IN THE
MATTEROF:
)
)
PETITION
OF
WESTWOOD
LANDS
)
INC. for
an
ADJUSTED
STANDARD
from)
portions
of 35
Ill.Adm.Code
807.104
and
)
35
III.Adm.Code
810.103,
or
)
in
the
alternative,
A FINDING
OF
)
INAPPLICABILITY.
AS
09-03
(Adjusted
Standard
-- Land)
CLERKSS
OFFICE
JUN
222009
Pollution
STATE
OF
Control
ILLINOIS
Board
To:
(See
attached
Service List.)
NOTICE
OF
FILING
PLEASE
TAKE
NOTICE
that on
this 22
day
of
June
2009, the
following
was filed
with
the
Illinois
Pollution
Control
Board:
Petitioner
Westwood
Lands
Inc.’s
Amended
Petition
for
Adjusted
Standard,
which
is
attached
and
herewith
served
upon you.
Elizabeth
S.
Harvey
John P.
Arranz
Swanson,
Martin
&
Bell
330
North
Wabash
Avenue
Suite
3300
Chicago,
IL 60611
312.321.9100
312.321.0990
(facsimile)
WESTWOOD
LANDS
INC.
By:
CERTIFICATE
OF SERVICE
I,
the
undersigned
non-attorney,
state that
I served
a copy of the
above-described
document
to
counsel
of
record via
U.S.
Mail
at
330
North Wabash
Avenue,
Chicago, IL
60611, at
or
before 5:00
p.m.
on June
22,
2009.
[x]
Under
penalties as
provided
by
law
pursuant
to
735 ILCS
5/1-109,
I certify
that
the statements
set forth
herein
are true and
correct.
eodIi
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
4376-001
SERVICE
LIST
Westwood
Lands,
Inc.
v.
Illinois
Environmental
Protection
Agency
AS
09-03
(Adjusted
Standard
—
Land)
William
Ingersoll
Division
of
Legal
Counsel
Illinois
Environmental
Protection
Agency
1021
North
Grand
Avenue
East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
4376-001
CVED
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
0
PICE
JUN
222009
IN
THE MATTER
OF:
)
-
PoI1u
1
ILLINOIS
PETITION
OF
WESTWOOD LANDS
)
AS 09-3
rltrol
Board
INC. for an
ADJUSTED STANDARD from)
(Adjusted Standard Land)
portions
of 35
lII.Adm.Code
807.104 and
)
35 IlI.Adm.Code
810.103, or
)
in the alternative, A
FINDING OF
)
INAPPLICABILITY.
)
AMENDED PETITION
FOR ADJUSTED STANDARD
Petitioner
WESTWOOD LANDS, INC.
(“Westwood”), by its attorneys Swanson
Martin
&
Bell LLP, hereby
submits its amended petition for adjusted standard.
Background
On March
31, 2009, Westwood filed its petition for adjusted standard, or in the
alternative,
a finding of
inapplicability. Westwood seeks
a
determination that the
raw
material used in
its production process is not a “waste,” and that therefore Westwood
does
not need waste permits pursuant to the
Board’s regulations.
In the alternative, if
the
Board disagrees that the
material
used is not a waste, Westwood seeks an adjusted
standard from
portions
of
the Board’s waste regulations.
On May 21, 2009, the Board
issued
an order directing Westwood to provide additional information in support of the
petition. This
amended petition addresses the questions asked
by
the Board in
its
order, and
is intended to be read in conjunction with Westwood’s
March 31, 2009
petition.
The sections in this amended petition
coincide with the numbered
sections of
the Board’s
order.
Introduction
Westwood will
construct and operate
a
facility that will process steelmaking slag
fines to extract
the metallic
content (metallic
iron and
iron oxides) from the fines. The
metallic material is formed
into briquettes and nuggets, and will be sold to steel
manufacturers for use in the making of steel in electric arc
furnaces. The briquettes
and
nuggets are not fuel for the furnaces;
they are “raw material” and are made into steel.
There are
two commercial advantages to Westwood’s
product: 1)
because non-metallic
materials have
been greatly reduced during Westwood’s process, the
nuggets
and
briquettes have a high
level of
metallic content and are efficient material for making
into
steel; and 2) the
nuggets
and briquettes are
easy
to handle and can
be used
in
a wide
variety of
electric arc furnaces.
Westwood’s process
is completely enclosed, from the delivery of the steelmaking
slag
fines through
the production process. The fines will
be
delivered to the
facility and
unloaded inside
the production building. The fines are then put through three
stages of
size reduction;
each stage has its own dust collection
and related control equipment.
After size
reduction, the material is classified
as
coarse, medium, fine,
and very fine
fractions. The
coarse fractions are nuggets, which range in size from 1/16
of an inch to
half an
inch. The medium, fine, and very fine fractions are fed to individual
magnetic
drums,
which separate the predominately metallic
particles from the non-metallic
particles. The metallic particles are subsequently
combined with hydrated lime
and
molasses
to create briquettes. All of these operations take place within
the building,
and
are subject
to
a
series of air
pollution control equipment.
Westwood
continues
to believe,
as demonstrated in the adjusted
standard
2
petition,
that
the material
used
in the
production
process
is
not a “waste.”
(See
Petition
for Adjusted
Standard,
pp.
2-6.)
The material
does
not fit the
regulatory
definition
of
“waste,”
and
thus cannot
be
regulated
as
such.
In the
alternative,
Westwood
seeks
an
adjusted
standard.
