10E-08
2.51E-10
5.49E-07
2.39E-07
Mercury
2.40E-02
Benz!):(ghi)perylene
•1:35E03
N
?
L,
7.16E I1
lrideriO(1 ,2,370):pyrene
1.40E-05
7.36E09..
6.98EH14..
.
?
„.
3.41E-07
1.48E-07
Benzyi 21c_orlo',
5,00E-04
5.70E-07
3.48E-07 -
TCDD, 2,3,7,8-
L'.en20:0/3
Chloro-3-methylphenol 4-
Silver
Dirnethyl phlf @late
Dibenz(a,h)anthracerie
Eluoranthene
Groundwater Pathway Risk
Results for Analysis: Updated DRAS 2-19-08, Max values used
Groundwater` Groundwater
Dermal?
Pathway
Adsorption Aggregate Risk
Pdthway -
Child
Toluene
3.75E-04
Thallium
9.30E-03
Pyrene
3.30E-03
Antimony
2.1
Tin
7.50E1-00
Eacy!liun-,
3.40E-04
MethYlnapthalene
2-
2.65E-04
Petitioned Waste.Carcinogenic
Risk - Groundwater Exposure Pathways
5.00E-04
Arsenic
Barium
3 70E-03?
3.95E-06
6.30E-01
3.95E-06
Cadmium •
1.2.5E 0
!Benzene
1.90E:05
7.94E-10
4.36E-1'0
9.15E-11?
3.99E-11?
1.32E-09.
r
..15i 04
Groundwater
Groundwater Groundwater
Ingestion?
Inhalation?
Dermal
Pathway
?
Pathway. :
?
Absorption
Pathway -
Adult
Waste
Stream
TCLP
Concentration
(mg/L)
8.50E-05
Chemical
Name
Bromophenyi-phenyl
ether 4-
Groundwater Pathway Risk
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
2
Acenapthylane
5.50E-04.
Petitioned Waste Carcinogenic Risk - Groundwater
Exposure Pathways
Groundwater Groundwater
Drermal?
Pathway
Absorption Aggregate. Risk
Pathway -
'Child
3,44E-07
Groundwater
Dermal
Absorption
Pathway -
Adult
7:89E-07
8.31E707
Vanadium
Chromium
3.15E-04
5.50E-01
Pentabh1OrtiphetIO1.
Naphthalene.
PyrOine
Nickel
Di,n-butyl phthalate
Cobalt
9.50E-04
9.50E-04
8.90E-02
1.05E-03
1.70E-02
2.87E-08
1:76E-09
1.13E-07
4.92E-08
1.43E-07
1.92E-07
1.92E-07
8 41E-11
1225-, T'
Chrysene
1.65E-03
8.67E-09
2.08E-11
5.19E08
1.28E-07
Selenium
Benzo(k)fluoranthene
.
?
,4.20Et08
3.44E-11
Waste Stream Groundwater
TCLP?
Ingestion
Concentration?
Pathway
(rngiL)
Groundwater
Inhalation
Pathway
Groundwater Pathway Risk
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
03
Groundwater Pathway Risk
Petitioned Waste Carcinogenic
.
Risk -
Groundwater Exposure Pathways
Chemical Name
?
.
Waste Stream
TCLP
Concentration
(mg/L)
Groundwater
?
Groundwater
ingestion?
Inhalation
Pathway?
Pathway
Groundwater
Dermal
Absorption
Pathway -
Adult
Grqundwate
Dermal
Absorption;
Pathway -
Child
'Groundwater
Pathway
Aggregate Risk
Benzo(a)pyrene
2.30E-05
1.28E07
2.10E-10
2.85E-06
1.24E-06
2.98E-06
Lead
3:60E-01
---
Dv-tidy
?
p'-‘1,21.6,-
2.8f_-t24
---
---
---
---
---
All Waste Constituents
4.96E06
1.99E-07
1.39E05
6.07E-06
1.91E-05
Results for Analysis: Updated DRAS 2-19-08, Max values used
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Chemical Name
Risk
Factor = 1.00E-06
.
•
HQ:FactOr = 1.00E+00
?
'
*=
Detection Limit
Waste Stream
TCLP
Concentration
(mg/L)
Dilution
Attenuation
Factor (DAF)
Waste
Volume
Adjusted
DAF
Maximum
Allowable
Concentration
(mg/L)
DL
Max. Allowable
Concentration
Based
on
Groundwater
Ingestion Pathway
Max. Allowable
Concentration
Based on
Groundwater
Inhalation
Pathway
Max.
Allowable '
Concentration
Based
on
Adult
.
Groundwater Dermal
Absorption Pathway
Max.
Allowable --'
Concentration
Based on Child
?
I
Groundwater
Dermal
Absorption Pathway
Benzyi aicoho!
2.14E+02
,?
J•;
BromOphenylA
p henyl ether
""
8;
50E705
1.80E+01
1.80E+01
1.22E+01
3.92E+01
1265E+01:
1:.
22E±'01
1.90E+01
.?
,
Phenol
2:10E-03
1.90E+Ot:
1.90E+01
2:14E+02
2.14E+02,
4.73E+03
2.17E+03
‘..,co:N,'.,
....:-
1?
,
?
,?
.?
■
1
7.13E-01
Bi$(27etrlylhe41)0(ithal4te
?
r
?
1:.70E
.
02
. : ;;
1:90E+01
1.90E+01
6.10E•12
9.92E-02
2:99E+02
6.10E702
1:40E-01
.
,?
•
0c 491
2,70t?
i
7.00E-02
Anthracene
5.00E04
1.80E+01 .
1.80E+01
2.50E+01.
2.03E402
1.35E+03
:5.44E+01
"::!2.50E+01
1
-i•:: I
I?
`.::0E
.
i
.
:
1.23E+00
Dimethyl phth
a
late
1:15&04
1.80E+01:::
1,80E4701:
6.76E+03
6.76E4.03
' 2.68E+05
. 1.23E+05
!..,
1?::E 4 :, i
;,80:1.
1.04E01
,?
y
.''
,.
r.
.0E
TODD;
..?
'
?
2;3;7,8i
::.
: '
4.00E-J11
;1.80E+01
1..80E+01?
2.05E.10
817-7E09
1.93E-07
;2:05E10
i 4.70E-10
,
0.'.1+01
!
-
---
InizienO(1,2,3C0)•pyrene
1:40E-05
1.90E+01
1.90E+01..'.:
1.90&03:
2.95E+02
4.11E705 '
- 9:43E-05
Renze.;-(eol'iuorntiene
.4- 00E-05
1 .
905401
1 .00E +01?
7.29E-05
2.35E-01
':',.F-v;',
.
FlObranthëtle
2.95E-03
1.90E+01
1.90E+01
?
:1.61E+00
2.85E+01
2,94E+02
3,51E+00
:. 151E+00
Benzc(k)fiuoranthene
8 Q0E-0
. :
i'.],
I 93E4-
?
1.01E-03
i E.,?
_
Acenapthylehê
.s.
._.5.,50E-04
'• 1.80E+01
1.80E+01
("hysene
1.:15- 03
•-.)1
I
.905+01
?
1 39E-02
Benzo(a)pyrene
230E-05
.1.80E+01
1..80E+01?
8:06E-
06:: :
1.80E-04 '
1.61E-01
8.06E-06
1.35E05
Dr...nz;ar!)ar
?
c;`,-vi
'?