Westwood
provides
this
additional
information
at the
request
of the
Board,
to support
that
alternative
request,
without
prejudice
to
Westwood’s
demonstration
that the
material
is not a
“waste.”
Section 1.
The Board
asks
the
effective
date of the
standards
from
which
an
adjusted
standard
is
sought.
Westwood
seeks
an
adjusted
standard
from
the following
definitions
of
35
lll.Adm.Code
807.104:
“facility,”
“solid waste,”
“solid
waste
management,”
“waste,”
and
“unit.”
Section
807.104
was first effective
on
July 27,
1973.
The
section
has
been
amended
several
times,
including
on
September
18, 1990.
Westwood
also seeks
an adjusted
standard
from
the following
definitions
of 35
lll.Adm.Code
810.103:
“facility,”
“landfill,”
and
“solid waste.”
Section
810.103
became
effective
on
September
18,
1990, and
has subsequently
been
amended
several
times.
Sections
2
through
5.
In
Sections
2 through
5,
the Board
asks
a series
of questions
about
the
applicability
of
specific
provisions
of
Part 721
of
the
Board’s
rules.
The
steelmaking
slag
fines used
by Westwood
are not
hazardous.
They
are not
listed
as a
hazardous
waste, and
do not
exhibit
a characteristic
of
hazardous
waste.
See
Exhibit
C,
attached.
1
The
steelmaking
slag
fines are
not
classified
as
hazardous
under any
of the
provisions
of
Part
721.
The steelmaking
slag
fines
are
not
“solid
waste”
under Part
721.
Section
1
Exhibits
A-F are attached
to Westwood’s
March
31, 2009
petition.
3
721.101(a)
states
that
Part 721
identifies
“those solid
wastes
that
are
subject
to
regulation
as
hazardous
wastes....”
Section 721.101(b),
“limitations
on definition
of
solid
waste,”
provides:
The
definition
of
solid waste
contained
in
this
Part applies
only to
wastes
that also
are
hazardous
for
purposes
of the
regulations
implementing
Subtitle
C
of RCRA.
For
example,
it does
not apply
to materials...
.that
are
not
otherwise
hazardous
and
that
are recycled.
(35
lll.Adm.Code
721.101(b)(1).)
This
provision
applies
to the
steelmaking
slag
fines.
The
fines
are
not
hazardous,
and thus
the definitions
of
“solid waste”
contained
in
Part
721 do not
apply
to
the
fines.
Further,
Part
721,
Appendix
Z is
a chart
used
to categorize
materials
as
solid
waste
(or
not solid
waste)
under
Part
721.
None
of the
categories
on
the left-hand
side of
Appendix
Z applies
to the
steelmaking
slag
fines.
The
fines
are
not
a “spent
material,”
which
is defined
as a
“material
that has
been used
and
as a
result of
contamination
can no
longer
serve
the purpose
for
which it
was
produced
without
processing.”
(Section
721
.1 01(c)(1
)(emphasis
added).)
The
fines
are
not sludge,
either
listed
or exhibiting
a
characteristic
of
hazardous
waste.
Likewise,
while
the
steelmaking
slag fines
could
be considered
a
“by-product”
as defined
by Section
721.101(c)(3),
the
fines are
not
listed in. Sections
721.131
or 721.132,
nor
do
they
exhibit
a
characteristic
of hazardous
waste.
Thus,
the fines
do
not
fit
the
“by-product”
categories
in Appendix
Z.
Finally,
the
steelmaking
slag
fines are
not
a commercial
chemical
product,
nor are
they scrap
metal.
None
of the
categories
in Appendix
Z
apply
to the steelmaking
slag
fines.
The
steelmaking
slag
fines
are not
listed hazardous
waste.
K177
waste
listed
in
Section
721.132(a)
applies
to
“wastes”
from inorganic
chemical
production,
not
to
4
materials
generated
from
steel
production.
Further,
even
if the
K177
definition
applied
to
steel
production,
the
slag
fines
are
not “speculatively
accumulated
or disposed
of,”
as
provided
in
the
definition
of
K177
wastes.
Section
6.
The
Board
asks
if the
steelmaking
slag
fines
constitute
an Illinois
special
waste.
They
do
not.
Under
the
current
“special
waste”
statutory and
regulatory
scheme,
the
steelmaking
slag
fines
are
eligible
for
self-certification
by
the
generator (for
example,
U.S.
Steel)
that
its
industrial process
waste
is
not
“special
waste,”
pursuant
to Section
22.48
of
the
Act.
(415
ILCS
5/22.48.)
The
steelmaking
slag
fines,
even
if considered
industrial
process
waste,
do not
fit
into
any
of the
categories
(i.e.,
liquid
waste,
contains
asbestos
or
PCBs,
delisted
hazardous
waste,
decharacterized
hazardous
waste
or
a
waste
resulting
from
shredding
recyclable
metals)
which
would
prohibit
the
generator
from
self-certifying
the
waste
as non-special
waste.
Westwood
will
utilize
only
slag
fines
which
have
a
certification
from
the
supplier
that
the
fines
are
not
special
waste.
Section 7.
The
Board
asks
several
questions
about
the
parameters
Westwood
uses
to
evaluate
whether
specific
fines
are
appropriate and
useful
for Westwood’s
process.
The
most
important
parameter
for
Westwood’s
process
is
that
the
steelmaking
slag
fines
have
a
metallic
content
of
50%
or
more.
That
level
of
metallic
content
is
necessary
for
Westwood’s
process
to produce a
saleable
product. The
exact
amount
of
metallic
content
needed
in
the
raw
material
(the
steelmaking
slag)
can
vary
with
market
conditions
such
as
the
price
of
:metals.
The
metallic
content
of
the
raw
material
5
obviously
impacts
the metallic
content
of the
finished
products.
Under
fluctuating
market
conditions,
the
amount
of
metal
in
the
finished
product
needed
to
make
the
product
saleable
can vary.
Therefore,
it is not
possible
to
establish
a hard
and
fast
percentage
of
metals
needed
in
the
steelmaking
slag fines.
However,
a
figure
of
50%
or
more
is a
general
guide.
The
steelmaking
slag
fines
are
not
hazardous,
and
Westwood
will
ensure
that
no
hazardous
material
is
included
in the
fines.
Westwood
has
received
test
results
from
the
generator
of
the
steelmaking
slag
fines
(U.S.
Steel)
that
demonstrate
the
fines
are
not
hazardous.
Westwood
plans
to
contract
with
suppliers
in
addition
to
U.S.
Steel,
and
will
require
those
suppliers
to
provide
test
results
showing
that
the
fines
are not
hazardous.
2
Requiring
testing
of
each
load
of fines
would
render
the
process
unworkable
and
not
economically
viable.
Requiring
test
results
of
a representative
sample
of
a
supplier’s
fines
will allow
Westwood
to
ensure
that
its raw
materials
are
not
hazardous.
3
In
addition
to
ensuring
that
the steelmaking
slag
fines
contain
the
appropriate
metallic
content,
and
that
the
fines
are not
hazardous,
Westwood
will
also
visually
examine
the loads
for
trash
or
any
other
“non-fine”
material.
If
any load
contains
items
other
than
steelmaking
slag
fines,
Westwood
will
either
remove
those
items,
or
reject
the
load,
depending
upon
the
circumstances.
For
example,
and
speaking
theoretically,
if a
load
contains
a
single
piece
of
non-fine
material
(such
as
wood),
it
would
be most
2
It
is possible
that Westwood
will sometimes
have the
tests performed, of a representative
sample
provided
by
the supplier.
Regardless
of
whether
the tests
are
performed
by
the
supplier
or
by
Westwood,
there
will
testing
of representative
samples
of steelmaking
slag fines
from
all suppliers.
This
procedure
of obtaining
test
results
of
a
representative
sample
is
similar
to
the procedures
used
to
test
waste
before
acceptance
at
a
landfill.
6
efficient
for
Westwood
to
simply
remove
that
non-fine
material,
rather
than
reject
the
load.
However,
if
there
is
a
large
amount
of
non-fine
material
in a
load,
or
if
Westwood
has
reason
to
suspect
that
the
load
might
contain
off-specification
fines,
Westwood
would
reject
the
load.
Section
8.
The
Board
asks
about
the end
market
for
the
coarse
fractions
generated
by
Westwood’s
process.
The
end
market
for Westwood’s
product
is
the
same
regardless
of
whether
the
product
comes
from
the
coarse
fractions
or from
the
medium,
fine,
and
very
fine
fractions.
It is
useful
to
visualize
the
bulk
form
of the
coarse
fractions
as
nuggets,
which
range
in size
from
approximately
1/16 of
an inch
to
half
an
inch.
Those
nuggets
will
be
sold
for
use in
electric
arc
furnaces
used
for steelmaking. Quite
simply,
the
extracting
of
the
metals
from
the
steelmaking
slag and
forming
the
extracted
metals
into
nuggets
allow
those
nuggets
to be made
into steel.
The contract
between
Westwood
and
U.S. Steel
(included
as
Exhibit
A
to
the
petition)
includes
provisions
for
U.S.
Steel
to
purchase
Westwood’s
products.
(See
redacted
Section
10
of
Exhibit
A, claimed
as a
trade
secret.)
4
Westwood
has
had
discussions
with
other
possible
purchasers,
but
has
not- yet
entered
into
formal
contracts.
Because
Westwood
cannot
be sure
when
its
facility
will be
permitted
and
operational,
it is
impossible
for
Westwood
to
enter
into formal
contracts
at this
time.
Section
9.
•
None
of
Westwood’s
end
product
will
be
used as
soil
amendment
at
abandoned
mines
or
for
land
reclamation
projects.
Westwood’s
product
is
much
too valuable
to he
On
March
31, 2009,
Westwood
claimed
trade
secret protection
for portions
of the
contract
between
Westwood
and U.S.
Steel
(Exhibit
A),
and for
portions
of the
correspondence
between
Westwood
and Stein,
Inc.
(Exhibit
C).
7
used in such a
way; the
product contains a
high
amount
of metallic content, and
will
be
sold for use in
making steel in
electric
arc
furnaces. Because the
product.will
be
sold
on
the open
market to
steel manufacturers, and not used as
soil amendment, Westwood -
does
not
plan
to
work
with state agencies
on land reclamation or
soil amendment
projects.
Westwood included the
information
that its raw material (the
steelmaking
slag
fines)
has
been approved
for such soil
amendment use only to
demonstrate that there
should
be
no
concern that the raw
material is an environmental threat.
Section 10.
As
discussed
above in Section 8,
the end market for Westwood’s briquettes is
the same as
the end
market for the
nuggets; they will be sold for use in steelmaking in
electric arc
furnaces.
Westwood has an
agreement with
U.S.