..:,
3.80E-06
-,:
,
3i
,
,s-. co
22-E4-6 .
..;?
).:',0E .?
• !f..;
..',
?
7:::
Beriz(a)afitheaCene
..
?
:?
.?
'
1.05E-;03
1.89E+01
1.80E+01?
1::
..1g,:.01v.
;80E703
,,.
3.73E-01
?
1.31E04
:
•
3'01E-04
?
.
Results for Analysis: Updated DRAS 2-19-08, Max values used
•-.1:14E-01.•....:...•.
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Max. Allowable
Concentration
Based on MCL
•- •
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
01
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Chemical Name
Risk
Factor = 1.00E-06
?
r
HQ
Factor = 1.00E+00
*= Detection Limit
Waste Stream
TCLP
Concentration
(mg/L)
Dilution
Attenuation
Factor
(OAF)
Waste
Volume
Adjusted
DAF
Maximum
Allowable
Concentration
(mg/L)
DL
Max. Allowable
Concentration
Based on
Groundwater
Ingestion Pathway
Max. Allowable
Concentration
Based on
Groundwater
Inhalation
Pathway
Max. Allowable
Concentration
Based
on
Adult
Groundwater Dermal
Absorption Pathway
Max.
Allowable 7-1
Concentration
Based
on Child
Groundwater Dermal
Absorption Pathway
C.,?
aro-.:?
,
---
--
---
Acetone
1%25E-02
1.90E+01
1.90E+01
6.42E+02
6,42E+02
1.32E+06
8.37E+04
benzer€:.
I?
91 :1:
I?
2;1
I K:
2.39E-02
''?
L
Lead:
..
`.:
6.00E+03
6.00E+03.
7.50E+01
---
err,..,r;.
..
?
t.
?
,
-5E=::1
8.14E-02
61-i-
---
Nickel .
6.90E02
3.76E+01
3.76E+01
.2.83E+01
2.83E+01
50E -(.)
/?
ot+fil
2 (?
4-01
3.84E+00
---
---
Thallium
9:30E-03
4.40E+01
4.40E+01
8.80E-02
1.09E-:01
-
-
?
50
i-
+
2
1?"
.7
:;1
3:.--1-01
2.25E+02
---
Antimony
2.10E-0
3.43E+01
3.43E+01
2.06E-01
6.1.5E-01
---
.
?
-
H...A-..
?-1
9.36E-04
---
---
Barium-
6.30E-01
2.78E+01
2.78E+01
5.57E+01
2.09E+02
i.,,,
4.16E-01
---
---
---
Cadmium
9.20E4:12
3.00E+01
3.00E+01
1:50E-01
5.63E01
-
..;i- omi.,r
,
.
9 50E-02
,..3 85E403
3 851=
,
:)3
3.85E+02
-
---
Cobalt
5.50E-01
1.00E+01
1.00E+01
7.51E+00
7.51E+00
Copper
8 006 + a1
,
9.11E+03
---
---
Vanadium
1.00E-02
8:08E+01
8:03E+01
3.02E+00
3.02E+00
---
___
•
Selenium.
180E-02
1.16E+01
1.16E+01
5.80E-01
2.18E+00
-
i..?)::1?
OP :A I::
;L..
+ '
1.32E+00
''
.-.)?,i_,I''
Acenaphthene
.,,
ene
?...
'
1.15E-04.
1.90E+01
1.90E+01
1..25E+01
4.28E+01
6.86E+01
2.73E+01
1+
.25E
01
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
2
9.00E -02
".50E-t01
1380E-02
2.06E-01
1 ,S32 E -01
5.57EF01
1.50E-01
5.80E-01
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Max. Allowable
Concentration
- Based
on MCL
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
[2,
2
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Chemical
Name
Risk Factor = 1.00E-06
HQ Factor =1.00E+00
* = Detection
Limit
Waste
Stream
TCLP
Concentration
(mg/L)
Dilution
Attenuation
Factor (DAF)
Waste
Volume
Adjusted
OAF
Maximum
Allowable
Concentration
(mg/L)
-.
DL
Max.
Allowable
Concentration
Based
on
Groundwater
Ingestion Pathway
Max. Allowable
Concentration
Based
on
Groundwater
Inhalation
Pathway
Max. Allowable
Concentration
Based on Adult
Groundwater Dermal
Absorption Pathway
Max. Allowable
Concentration
Based on Child
Groundwater Dermal
Absorption Pathway
c;
?/'?
a
6.91E+02
---
Di-n7bOtyl'phthalate
6.00E-03
2.00E+01
2:00E+01
1.65E+01
7.51E+01
3.60E+01
1.65E+01
Butylbenzylphthalate
1.35E-03
2.00E+01 -
2.00E+01
2.90E+01
1.50E+02
7.67E+03'
6.32E+01
- 2.90E+01
..?-
i
2.69E-01
/
?
.:-
.
Fluorene
4.65E-04
1.90E+01
1.90E+01
5.55E+00
2.85E+01
4.61E+01
1.21E+01
5.
55E+00
1
-'!:.i'.w.'i;)'
?
,,
?
'
1
?
-
;(2.E.
+1
1 80E+01
2.79E-03
2.6,7A:: k
nitroaniline 2-
9.50E-04
1.80E+01
1:80E+01
2:03E+00
2.03E+00
2:05E±01.
3.74E+01
1.72E+01
e
8.06E-03
___
)
?
-
___
Methylhapthalene2-
2.65&04
1.80E+01:,'. . 1.80E+01
-
---
---
'?
crfl.:
01
;
?
:.:EH-
.
-
2.86E+01
---
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
03
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Max. Allowable
Concentration
Based on MCL
Results for Analysis: Updated DRAS 2-19-08, Max values used ?
q
3
Petitioned Waste Non-carcinogenic Hazard Quotient - Surface Water Exposure Pathways
Chemical
Name
Waste Stream
Surface
Water
517-Particulate
Fish
Soil
Air Volatile Surface Pathway
Total
Ingestion
Inhalation
Ingestion
Ingestion
Inhalation
Aggregate
Concentration
Pathway
Pathway
Pathway
Pathway
Pathway
Hazard Quotient
(mg/Kg)
•
chlotb-3.:rriethylphOld1.4-
•?
.
E1
Dibenz(a,h)anthracene
1.30E-02
1.
Fluoranthene
5.90E-02
7.12E-10
6:75E-08
1.15E-08
2.70E
- 0).
3.52E-1
Benzo(b)fluoranthene
3.20E-02
ra
-+00
72,E
Benzo (ghi) perylene
2.70E;:02
Indeno(1,2,3-cd) pyrene
1.70E-02
1
?
.7
Eromophenyl-Phenyl ether
4-
1.70E4:13•
1,41E-11
1.92E-07
2.25E:710
Toluene
7 .50E-0
4.53E-11
6.18E-15
8.05E-08
774E16
•
1,92E-07
1.23E-1()
9,47FH.
Surface Pathway Hazard Quotient
Results for Analysis:
Updated DRAS 2
-19 -
08, Max values used
?
q
1
pyrene%
6..60E-02
Waste Stream
Total
Concentration
(mg/Kg)
1.40E+00
Antimony
Chemical Name
Thallium
Tin
•
'•
2.10E+02:
2.03E:04
2.09E-04?
3.27E-03.
3.68E-03
.3.80E-04?
4.59E-11
?
2.41E-11?
4.72E-11
3.55E-09?