Steel regarding
the
purchase
of Westwbod’s
products.
Westwood has pursued discussions
with
other
potential
purchasers, but cannot at
this time enter into formal contracts because of the
uncertainty
about when the facility
will be operational.
Section
11.
The
Board asks
for information on
the
calcium magnesium silicate that will
remain at
the end of
Westwood’s process. Roughly one-third
(by
weight) of the raw
material
(the
steelmaking slag fines) will be usable product
(the
nuggets and
briquettes),
while
the
remaining two-thirds will be
the calcium
magnesium sulfate.
5 The calcium
magnesium
sulfate is not
a
listed or hazardous waste; test results
are
attached
as
Exhibit H.
Two
landfills
have already approved the
calcium magnesium sulfate for
disposal
at
their non-hazardous facilities.
Westwood
provided test results for the
Westwood
acknow’edges that its March 31, 2009 petition
used the word “small” when describing
the
percentage of calcium magnesium
sulfate remaining at
the end of the process. That adjective
should
not
have been
used.
8
calcium
magnesium sulfate
to a Waste Management
facility
and to the
Perry Ridge
Landfill. Both
facilities
verbally
indicated
they would accept
the calcium magnesium
sulfate
when Westwood’s
facility becomes
operational.
In fact, it was one
of the landfills
that indicated the
calcium
magnesium
sulfate may
be approvable as
cover material.
Westwood
may
use
landfills
in Illinois, but would
utilize any
permitted landfill that
makes
economic sense.
Disposal fees and
other market
conditions change,
so that the
landfill
which makes sense
at one time
might not
be the preferred
disposal
location
at
another
time. Westwood
needs
the flexibility to
respond
to changing
conditions in
choosing
the disposal
facility. Of course,
Westwood will use
only permitted
facilities.
The
calcium magnesium
silicate is
not
an Illinois
special waste. Under
the
current
“special waste”
statutory
and
regulatory scheme,
the calcium magnesium
silicate
is
eligible for self-certification
by
Westwood
that its industrial
process waste
is
not
“special waste,”
pursuant to
Section 22.48
of the Act. (415
ILCS 5/22.48.)
The
calcium
magnesium
silicate, even
if considered industrial
process waste,
does not
fit
into any
of the
categories
(liquid waste,
contains asbestos
or
PCBs, delisted
hazardous
waste,
decharacterized
hazardous waste
or
a
waste resulting
from
shredding recyclable
metals)
which would prohibit
the generator
from
self-certifying
the
waste as non-special
waste.
Westwood
will self-certify
that the calcium
magnesium silicate
is
not
a special
waste.
Section 12.
Westwood
noted
in its
petition for adjusted
standard that it
is possible
the calcium
magnesium
silicate remaining
at the end of the
production
process could
be approved
for use as
landfill cover.
One of the
landfills that has
verbally
approved the
calcium
9
magnesium
silicate
for disposal originally
suggested
that
possible
use.
Westwood has
not yet fully
explored
the testing
and
approval
process, and
has
not determined
whether
it would
be able to
sell that silicate
for
cover.
Westwood is concentrating
on
obtaining
approval
for its
facility to operate,
but will
continue
to explore
possibilities
for beneficial
uses of
the calcium
magnesium silicate.
Westwood
believes there may
be
other
uses of
the silicate
beyond
landfill cover, but has
not
yet
determined whether
other uses are
viable
and
approvable.
For purposes
of this petition, Westwood
presumes
that it will
dispose
of the
calcium
magnesium
silicate at an
approved landfill.
Section
13.
The two buildings
at the Westwood
facility in
Madison, Illinois,
were constructed
in 2006
and 2007.
That facility has
not yet operated because
of IEPA’s
position
that the
facility needs
local siting
approval
as
a “pollution
control facility”.
6
The facility
is located
at 4
Caine
Drive
in Madison,
and is on a parcel
measuring
4.94 acres. The
area around
the
Westwood
facility is zoned for
commercial
use.
The
Westwood
facility
will
employ approximately
12 people
per shift, and run
two
shifts
per
day.
Thus,
the
facility
will create jobs
for
approximately
24 people.
Additionally,
Westwood plans
to contract
with local trucking
companies
for the trucking
of the
raw materials
(steelmaking slag
fines) to
the facility, and for
the trucking
of the
finished
product (nuggets
and
briquettes)
to the purchasers.
Thus,
local truck drivers
will
have
additional work
as a result of
the Westwood facility.
The
facility will
have a
complete
system
of
air pollution control
equipment,
including
cyclones,
baghouses,
bin vent
filters, and stacks.
Please note
that
6
As
noted
in
Westwood’s
petition, the
facility
will
need an
air permit
before it operates. This
petition
is
limited to
“waste”
issues, and does not
involve the air permit.
10
Westwood’s
process is conducted
inside,
so
that
dust
or
particulate
matter
generated
by
the
process
are fully
contained
and
routed
through
the
air
pollution
equipment.
The
primary
dust
collection
system is
Baghouse
#1.
Fines
from
Baghouse
#1
will
be
routed
to
a second
baghouse,
and
the
fines
from
that
second
baghouse
will
be routed
to
Baghouse #3.
There
will also
be
bin
vent
filters
on
the silos
used
to
store
the raw
material,
and
the airstream
that
results
from
transporting
of
the
end
product
within
the
enclosed
facility
will
also
be vented
through
a
bin
vent
filtering
system.
Westwood
will
obtain
an
air
permit
prior
to
operating.