4.41E-09
2_30E-03
1
.8
6 E-1
1
6 64L-
5130E-03
Benio(k)fluoranthene,.
Aceriapttiyleil,e
Vanadium
1.80E+02
.?8.69E-05
8.95E-05
?
1.40E-03?
1158E-03
1.60E-02
CE
Petitioned Waste
Non-carcinogenic
Hazard Quotient - Surface Water Exposure Pathway
Surface Water
Ingestion
Pathway
Air
Particulat
Inhalation
Pathway
IngFeissthion
Pathway
Soil
Ingestion
Pathway
Air-Volatile
Inhalation
Pathway
1:02E705
1.05E-05
1.65E-04
1.61E-11
1.09E-09
1.20E-09
1.23E-05
1 71E-08
4.76E-15
3.54E-05
3.65E-05 -
5.71E-04"
1.21E'=.07
.
1.24E-07
1195E-06
Surface Pathway
Aggregate
Hazard Quotient
1.86E-04'
1.23E-05
6.43E-04
2.19E-06
Cadmium
Mdthylnapthalene
• 2--
Acetone
A ce naphtn ne
Benzene
Phenol.
4,20E-02
6.76E-11
6.96E-11
1.09E-091.
1.23E-09
Selenium
Surface Pathway Hazard Quotient
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
2
Petitioned Waste Non;carcinogenic Hazard Quotient - Surfacer Water Exposure Pathways
Surface Water
Air
Particulate
Fish?
Soil
Air Volatile
Surface Pathway
Ingestion
Inhalation
Ingestion?
Ingestion
Inftalation
Aggregate
Pathway
Pathway
Pathway?
Pathway
Pathway Hazard Quotient
Chemical Name
Waste Stream
Total
Concentration
(mg/Kg)
Zinc
1.20E+05
Chromium
1.80E+03
5.79E-07
2.67E708
9.34E-06
9.95E-06
Flueren:
I.
?:2.E •
Pentathlorophenol
6..30E-03
1.01E-10
414E-08
1.63E-09
4.32E-08
:‘?
!.•:,i7
4,81E-09
Naphthalene
'190E-02
4:59&10
1.21E-08
4.72E-10
7.39E-09
1.38E-09
2.:18E-08
?
•
Pyridine
2.10E-02
1.01E 08
Nickel
1.70E+02
4.10E-06
-4.22E-06
7.45E-05
5.246-1
4
Dkriihtityl:phthaiate.
5.79E-10
3;33E-06
9.34E-09
3.34E-06.
them
CObalt
....•••?
•?
•
1.10E+0T
2.65E-07
1.opE-03
2.'74E-07
4,28E-06
1.01E-03
Ch rysfic-.,
3.30E-02
Benzo(a)pyrenel
•":."?
•?
•
?
•
?"?
•
1:70E702
Trichiorophen:
9.60E+03
7 OE
4E•42
6.19E-04
1.11
8.680.
3.48E+00
;9.98E-03
?
1.69E-08?
3.49E+00
;$ 5
All Waste Constituents
Surface Pathway Hazard Quotient
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
03
Waste Stream
Total
Concentration
(mg/Kg)
Chemical Name
2.50E+01
- :3.22E-15 -
5 (,':5F fa'S,
4.01 E-15
1.35E-15
1.42E-14
229E-14
Surface Pathway Risk
Petitioned Waste Carcinogenic Risk
-
Surface Water Exposure Pathways
Surface Water Air Particulate
Fish
Soil
Air Volatile?
Surface Pathway
ingestion
?
Inhalation
Ingestion
Ingestion Inhalation?
Aggregate
Pathway?
Pathway
Pathway
Pathway
Rath,way?
Cancer Risk
5.90E-02
2.10E-04
7.81 E-09
2.64E-09
1.69E-03
Z77E-08
1.35E-18
1.69E:03
ChlorOT
3Tmethylpheribl 4-
Silver ':
D ;,.nethyl phthalate
Dipenz(a,h)anthracene
Diethyl.. phthalate
Dr)el
1.30E4)2
2.35E-11
3.37E-12
7.29E-09
8.35EH11
?
5.89E-23
7.40E-09
5.70E-03
Butylbenzylphthalate.
Mercury
N,NitrOSodipheriylamine
•? : •?
.!•"•••:•?
.
incieno(1 .2,3•-csi) pp'ene
f.t.J
2.70E-02
3.30E-03
1.70E
3.20E-02
1.50E+00
Benzyl alcohol
1.00E-02
Brornopfterly1-•pheriy1 ether
4-
1.70E-03
Results for Analysis: Updated DRAS 2-19-08, Max values used
q
i
Surface Pathway Risk
Petitioned Waste Carcinogenic
Risk Surface Water exposure Pathways
Chemical Name
Waste Stream
Surface Water Air Particulate
Fish
Soil?
Air]Volatile
Surface Pathway
Total
Ingestion?
Inhalation
Ingestion Ingestion?
Inhalation
Aggregate
Concentration
Pathway?
Pathway
Pathway
Pathway?
1?
Pathway
Cancer Risk
(mg/Kg)
Toluene
•
?
•
-7.50E-03
Anthracene
1.00E-02
Fyi
• ene
Antimony:.:„!:
3.90E+01
i•xsentc.;
2—
Barium
2.00E+02
.rTn
Beryllium;.
2.30E-01
1.62E-10
numn
z..10E+02
Acetone
2.50E-01
Benzene
t
L?
5
2L
Acenaphthene
;2.30E-03
1 1 naptaion 2-
03
Copper
1.60E+03
Selenium
9.00E+01
4,07E23?
1.30E-10
f:
Acenapthylene
?
1.10E-02
L.
?
L'.6(k)fftior,:ir!thene
:35E-10
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
02
Surface Pathway Risk
Petitioned Waste Carcinogenic Risk - Surface Water Exposure Pathways
Chemical Name
Waste Stream
Total
Concentration
(mg/Kg)
Surface Water
Ingestion
Pathway
Air Particulate
Inhalation
Pathway
Fish
Ingestion
Pathway
Soil
Ingestion
Pathway
Air-Volatile.
Inhalation
Pathway ,
Surface Pathway
Aggregate
Cancer Risk
1.80E *02
Zinc.;
1.20E+0
(..)
?
)nii,fl--
1 f:30
c
'
• (YE,
---
---
Fluorene
9.30E-03
-
---
Pe!-0.,:ichl:::-.;p1--..nd
.::?
3..'.E-'
..
'?
I?
3
2.41E
?
. ,
'
nitroaniline 2-,
1.90E-0
–
Na.:A7thalene
i.
?
1,1 0E-
",...-i-'?
14
t..
Pyridine -
2.10E:02
Bis(2-ethylhexyl)pflthalate
3:40E-01
1.18E12
3.99E13
8:62E=13
4.19E-12
2.25E-18
6.63E12
If?
Duty: phEtiala-:!,
i?
31
---
Phenanthrene
5.50E02
CD s :
1 '0L+01
3.30E-02
.
2.12E-13
---
1.75E-17
S.'?(.'
,2,:
Chrysene
5.97E-14
8.57E715
2.29E-10
2:29E-:10
E--,--1,:cf 3)p
%?f
.
r
?
az
38E-11
,1
2 0
?
20
';?
-z4t...
Trichlordphenol, 2,4,5,
7.70E03
All Waste Constituents
1.61E-08 .
4.50E07 ,
1.69E-03
5.70E-08
1.90E-13
1.69E03
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
3
Maximum Allowable Total Concentrations - Surface Exposure Pathways
Maximum Allowable
Total Concentration (mg/Kg)
Chemical Name
Risk Factor =1.00E-06
1-10 Factor = 1.00E+00
*= Detection Limit
Waste Stream Total
Concentration
(mg/Kg)
Maximum
Allowable Total
Concentration
(mg/kg)
DL
Surface
Water
Ingestion
Pathway
Air
Particulate
Inhalation
Pathway
Fish
Ingestion
Pathway -
:?
Soil
Ingestion
:;':Pathway
'''
Air Volatile
Inhalation
Pathway
Di-,?
oct?
, -)r ?
i
2.57E+01
.:[..
:::: , c-7
.
f7E :0
TCDDi 2,3,7;6 ::
2;10E±04 .
7358E03
.?
.
2.69E-02 '
7;96E7:02
6:10E+03
7.58E-03
1.55E+04
Fsenz(z-i)anthr;.-ice! -
2 10E-02
1.56E+03
.)::.;
Chlbro,3methylpheriol 4-
?
:
7.70E-03,:
is-c, phoroile
f'ciE?
'',7,
2.51E+0
:c..3E.?
7
E'+05
1.14E+•06
2.:'.?
E .02-
SilVer :?
:
Z50E+01
4.93E
+04
1.04E+07
: 4.93E+04
6.42E+05
:-., 77. 4
'4'
i)G
1
26E+5`:4
Dibenz(a,h)anthracene
1.30E-02
ZOni?,: .1
4:?
:OE - )
Diethyl phthalate
5.70E-03
6.57E+05 ;
: 13.66E+09
' S.57E+05
1.03E+08
1-MAN'ant
:J
.
ne
c3E-02
8.03E+05
8 20E 4 L
% 3.3E i-O.'
8 03E+95
5 14E+06
9 54F ,08
BLitylbenzylphthalbte
.?
.
:2.70E-92
1.69E+05
414E+08' , :, 3.66E+08' : 1 : 69E+05
2357E+07
3:49E+09 "...
Benzo(b)fluo; .1-itilene
!?
-04!
1.56E+03
i
-
1?
'1 , 0E+0::!
4?
;:,;.•
?
,
Mercury':
1.50E+00
9:01E-02
:2:07E+05:.•
1 . 357+05
9.01&02
1.28E+04
2.12E+04
Benz() (giii) ;:)
---
___
N-Nitrosodiphenylamine
,3.39E-03
2.32E+03.
?
.
'8:23E4,05 . .-!2,44E+:05
8.69E+03 -2.32E+05
2..32E+03
incterc(1,2.3-
?
..1) r-
i?
7;;E:-,,,.
1.56E+03
5 53E4?
3
:
?
-;F:3E
1.56E+03
3.oaE, v.,
Be
:
nzyl alcohol ,:
1:00E:0
..
4:08E+05 :
6321E+08..`
5.49E+08 : 1.49E+08
3.85E+07
4.08E+05 :
Bromophenyi-phenyi ethet 4-
I 70E-5?.
7.21E+03
1?
20E
4
08
7 21E4-03
7 -15E40,7,
---
TOl Or* ::::
::;• 7:50E03
.
6.11E+03
1.66E+08
. 2.62E+09.
2.57E+06
1.03E+07
6:11E+03
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
1
Maximum Allowable Total Concentrations - Surface Exposure Pathways
Maximum Allowable Total Concentration
(mg/Kg)
Chemical Name
Risk Factor = 1.00E-06
HQ
Factor = 1.00E+00
*= .
Detection Limit
Waste Stream Total
Concentration
(mg/Kg)
Maximum
Allowable
Total
Concentration
(mg/kg)
DL
Surface
Water
Ingestion
Pathway
Air
Particulate
Inhalation
Pathway
Fish
Ingestion
Pathway
Soil
, ingestions
'"
;
Pathway
Air Volatile
Inhalation
Pathway
9.47E+01
---
lAnthracene
1.00E-02
2.27E+05
621E+08
...5.49E+08
227E+05
3.85E+07
--1
220E+09
?
;.
Pyrene
E.
4.78E+03
, X'.
Antimony
190E+01
-?
-
.": 2.01E+4
0
.
.8.29E+05
2
•
01E+04
5 14E+04
,=,SGM;.'.
.F,;, ,
1.68E+02
i?
:.3
...',-
7.58E+02
---
Barium?
,
2:00E+02
2.62E+06
4.14E+08
2.62E+06 - 4.02E+08
2.57E+07
T r ,
50E+02
7.71E+07
1
?•::?
:F
---
Beryllium
2.30E-01. '
1.42E+03
1.42E+03
7--
J2
1.90E+03
---
---
Acetone.::::':.;
2.50E-01
1.16E+08.
.186E+09
.4.52E+09
1.16E+08
Ranz.cr.::
3.00E-01
' ?::,
?
,
-=?
:,1,_-
Acenaphthene
.: 2.30E-03
1.98E+05
. 124E+08 . 1.10E+08 '
1.98E+05
7.71E+05
2.66E+06.,..?
-
Met{
?
-?
'
5 30E-03
--
---
Copper
1.60E+03
5.14E+06
8.29E+07 -
8.04E+07
5.14E+06
Phenol
3.85E+07
Selenium
9.00E+01
7.79E+04
1,04E+07 -
7.79E+04
6.42E+05
E
t
iz
o( k
)
.:
-1-
x
z
1.56E+04
Acenapthylene
1:10E-02
varr.?.,;;L
?
ps
.
I H
1.28E+05
2
07E i n'"
201E4-06
1.28E+05
Zinc
1 20E+05
922E+05
621E+08
922E+05
3.65E+07
Results for Analysis: Updated DRAS
2-19-08, Max values used
?
02
Maximum Allowable Total Concentrations - Surface Exposure Pathways
Maximum Allowable Total Concentration
mg/Kg}
Soii?
'-'
ingestion
Pathway
'
?
Air Volatile
Inhalation
Pathway
Chemical Name
Risk Factor = 1.00E-06
140 Factor = 1.00E+00
* = Detection Limit
Waste
Stream Total
Concentration
(mg/Kg)
Maximum
Allowable Total
Concentration
(mg/kg)
DL
Surface
Water
ingestion
Pathway
Air
Particulate
Inhalation
Pathway
Fish
ingestion
Pathway
ChromiL '
4.77E+0
„..
∎
.1?
77'--:
- ,?
:,,?
t
?
,_-.:
FlObrene
9:30E03
8.98E+05 • ::
:
7.33E+07
8:98E+05
5 14E+06
1:15E+07 '
1:)ropheno:
730E-C;3
9.47E+03
..—•:''.
?
'
<-52E+;
_,
3.85E+05
:-. ?
c' ?
••?-04
,?
.
nitroaniline.2.
1.90E-02
3.95E1-02
• 621E+06 '
5A9E+04: •
4:02E+0F:
3.95E+0Z1'•
.?
„
?
:
N,;::;t1hali?:lc:
1 50E-02
2.99E+0
'1E-4-04
---?--
2?
.)•4:.+.:-..
Pyridine •:'
2:10E4:12
1:28E+05
2:07E+06: .
1:X)6E+06?
1.28E+05
N:;e1
70E. 4
D2
1.30E+05
••,.?