Details
of
the
air
pollution
control
equipment
will
be
approved
by
IEPA.
Section
14.
As
explained
in the
petition
for
adjusted
standard
(see
page
7-8)
and
above,
Westwood’s
process
occurs
entirely
within
its
production
building.
This
includes
storage
of
the
fines
before
processing.
The
incoming
fines,
which
arrive
by
truck,
are
unloaded
within
the
building
and
stored
inside
until
used
in
Westwood’s
process.
The
entire
production
process
occurs
inside.
After
the nuggets
and
briquettes
are
complete,
they
are
stored
on
a large
pad,
which
will
be
covered.
Because
the
fines
used
in
the
process,
as
well
as
the
finished
product,
are
not
stored
outside and
are
not
exposed
to
the elements,
there
is no
need
for
stormwater
runoff
permits.
There
may
be
some
misunderstanding
about
the
statement
of the
mayor
of
Madison
that
the
facility
is located
adjacent
to the
area
where
slag
may
be
stored.
(See
Exhibit
D.)
The
mayor’s
reference
is
to
the
area
where
slag
is
currently
stored
on U.S.
Steel’s
property,
not to
storage
of slag
on
Westwood’s
property.
The
Westwood
facility
is
located
nearby
to
the
U.S.
Steel
facility,
which
results
in efficiencies
in
transporting
11
the
slag
to
Westwood. The slag
is unloaded
at Westwood
inside the
building, and
stored in hoppers
until use
in the
production process.7
There
are no piles of slag
at
Westwood, and
thus no
concern about
the
height of the piles
or exposure of
the slag to
the
elements.
Section
15.
The Board asks
about
the
testing
Westwood
would require or
perform
to
determine
whether steelmaking
slag
fines
from
sources
other
than U.S. Steel
are
acceptable.
Westwood
would
obtain t.he same
information
from .other
suppliers
as
it has
from U.S.
Steel. As
previously
described in
Section 7, the
most important
parameter to
Westwood’s
process
is that the slag
fines have
a
metallic content
of approximately
50%
or
greater.
Of
course,
Westwood
would require
the
same
testing to demonstrate
that
the
fines
are
not hazardous
as
it obtained
from U.S.
Steel. As described
in Section
7,
Westwood
will
obtain
test
results for a
representative
sample of any supplier’s
fines
(U.S.
Steel or
any other
supplier) to ensure
that the fines
are not hazardous.
This is
similar
to the
process used
for disposal of
waste
at
a
landfill, where a representative
sample
is
tested in
advance of
disposal.
No
steelmaking slag
fines will be used,
from
any
supplier,
without
testing of a
representative sample.
Section
16.
Westwood
believes it
is
unnecessary to
include,
in the
language
of the adjusted
standard,
conditions
specifying
the parameters
of acceptable slag
fines. As explained
in
Section
7, the
metallic content
required for
Westwood’s
process
to
produce a
saleable
product may
vary over
time, depending upon
market conditions.
Thus,
Westwood estimates
that
slag stored in its hoppers
will be used in its
process
in
a week or less.
The slag
will
not be
stored
long-term at Westwood.
It is to Westwood’s
benefit to use the
slag in
its
process
as
quickly
as
possible,
so
it
is
not storing raw
material for which it has
paid.
12
including
a
specific
percentage
of
metallic
content
in
the language
of the adjusted
standard
would
limit
Westwood’s
ability
to respond
to
changing
market
conditions.
Conversely,
including
a percentage
of
metallic
content
in the
adjusted
standard
would
not
result
in
any environmental
benefit.
Of
course,
Westwood
would
agree
to
language
that the
steelmaking
slag
fines not
be hazardous
or contain
asbestos,
PCBs,
or a
listed
hazardous
waste.
8
Westwood
would
reject
a load
if that load
contained
a
large amount
of
trash
or
material
that
is
not steelmaking
fines.
Additionally,
Westwood
would
reject a load
that
appeared
materially
different
than
steelmaking
slag
fines ordinarily
used
in the
process,
or if
Westwood
had
any
other
reason
to
believe
the fines
were
hazardous,
or
contained
asbestos,
PCBs
or
a listed hazardous
waste.
It should
be noted
that it
is to
Westwood’s
benefit
to
ensure
that
it
uses
only
raw
materials
(steelmaking
slag
fines)
that
are
suitable
for its process,
and
do
not
contain
other
materials
that
are
hazardous,
contain
asbestos,
PCB5,
or
listed
hazardous
waste.
Westwood
is
committed
to
complying
with
environmental
standards
and
regulations,
and to
running
an
efficient
operation.
In
order
to achieve
those
goals,
and
in order
to
produce
a
saleable
product
in
an
economically-
efficient
manner,
it is
essential
to
Westwood
that
it
use
only steelmaking
slag
fines that
meet the
parameters
of
the
representative
samples.
As
described
in
Section
7,
requiring
testing
of each
load of
fines
received
at
Westwood’s
facility
would
render
Westwood’s
process
unworkable
and
not
economically
viable.
Westwood
requires
suppliers
of fines
to
provide
test results
of a
representative
sample
of
steelmaking
slag
fines,
so
that Westwood
can
ensure
that
its
8
Westwood
believes
those
limitations
are
already
presumed
in
the
proposed
language
of
subsection
(4),
that Westwood
operates
its
facility
in
compliance
with other
provisions
of
the
Environmental
Protection
Act,
but would
agree that
limitations
be more
specifically
spelled out.