30E, r_:.?
.?
.7"•-•••,-:?
tc).-•-•;
BiS(2ethylhexyl)bhthalate
3.40E-01.:.:
:288E+05 •• 8.53E+06
, •_
2.72E+03?
8.12E+04'
1•.51E+.07.H
•
out/ pn:
?
i
! 2.0E-01
3.60E+04
---
---
Phenanthrehe
: 5.50E-02
CDo .
alt
1 105 01
1.22E+03
:::-,Ei 03
---?--
Chrysene
'3,30E-02
1.56E+05,.
:5.5E+05.
3.85E+06
.
1.56E+05
1.89E+05
Bonzo(a
,
)i
y
,,rerie
1?
Y OE-02.
1.56E+02
i?
i 05
3...:r
?
, (Y,'
..::?
1 ;::•::- , :”'
?
1?
!,-;6E4 i)2
.5,.45E.: , 07
TriChlOrOphencil, 2,4,5-.
7.7003:
: 3:9'1E+05
i,2.07E+0814
3.91E+05?
1.28E+07
L'ad
C.. ...3E+C)3
4.39E+04
.,:.?
3
•
:]:E?
: (-:::
---
?
1.64E+05
---
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
03
1.23E-09?
1.08E-05
Petitioned Waste Aggregate Non-carcinogenic
Hazard
Petitioned Waste Aggregate Carcinogenic Risk
Chemical Name
CAS
Aggregate HI-Aggregate HI-
Total
Aggregate
Aggregate Risk-
Total
Number
Groundwater?
Surface
Aggregate
Risk-
',Surface
Aggregate
Pathways
?
Pathways
Hazard Index
Groundwater
Pathways
Risk
Pathways
Methylnapthalene 2-.?
91-57-6
7,00E-03
Phenol:
T08-95-2
1.08E-05
1.75E-02
Benzo(k)fluoranthene
Vanadium
Chromium
Perithttilorephen-ol
Naphthalene:
Pyridine
ii?r-caniline 2-
8:31E-07.
1.36E-10
203-96-3
7440-62-2
-3.32E-03.
1.58E-03
4.89E-03
1 46
?
02
7440-47-4
4.38E-07
9.95E-06
1.04E-05
15E-N
87,-86-5
1:86E;04
4.32E-08
1,87E-04
1,43E-07?
•
6.06E-11
1.44E-07
91-20-3
4.34E203
2.18E-08
4.34E-03
1„-92E-07
6.20E-13
1.92E-07
:,4E-07
2E-03
:6,31E-07:.
Aggregate Risk and Hazard Quotient Results
Results for Analysis: Updated DRAS 2-19-08, Max values used
Aggregate Risk and Hazard Quotient Results
Chemical Name
Petitioned Waste Aggregate Non-carcinogenic
Hazard
Petitioned Waste AggregateCorCinogenic
..,
Risk
CAS
Number
Aggregate
HI-:
Groundwater
Pathways
Aggregate
HI-
Surface
Pathways
Total
Aggregate
Hazard Index
Aggregate
Risk-
Groundwater
Pathways
AggregateiRisk-
::Surface
Pathways
Total
Aggregate
Risk
Nickel
7440-020
2.44E
c:1
7.45E05j .:
:.
E
:
2.52E-03 .?
"
Et is(2-ettiy!he
;;
.il: -03
1
'
;:•
.;::.f
6553E.12
Din-butyl phthalate
84-74-2
4.43E-04
3.34E06
4A7E04
Prienanthiene
S=r
2)1
,
;.';
---
---
Cobalt
.74-4048..4
..
732E-02
: 1.01E
7 03
7.43E02
'9.0.3&09 -
.?
9.03E-09
Ch'yset;e
21
''..
BenZo(a)pyrene
50-327.8
2.98E706 1
i1.34E08;
3.00E-06
F.
;::::Ittort . ;:heno!
•
g5-95-4
;,
„
6 7
t?
';'',i
l::
-0:5
___
___
___
Lead' :
' 7439;-92-i1 •
_
?
ntr;;;.;;21-.
S$ -Se- 2
5.00E-07
---
1 All
Waste: Constituents Excluding
Ncin
7
cletéctjRisk ;
1.11E+0
'.3A9E+00
.
?,
:
4:',60gt00
:1:91E-05
1.69E-03
1.71E4)3
Ail
'Waste Constititen03
Non-detect Fisk
1.11E+00
3.49E+00
4.60E+00
1.91E-05
1.69E-03
1.71
E-03
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
q
4
Tridhlorophenol, 2,4,5-
95=964
1.44E-08
Pyrene
129-00-0
1.16E-07
Zinc
7440=666
Toxicity Characteristic Rule
?Soil Saturation
Ecological Screen
Allowable
TC
Concentration
(mg/L)
Waste
Constituent
TCLP
Concentration
(mg/L)
Allowable Soil
Saturation
Concentration
(mg/Kg)
Lead
Actual Soil
Concentration
(mg/Kg)
Allowable
Aquatic
Concentration
(mg/L)
Predicted
Ambient
Concentration
(mg/L)
Chemical Name :
CAS Number
Toxicity Characteristic, Soil Saturation, and Ecological Values
Results for Analysis: Updated DRAS 2-19-08, Max values used
Pathways. Exceeding the Delisting Limits
Exceeding Pathways Analysis - Chemicals that exceed the delisting level
listed by exceeding pathway
Actual Total
Concentration
(mgikg)
Chemical Name
CAS Number
Actual TCLP
Concentration
(mgJL)
Limiting TCLP
Concentration
(mgfL)
Limiting TCLP
Pathway
Limiting Total
Concentration
Limiting Total
Pathway
R!a:17::...H:o.anthracene
1 05E-03
Benz(a)anthracene
5655-3
1.05E-03
3:01E-04
GW : Dermal-.Child
9,01E-02
Fish
Arsenid
7440-38-2
3.70E-03
9.36E-04
GW:lngestion:
Benzo(a)pyrene
Benzo(a)pyrene
50-32-8
2.30E-05
1.85E-05
GW Dermal-Child
Results for Analysis: Updated DRAS 2-19-08, Max values used
?
01
Site and WMU Information
Delisting Petition Number:
File Name:
Petitioner's Name:
Address 1:
Address 2:
City, State:
Zip Code:
Analysis Performed by:
Date of Analysis:
Waste Description:
Waste Code:
WMU Type:
Waste Volume (yd3):
Active Life (years):
Risk Factor:
HQ Factor:
DL-
2-20-08, Arsenic, Max values used
Peoria Disposal Company
4349 W. Southport Road
Peoria,
61615
RMT Inc.
Feb-20-2008
EAF Dust Stabilized Residue
K061
Landfill
95000
20
1.00E-04
1.00E+00
Select Chemicals of Concern to be Modeled (Steps 4 5)
Chemical Name
CAS Number
TCLP?
TCLP
Total
Total
.
Maximum
Carcinogenic
Slope
—
Carcinogenic Slope
— - ---
Reference
Concentration
(nig/L)
Detection
Limit
Concentration
(mg/kg)
Detection
Limit
Contaminant
Level (MCL)
Factor - Oral (CSFo)
(kg-day/mg)
Factor- Inhalation
(CSFi)
(kg-day/mg)
Dose - Oral ,
(RFDo)
(mg/L)
(mg/kg-day)
Results for Analysis: 2-20-08, Arsenic, Max values used
Select Chemicals of Concern to be Modeled (Steps 4 5)
Reference
Bio- concentration
Soil Saturation
?
Toxicity
Henry's Law
Diffusion
.
?
Diffusion
Solubility
Landfill
Surface Impoundment
Dose -
Factor (BCF) (L/kg)
Level
Characteristic Coefficient (H) Coefficient in Coefficient in (sop (mg/t)
Dilution
Dilution Attenuation
Inhalation
(SOILSAT)
Level (TC)
(atm-m3/mol;K)
Water (Dw)
Air (Da)
Attenuation
Factor (DAFSI)
(RFC) (mg/m
3
)
(mg/kg)
(mg/L)
(cm'/sec)
(cm'/sec)
Factor
(DAFLF)
Results for Analysis: 2-20-08, Arsenic,
Max values used?
01
Select Chemicals of Concern to be Modeled (Steps 4
5)
Time
to
reach
Skin
Tau (T) (hrs)
Bunge
Organic/
Bio. accumulation
Chronic
Carcinogen/
Molecular
Vapor
Surface Water
steady state
Permeability
Coefficient (B)
Inorganic
Factor (BAF) (L/kg)
Ecological
Noncarcinogen
Weight (MW)
Pressure (Vp)
Partition
(T*) (hrs)
Coefficient
(unitless)
, Threshhold
(gm/mol)
(atm)
Coefficient
(Kpw) (cm/hr)
(Aquatic TRV)
(Kdsw) (L/kg)
(mg/L)
( ?CO-?.,('-
,,,,
,E?
'
,t
?
0
30?
-
Results for Analysis: 2-20-08, Arsenic, Max values used
?
q
1
GAScNuriiber
Parameter, Modified:::
Parameter Ji it
•
?
:
•
..::Parameter •
Symbol ;
Value `
Arsenic
7440-38-
Cancer,'
5
List of COCs with Altered Chemical Properties
Results for Analysis: 2-20-08, Arsenic, Max values used
?
01
Chemical Name
CAS
Number
0-3&-2
11/faxipium Allowable Total
Pathway
Limiting Pathways
Detection Limit Analysis - Toxicity of Petitioned Waste cannot be confirmed if Detection Limits
fall below maximum allowable concentration
Maximum?
Maximum Allowable TCLP
Allowable TCLP
?
Pathway
Concentration
(mg/L)
9,36E-02
Grou'
Maximum
Allowable Total
Concentration
(mg/Kg)
Fish ingestion,
Results for Analysis: 2-20-08, Arsenic, Max values used
?
q
1
Groundwater Pathway Hazard Quotient
Petitioned Waste Non-carcinogenic
Hazard Quotient - Groundwater
Exposure
Groundwater
Dermal
Absorption
Pathway - Child
Pathways
Chemical Name
Waste Stream
TCLP
Concentration
(mg/L)
Groundwater
Ingestion
Pathway
Groundwater
Inhalation
Pathway.
Groundwater
Dermal
Absorption
Pathway - Adult
Groundwater
Pathway Aggregate
Hazard Quotient
,
"'l
c
-
---
—
Ail-Waste GonStituents
1.71E-02
—
1.71E-02
Results for Analysis: 2-20-08, Arsenic, Max values used
Groundwater Pathway Risk
Petitioned Waste Carcinogenic
Risk -
Groundwater Exposure Pathways
Chemical Name
Waste Stream
TCLP
Concentration
(mg/L)
Groundwater
Ingestion
Pathway
Groundwater
Inhalation
Pathway
Groundwater
Dermal
Absorption
Pathway -
Adult
Groundwater
Dermal
Absorption
Pathway
Child
Groundwater
Pathway
Aggregate Risk
Ars-,
,
r1
,
3?
,
---I
,?
%.",
All Waste Constituents
--
3
95E-06
3.95E-06
Results for Analysis: 2-20-08, Arsenic, Max values used
?
01
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
Chemical Name
Waste
Stream
Dilution
Waste
Maximum
DL
Max. Allowable
Max.
Allowable
Max, Allowable
Max.
Allowabll
TCLP
Attenuation
Volume
Allowable
Concentration
Concentration
Concentration
Concentration
Risk Factor = 1.00E-04
Concentration
Factor
(DAF)
?
Adjusted
Concentration
Based on
Based on
Based on Adult
Based
on
Child
HQ
Factor = 1.00E+00
(mg/L)
DAF
(mg/L)
Groundwater
Groundwater
Groundwater Dermal
Groundwater Dermal
*= Detection Limit
(Ingestion Pathway
Inhalation
Absorption Pathway
Absorption Pathway
I
Pathway
i r:
, r,
v;?
CE
-
,
„ '
'?
2L
-
0 1
12E±:) 1
9.36E-02
---
—
---
Results
for Analysis: 2-20-08, Arsenic, Max values used
Maximum Allowable TCLP Concentrations - Groundwater Exposure Pathways
-yet:6644ton.
Results for Analysis: 2-20-08, Arsenic, Max values used
?
El
Surface Pathway Hazard Quotient
Petitioned
Waste. Non-carcinogenic Hazard Quotient - Surface
Water. Exposure Pathways]
Chemical Name
Waste Stream
Total
Concentration
(mg/Kg)
Surface Water
Ingestion
Pathway
Air Particulate
inhalation
Pathway
Fish
Ingestion
Pathway
Soil
Ingestion
Pathway
Air Volatile
Inhalation
Pathway
Surface Pathway
Aggregate
Hazard Quotient
E-GF
All•
VVaste Constituents
3.54E-05
--
3.65E-05
5 71E-04
---
6.43E-04
Results for Analysis: 2-20-08, Arsenic, Max values used
Surface Pathway Risk
Petitioned Waste Carcinogenic
Risk - Surface Water
Soil
Ingestion
Pathway
Exposure
Air Volatile
Inhalation
Pathway
Pathways
Surface Pathway
Aggregate
Cancer Risk
Chemical Name , -
Waste. Stream
Total
Concentration
(n10(9)
Surface Water
Ingestion
Pathway
Air Particulate
Inhalation
Pathway
Fish:
Ingestion
Pathway
A
r:sert
i e
,
All:Waste
.::
Constituents "
. 8:18E-09
2.78:E-0
8i86E-09
2:905;08
7:.16E-08
?
'
Results for Analysis: 2-20-08, Arsenic, Max values used ?
q
1
Maximum Allowable Total Concentrations - Surface Exposure Pathways
Maximum Allowable Total Concentration (mg/Kg)
Chemical Name
Risk Factor =1.00E=04
HQ Factor = 1.00E+00
*= Detection Limit
Waste Stream Total
Concentration
(mg/Kg)
Maximum
?
I
Allowable Total
Concentration
(mg/kg)
DL
Surface
Water
ingestion
Pathway
Air
Particulate
Inhalation
Pathway
Fish
Ingestion
Pathway
Soil.
Ingestion
Pathway
Air Volatile
Inhalation
Pathway
1.68E+04
,-:, ,
'F:4
---
Results for Analysis: 2-20.08, Arsenic, Max values used
Aggregate Risk and Hazard Quotient Results
Petitioned. Waste.