13
raw
material
is
consistent,
non-hazardous,
and
contains
the
metallic content
needed
for
Westwood’s
process.
9
This
process
is
simHar
to the
representative
sample
process
used
at landfills
in
Illinois:
landfills do
not test
each and
every
load
of
waste
coming
into
the facility.
Instead,
they
require
testing
of a
representative
sample
of a waste
stream,
to
ensure
that
waste
stream
can be
disposed
at their
facility.
Westwood
does
not in
any
way
admit
or
imply
that
its
facility
is a
“landfill”:
it
is
a
production
facility, and
not a
“disposal”
facility.
Westwood
uses
this example
only
to
demonstrate
that
there is
no
need
for
testing of
each load
of fines
received
at Westwood’s
facility.
If
Westwood
finds,
after
slag
fines
arrive
at its facility,
that
the slag
fines
exhibit
a
characteristic
of hazardous
waste
or
contain
asbestos,
PCBs, or
a listed
hazardous
waste,
Westwood
will
reject the
load
and return
the
fines
to the
supplier.
Westwood
would
agree to
such
a condition
in the
language
of
the
adjusted
standard.
Westwood’s
costs
to achieve
the
proposed
adjusted
standard
are
similar
to
the
costs
necessary
to
operate
its
process.
Because
the proposed
adjusted
standard
would
exempt
Westwood’s
facility from
the
specified
definitions,
there
are no
additional
costs
of
achieving
compliance
with
the
adjusted
standard.
The
costs
of testing
the
steelmaking
slag
fines
will sometimes
be borne
by
the
supplier.
Where
Westwood
undertakes
the
testing
of representative
samples
provided
by the
supplier,
Westwood’s
costs
do not
increase
as
a
result
of the
adjusted
standard
because
Westwood
will
undertake
that
testing
in
any
event.
Westwood
would,
however,
be
faced
with
huge
costs
if
it
does
not
obtain a
finding of
inapplicability
or
an adjusted
standard.
In those
events,
Westwood
would
be
As noted
above,
it is
possible
that Westwood
would
arrange
for testing
of a representative
sample
provided
by
a supplier.
Regardless
of who
performs the
testing,
no fines
will be used
without testing
a
representative
sample.
14
forced to obtain
local
siting
approval
and
to
comply with the myriad
requirements
of the
Illinois
solid
waste regulations.
Obtaining local
siting approval
is extremely expensive,
as the
Board is aware.
The fee for
filing a
siting
application is
often more than
$100,000,
and
the
costs of proceeding
with
a
siting
hearing are equally
high.
Having
to
obtain local
siting approval
and comply
with
the
Illinois
solid waste regulations
would
almost certainly
render it
economically impossible
for Westwood
to construct
and
operate its proposed
facility.
Section
17.
In Section
17, the
Board asks several
questions
about
IEPA’s approval for
steelmaking
slag
to be used as a
soil amendment in
mine
reclamation
projects.
As
Westwood has
previously addressed
in this amended
petition
(see
Section
9),
Westwood included
the information
that steelmaking
slag from U.S. Steel
had
been
approved
for a
specific
soil amendment
use only to demonstrate
that the
raw material
used
in Westwood’s process
is not an environmental
threat.
Westwood’s
end
product
will not be used
as a soil amendment
or for
land reclamation.
Westwood
had no involvement
in the approval
process for the use
of
steelmaking
slag
fines as a soil
amendment, and•
cannot
answer
specific
questions about
that
approval.
Because the use
of steelmaking slag
fines as a soil amendment
is not
related
to
Westwood’s process
or to the use
of its product, the
testing
or
types
of slag used
are
not
directly
relevant to this
petition. Based
on
the correspondence
approving
the use,
however,
IEPA agreed that
the use
of
steel
slag fines
as a soil amendment
is a “not
otherwise
prohibited use,”
and therefore
is
allowed
under 35
IlI.Adm.Code817.101(c).
(See
ExhibitF.) Section
817.101(c)
provides that
Part 817
does
not
apply to “the
not
15
otherwise
prohibited
use of iron
and steelmaking
slags, including
the use
as a base
for
road building,
but not including
use
for land
reclamation
except as
allowed
under
subsection
(e).”
1°
Section
18.
V
The Board
notes
that the
unredacted
portions
of
contract
between
Westwood
and U.S.
Steel discuss
different
types
of steelmaking
slag fines.
The
Board
asks which
types of
slag fines will be used
in Westwood’s
process.
Westwood will
purchase,
from
U.S.
Steel, all
types of steelmaking
slag
fines discussed in
the
contract:
desulfurization
slag
fines,
steel slag fines, and
ladle
metallurgy
facility (LMF)
slag. All
of those types of
steelmaking
slag
fines will be used
in
Westwood’s
process. The
contract
between
Westwood and
U.S. Steel
uses the
term “steelmaking
slag fines” as
an inclusive term
for
slag fines
generated
from the processing
of
raw steelmaking
slag. “Desulfurization
slag fines,”
“steel slag fines,”
and “ladle
metallurgy facility
(LMF) slag” are
categories of
“steelmaking
slag fines.”
(See unredacted
Sections
1.3, 1.3.1, 1.3.2,
and 1.3.3
of
Exhibit
A.’)
In
its petition for adjusted
standard,
and
in
this amended
petition, WestWood
uses
the
phrase “steelmaking
slag
fines”,
as
that
phrase is defined
in the U.S. Steel
contract,
as an inclusive
term to
refer
to
all types of steelmaking
slag fines.
Section 19.
Please see
Sections
7 and
15 for
a
description
of
the testing
of
the
fines to
ensure
they are not hazardous
wastes (by
characteristic or
listing), do not contain
asbestos, PCB5
or other
listed hazardous
wastes,
and are suitable
for use in
Westwood’s
process.
As
described,
it is essential to
Westwood to ensure
the
quality of
10
Westwood notes
that Section
81 7.101(f)
provides “This Part
shall not
apply to the use or reuse
of
iron and
steelmaking,slags
and
foundry
sands as ingredients
in an industrial process
to make
a product.”
Thus,
it is clear
that
Part 817
does not
apply to Westwood.
16
the
fines
it
receives,
both
in
order
to
comply
with
environmental
regulations
and
to
ensure
its
process
proceeds
in
an efficient
and
economic
manner.
If the
Board
has
concerns
about
the
statement
in
the
U.S.
Steel
contract
that
U.S.
Steel
does
not
warranty
the
quality
of
the
steelmaking
slag
fines,
Westwood
again
points
to
the
specific
provision
that
Westwood
may
“reject
any
materials that
may
have
a
chemical
analysis
that
does
not
fit
the
parameters
needed
to
make
a
quality
product.”
(Unredacted
Section
4.2
of
Exhibit
A.)
Westwood
has,
and
will
exercise,
an
absolute
right
to reject
any
fines
that
do
not comply
with
environmental
regulations
or with
the
metallic
content
required
for
its
process.
Conclusion
Westwood
Lands,
Inc.
has
demonstrated
that
the
steelmaking
slag
fines
used
in
its
process
are
not
a
“waste.”
Therefore,
Westwood
seeks
a finding
of inapplicability,
with
the
result
that
Westwood’s
facility
does
not need
waste
permits
pursuant
to
Parts
807
and
810 of
the
Board’s
rules.
Alternatively,
if
the Board
disagrees
that
the
material
is
not
a
“waste,”
Westwood
seeks
an
adjusted
standard
from
the
specified
portions
of
Sections
807.104
and
810.103.
Respecifully
submitted,
WESTWOOD LANDS,
INC.
BY:&
Dated:
June22,2009
17
TEKLAB,
INC.
5445
HORSESHOE
LAKE
ROAD
COLUNSVILLE,
ILLINOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
January
18,
2007
Carl
Cannon
U.S.
Steel-Granite
City
Works
20th
&
State
Streets
Granite
City,
IL
62040
TEL:
(618)451-3013
FAX:
(618)451-4020
RE:
Steelmaking
Slag
C-Fines
Dear
Carl
Cannon:
TEL:
618-344-1004
FAX:
618-344-1005
OrderNo.
07010324
TEKLAB,
INC
received
1
sample
on
1/11/2007
3:35
:00
PM
for
the
analysis
presented
in
the
following
report.
A
list
of
report
contents.
can
be
found
on
the
following
page.
Samples
are
analyzed
on
an
as
received
basis
unless
otherwise
requested
and
documented.
The
sample
results
contained
in
this
report
relate
only
to
the
requested
analytes
of
interest
as
directed
on
the
chain
of
custody.
IL
ELAP
and
NELAP
accredited
fields
of
testing
are
indicated
by
the
letters
NELAP
under
the
Certification
column.
All
quality
control
criteria
applicable
to
the
test
methods
employed
for
this
project
have
been
satisfactorily
met
and
are
in
accordance
with
NELAP
except
where
noted.
The
following
report
shall
not
be
reproduced,
except
in
full,
without
the
written
approval
of
Tekiab,
Inc.
If
you
have
any
questions
regarding
these
tests
results,
please
feel
free
to
call.
Sincerely,
A.
—‘c
Kelly
A.
Klostermann
Proj
ect
Manager
(618)344-1004
ex.11
IL
ELAP
and
NELAP
Accredited
-
Accreditation
#100226
IDPH
Registry
#17584
.0
.0
a
Page
1
of
4
IT
NELAP
Accredited
#1002Z6
TEKLAB,
INC.
5445
HORSESHOE
LAKE
ROAD
COLLINSVJL±E,
ILLINOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
TEL:
618-344-1004
FAX
618-344-1005
Client:
U.S.
Steel-Granite
City
Works
REPORT
CONTENTS
Project:
Steelmaking
Slag
C-Fines
LabOrder:
07010324
Report
Date:
January
18,
2007
This
reporting
package
includes
the
following:
Analysis
Results
(
this
document)
4
pages
Chain
of
Custody
I
pages
Sample
Receipt
Checklist
I
pages
Associated
Infonnation
NA
pages
Sample
Summary
NA
pages
Dates
Report
NA
pages
QC
Report
NA
pages
Sub
Contracted
Lab
Report
NA
pages
v1DL
Report
NA
pages
IL
ElfiP
and
NELAP
Accredited
-
Accreditation
#100226
IOPH
Registry
#17584
Page
2
of
4
5445
HORSESHOE
LAKE
ROAD
TEI(LAB,
INC.
COLUNSVILLE,ILLINOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
TEL:
618-344-1004
FAX:618-344-1005
Client:
U.S.
Steel-Granite
City
Works
CASE
NARRATIVE
Project:
Steelmaking
Slag
C-Fines
LabOrder:
07010324
Report
Date:
January
18,
2007
Cooler
Receipt
Temp
5.6
°C
Original
Chain
of
Custody
and
sample
receipt
checklist
are
on
file
at
Tekiab.