Aggregate
Non-carcinogenic
Hazard
Petitioned Waste
Aggregate Carcinogenic Risk
Chemical Name
CAS
Number
Aggregate HI-
Groundwater
Pathways
Aggregate
HI-
Surface
Pathways
Total
Aggregate
Hazard Index
Aggregate
Risk-
Groundwater
Pathways
Aggregate 'Risk-
Surface
Pathways
Total
Aggregate
Risk
All Waste Constituents Excluding
Non-detect Risk
-
1.71 E-02
6.43EL.04
1.77E-02
3.95E-06
7.16E-08
4.02E-06
< -
1.71E-02
6.43E-04
1.77E-02
3.95E-06
7.16E-08
4.02E-06
Results for Analysis: 2-20-08, Arsenic, Max values used
?
q
1
Attachment 7
Revised Appendix H.4 Dioxin and Furan Worksheet and Summary
Dioxin Model
Spreadsheet
Page 1 of 2
INPUT VARIABLES
OUTPUT VARIABLES
Rationale modification of
assumptions
Increased from 80000 in
Waste Volume (cy/year)
95000 original provided
Slope Length
708.7
Landfill Lifetime (year)
20
Topographic Factor, LS
1.42
Covered daily
Modified from 30 days in
Period of Waste Exposure (day)
10 original
Soil eroded (kg/acre/year)
1.16E+05
Rainfall Erosion Potential, R (1/year)
Figure B-1 for Peoria area
modified from 300 in original
Value is supportable for Silty
Soil Erodibility, K (ton/acre)
0.3 Clay Loam - Not modified
Percent slope
5.00%
Cover & Management Factor, C
1
Sedimentary Delivery Ratio, Sd
0.28
Original assumption assumes
Support Practice Factor, P
no mangement practice
Soil Delivered to Stream, As (kg/acre/year)
3.25E+04
Distance to Stream (meter)
Default assumption
Percentage of Eroded Waste in Soil
0.0014
Percentage of Waste Exposed
0.0014
Annual Waste Eroded, Aw (kg/acre/year)
4.45E+01
2nd order Stream Volume (Uyear)
3.30E+09
Waste Conc. - 2nd Order Stream, (kg/L)
6.22E-07
5th order Stream Volume (L/year)
3.40E+11
Waste Conc. - 5th Order Stream, (kg/L)
6.04E-09
Dilution factor - 2nd Order Stream, (UKg)
1.61E+06
Concentration Reduction Factor
1
Dilution factor - 5th Order Stream, (UKg)
1.66E+08
Due to Addition of Reagents
CALCULATIONS
fraction organic carbon in suspended solids =
0.075 assumption
Area (acre)
46.12
minimum TSS level (erosion input only) to 2nd order stream =
454.3 mg/L
Slope Length (ft)
708.7
Slope Length-Exponent, m
0.5
Topographic Factor, LS
1.42
454.3 mg/L
Soil Eroded (ton/acre/year)
128.18
Soil Eroded (kg/acre/year)
116282
Sed. Delivery Ratio, Sd
028
Soil Delivered to S.W. (kg/acre/year)
3.25E+04
Surface Water Spreadsheet
?
Page 2 of 2
Assumptions
fraction organic carbon in suspended solids =?
0.075
background TSS concentration in stream = ?
10 mg/L
Concentration Concentration
?
Kdsw?
2nd order stream
Total Constituent (Fifth order?
(Second order?
log Koc sometimes Koc(BCF for metals etc; Surface Water
Edible Portion
Fish Tissue
Constituent
?
Concentration
?
Stream)
?
Stream)?
(log Kow?
(or Kow for
?
BAF?
Concentration
?
TEF?
Concentration from
(mg/Kg)?
(mg/L)?(mg/L)?
for organics)
?
organics)
?
freely dissolved (freely dissolved)TEQdfp-WHO98 freely dissolved
2,3,7,8-TCDD
?
1.60E-04
?
9.67E-13
?
9.96E-11
?
5.31?
2.02E+05?
9.16E+05
?
1.05E-12
?
1?
9.62E-07
Estimating Lake Trout Fish Lipid Content
sample
From Table 1, Appendix I, EPA-820-B-95-005
?
weighted
% lipid
?
samples?
percent
Lake Superior?
11.42%
?
44?0.66%
10.46%
?
71?0.97%
9.21%
?
28?
0.34%
766?
12.04% sample weighted mean of mean lipid content
trophic level 4
From Table 2, Appendix I, EPA-820-B-95-005
Lake Superior
?
10.61%
Lake Huron
?
14.12%
Lakes St. Claire and Erie
?
13.00%
Lake Michigan
?
13.70%
Lake Ontario
?
14.53%
13.19% average lipid content of Lake Trout weighing each lake equally
trophic level 4
From Table 10, EPA-820-B-95-005
Mean TCDD BAF (in fish lipids and referenced to chemical concentration freely dissolved)
To convert to a BAF for lipids in the edible portion only, multiply by the lipid concentrations above
Summary
To conservatively evaluate the bioaccumulation of chemicals in fish for the
purpose of conservative human health comparison, EPA assumed subpopulations
could be exposed to trophic level 4 Lake trout (a fatty species).
9.00E+06 salmonids
1.08E+06 from sample weighted mean of mean lipid content
1.19E+06 from average lipid content of Lake Trout weighing each lake equally
9.16E+05 current value in DRAS
10.18% lipid content assumed in DRAS
The BAF in DRAS is consistent and actually a little less than that implied by the fish lipid concentrations given in the report.
Dietary Exposure/Risk Modeling
?target hazard quotient (HQ) =?
1 unitless
target cancer risk (CR) =
?
1.00E:06 unitless
chemical concentration in fish lipid tissue (Clipids) = calculated per constituent mg/kg
fraction of fish intake from this source (F) =
fish consumption rate (CR) =
exposure duration (ED) =
exposure frequency (EF) =
cancer slope factor (CSF) =
body weight (BW) =
noncarcinogenic averaging time (AT) =
carcinogenic averaging time (AT) =
drinking water ingestion rate (adult) =-
age-adjusted drinking water ingestion factor (IFWadj) =
0.5 unitless
0.006 kg/day
30 years
350 days/year
chemical specific kg-day/mg
72 kg
30 years
75 years
2 L/day
1.07 L yr/kg day
Rationale modification of assumptions
Assumes 50% of all freshwater fish consumption is from surface water
nearest the disposal site
Fish consumption value reflects recommended freshwater fish
consumption/day - modified from 0.02 kg/day which is a recommended total
(marine/freshwater) fish consumption rate.
COPC
?
Waste Conc
?
Rfd
?
CSFo 5th order stream
?
Suring HQ
?
Suring CR Suring DL
?
Fish Concentration
?
Fishing HQ Fishing CR Fishing DL
concentration
?
Edible Portion
?
for Waste
mg/kg?
mg/kg day kg day/mg
?
mg/L
?
mg/kg
?
mg/kg
2,3,7,8-TCDD 1.60E-04
?
1.50E+05?
9.67E-13
?
0.00E+00?
9.62E-07?
2.31 E-06
?
6.94E-05
0.96ng/kg
See table on observed dioxin
concentrations in background
fish. Modeled concentration
consistent with background.
Revised Dioxin/Furan Summary
Modeling of Fish Tissue Ingestion
Pathway for Dioxin TEQs
Background
The DRAS v.2 model has a confirmed error in the surface migration/fish ingestion pathway that is
particularly problematic for those compounds which have a tendency to bioaccumulate, most notably
dioxins and furans. As a result of this known error in the available DRAS v.2 model, Mr. Todd
Ramaly, USEPA Region 5, provided a spreadsheet calculation model (USEPA email dated January 14,
2008, located in Appendix C of the Technical Support Document to the RCRA Delisting Adjusted
Standard Petition for PDC EAF Dust Stabilized Residue (TSD), filed as Attachment 2 to the Petition)
that could be used as a substitute evaluation tool. The spreadsheet calculation model corrects the
error in the DRAS v.2 model and incorporates updates to the modeling approach anticipated for the
updated DRAS v.3 model. An original dioxin and furan summary was provided in Appendix H.4 of
the Technical Support Document to the RCRA Delisting Adjusted Standard Petition for PDC EAF
Dust Stabilized Residue (TSD), filed as Attachment 2 to the Petition. This original analysis used site-
specific information for the PDC-owned Indian Creek Landfill in Tazewell County, Illinois, the most
likely receiving landfill of the delisted waste. This revised dioxin and furan summary provides a
general assessment applicable to all Subtitle D disposal facilities in Illinois, in response to comment 16
of Attachment A to the July 15, 2008 Hearing Officer Order by the Illinois Pollution Control Board.
Surface Migration/Fish Tissue Ingestion Pathway
Exposure through the surface pathway, and ultimately the fish ingestion pathway, is assumed to
result from erosion of hazardous materials from the surface of a solid waste landfill and transport of
these constituents to nearby surface water bodies. The initial component of the calculations rely on
the universal soil loss equation (USLE; Wischmeier and Smith 1978) to compute long-term soil and
waste erosion from a landfill in which delisted waste is being disposed. The amount of soil delivered
to surface water is estimated using a sediment delivery ratio, which is translated into estimates of
dissolved surface water concentrations and projected fish tissue concentrations through application of
• conservative partitioning and bioaccumulation values. In the final component of the calculations,
modeled fish tissue concentrations are incorporated into an ingestion pathway model to assess
potential risk and arrive at a delisting level.
With few exceptions, the surface migration/fish tissue ingestion pathway modeling was performed
using conservative generic parameter input values. Non-generic input values, which are determined
to be representative of any RCRA Subtitle D disposal facility in Illinois, are summarized in the
following table.
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Site Specific Model Assumptions
MODEL
VARIABLE
GENERIC
INPUT
SITE-SPECIFIC
INPUT
RATIONALE
USLE Assumptions
Waste Volume
(cy/year)
80,000
95,000
Increased to 95,000 to match maximum
allowed by the PDC Petition.
Period of Waste
Exposure (day)
30
10
The disposal area is covered on a daily basis
as required by 35 III. Adm. Code Part 811.106.
Additional intermediate cover requirements
are provided at 35 III. Adm. Code Part
811.313. The site-specific value assumes
deviation from standard practice of 10 days.
Dietary
Exposure/Risk
Model Assumptions
Fish consumption
rate (CR)
0.02 kg/day
0.006 kg/day
Fish consumption value reflects recommended
freshwater fish consumption/day (EFH, 1997)
Modified from 0.02 kg/day which is a
recommended total (marine plus freshwater)
fish consumption rate.
Fraction of fish
intake from this
source (F)
1.0
0.5
Assumes 50% of all freshwater fish
consumption for an individual is taken from
surface water immediately adjacent to an
Illinois disposal site.
The migration and exposure model for dioxins and furans is based on the assumption that waste
materials are eroded from the landfill surface and carried as sediment to the nearest stream which
supports a fishery. For licensed and permitted Subtitle D landfills in Illinois, it is important to note that,
in reality; the waste will always be covered with daily, intermediate or final cover and, therefore, will
not be subject to erosion. Furthermore, even if waste materials would be eroded from the landfill
surface, these sediments would be captured by the landfill's sediment control system, as required by
Illinois landfill regulations at 35 Ill. Adm. Code 811.103a)1). Only clear water is discharged from the
sediment basins to surface water. Therefore, the route of migration for dioxins and furans (and other
constituents) to fish is virtually incomplete.
The fish consumption value relied upon in support of the PDC delisting petition was 0.006 kg/day
(or 6 g/day). This value represents the freshwater portion of the recommended mean fish
consumption value. As presented in the Section 10.10.1 of the Exposure Factors Handbook (1997), the
generic fish consumption value of 0.02 kg/day reflects consumption of all fish including finfish
(freshwater and marine) and shellfish (marine). The recommended values for mean intake by
habitat/fish type are 6.0 g/day for freshwater/ estuarine fish, 14.1 g/day for marine fish, and 20.1 g/day
for all fish types. Although the relied upon value is not more conservative than the generic model
value, given that no Illinois disposal sites have a marine water habitat, the freshwater fish value is
more appropriate. Since the Delisting Adjusted Standard Petition for the PDC Electric Arc Furnace
Dust Stabilized Residue (EAFDSR) limits disposal to only Subtitle D facilities in Illinois, per 35 Ill.
Adm. Code 720.122(r), these fish consumption and intake modeling assumptions would apply in any
Illinois Subtitle D disposal scenario.
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The "fraction ingested" variable is intended to account in the model for the portion of an individual's
freshwater fish diet, over a 30-year period, anticipated to be harvested from surface water stream
adjacent to an Illinois disposal site. The 50 percent value was based on professional judgment reflecting
the conservative, yet highly unlikely, assumption that one-half of art individual's freshwater fish diet
over a 30-year period would be sourced from a single body of water immediately adjacent to an Illinois
disposal site.
The attached spreadsheet presents the results of an Illinois-specific LISLE and dietary exposure/risk
modeling of the maximum dioxin TEQ concentration (160 ng/kg wet weight) observed in treated waste
samples. The modeled fish tissue dioxin TEQ concentration for fish in surface water immediately
adjacent to an Illinois disposal site is 0.96 ng/kg. Estimated carcinogenic risk posed through a
conservative fish ingestion scenario is 2.3 x 10-6.
Discussion of Results
As shown in the following table, the modeled fish tissue concentration, which is likely an
overestimate given the compounding of conservative assumptions, is consistent with national
background TEQ concentrations in fish tissues.
Background Dioxin Concentrations in Fish Tissue
CATEGORY/DESCRIPTION
MAXIMUM OBSERVED
CONCENTRATION
AVERAGE
CONCENTRATION
DIOXIN
TEQ
(in
ng/kg
wet
weight)
NASQAN
(background)
(')
7.18
1.12
Background (1)
3.02
0.59
Agriculturar
4.44
1.02
North American Background (2)
- -
1.16
DRAS Modeled fish tissue concentrations in
surface water immediately adjacent to a
disposal site
(3)
0.96
(2)
Reported in USEPA's Dioxin Reassessment (USEPA, 1994)
(3) Modified DRAS v.3 spreadsheet model (original provided by Todd Ramaly, USEPA Region 5) of PDC waste materials
Dioxin/furans have been found throughout the world in practically all media including air, soil,
water, sediment, fish and shellfish, and other food products such as meat and dairy products. The
highest levels of these compounds are found in soils, sediments, and biota; very low levels are found
in water and air. The widespread occurrence is not unexpected considering the numerous natural and
anthropogenic sources that emit these compounds into the atmosphere, and the overall resistance of
these compounds to biotic and abiotic transformation. Modeled dioxin TEQ concentrations in fish
tissue are consistent with background and therefore are not expected to pose an unacceptable risk
over and above background.
(1)
Excerpted from the National Survey of Chemical Residues in Fish (USEPA, September 1992)
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