See
the
sample
receipt
checklist
for
any
noted
deviations
from
NELAP
sample
acceptance
policies.
Qaslifiers
DF
-
Dilution
Factor
B
-
Analyte
detected
in
the
associated
Method
Blank
£
-
Value
above
quantitation
range
RL
-
Reporting
Limit
J
-
Analyte
detected
below
reporting
limits
H
Holding
time
exceeded
ND
-
Not
Detected
at
the
Reporting
Limit
K
-
RPD
outside
accepted
recovesy
limits
D
-
Diluted
out
of
sample
Surr
-
Surrogate
Standard
added
by
lab
S
-
Spike
Recovesy
outside
accepted
recoveTy
limits
MI
-
Matrix
interference
TNTC
-
Too
numerous
to
count
X
-
Value
exceeds
Maximum
Contaminant
Level
DNI
Did
Not
Jgnitc
IDPII
-
flhinois
Department
of
Public
Health
NEJAP
-
IL
ELAP
and
NELAP
Accredited
Field
of
Testing
L
IL
ELAP
and
NEL4P
Accredited
-Accreditation
#100226
IDPH
Registry
#17584
Page
3
of
4
5445
HORSESHOE
LAKE
ROAD
ENVIRONMENTAL
TESTiNG
LABORATORY
TEL
618-344-1004
.
V
FAX:618-344-1005
Laboratory
Results
CLIENT:
U.S.
Steel-Granite
City
Works
Client
Project:
Steelmaking
Slag
C-Fines
WorkOrder
07010324
Client
Sample
ID:
Slag
C-Fines
Lab
ID:
07010324-001
Collection
Date:
1/11/2007
10:00:00
AM
Report
Date:
1
8-Jan-07
Matrix:
SOLID
Analyses
Certification
RL
Qual
Result
Units
DF
Date
Analyzed
Analyst
ASTM
03987.
EPA
600
160.1.
IN
SHAKE
EXTRACT
Total
Dissolved
Solids.
SHAKE
20
432
mg/I.
1
1/17/2007
CDII
ASTM
P3987.
SW-$46
3005A.
601gB.
METALS
IN
SHAKE
EXTRACT
BY
ICP
ArsenIc
0.0250
<
0.0250
mg/I
1
1/16/2007
12:47:28
PM
LAL
Barium
0.0050
0.0208
mg/I
1
1116(2007
1
2:47:28
PM
I_Al.
CadmIum
0.0020
<
0.0020
mg/I
1
11161200712:47:26
PM
1.41
Chromium
0.0075
<
0.0075
mg/I
1
1/16/2007
12:47:28
PM
LAL
Copper
0.0100
<
0.0100
mg/I
1
1/16/2007
12:4128
PM
1.41
Iron
0.0200
‘C
0.0200
mg/I
1
1/16/200712:4728
PM
1.41
Manganese
0.0050
<
0.0050
mg/I
1
11161200712:47:28
PM
LAL
Selenium
0.0500
‘C
0.0500
mg/I
1
1/16/200712:47:28
PM
1.41
ZInc
0.0100
<
0.0100
mg/I
1
1/16/200712:47:28
PM
LAL
ASTM
03987.
SW-846
3020A.
METALS
IN
SHAKE
EXTRACT
BY
GFAA
Lead,
SHAKE
by
GFAA
V
7421
V
0.0020
<0.0020
mg/I
1
1/18/2007
JMW
ASTM
D3987,
SW-546
9038.
iN
SHAKE
EXTRACT
V
Sulfate
5
22
mg/I
1
1/17/2007
SMK
ASTM
03987.
SW-848
9210.
iN
SHAKE
EXTRACT
Nitrate.
SHAKE
V
0.20
H
0.40
mg/I.
1
1/16/20073:00:00
PM
KIE
ASTM
03967.
SW-84$
9214.
iN
SHAKE
EXTRACT
fluoride
0.10
0.34
mg/I
1
1/1612007
AET
ASTM
03987.
SW-846
9251.
IN
SHAKE
EXTRACT
Chloride,
SHAKE.
I
3
mg/I
1
1/16/2007
9:45:00
AM
MVS
Sample
Nirrative
TEKLAB,
INC.
COLLINSVILLE,
ILLINOIS
62234
IL
ELAP
and
NELAP
Accredited
-
Accreditation
#100226
.
IDPH
Registry
#17584
Page
4of4
TEKLAB,
INC.
5445
HORSESHOE
LAKE
ROAD
COLLINSVILLE,
ILLINOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
January
16,
2007
Carl
Cannon
U.S.
Steel-Granite
City Works
20th
&
State
Streets
Granite
City,
IL
62040
TEL:
(618)451-3013
FAX:
(618)451-4020
TEL:
618-344-1004
FAX:
618-344-1005
•,
ACCo
C.,
NELAP
Accredited
#100226
RE:
Steelmaking
Slag
C-Fines
Dear
Carl
Cannon:
OrderNo.
07010380
TEKLAB,
INC
received
I
sample
on
1/1212007
3:40:00
PM
for
the
analysis
presented
in
the
following
report.
A
list of
report
contents
can
be
found
on
the
following
page.
Samples
are
analyzed
on
an
as
received
basis
unless
otherwise
requested
and
documented.
The
sample
results
contained
in
this
report
relate
only to
the
requested
analytes
of
interest
as
directed
on
the
chain
of
custody.
IL
ELAP
and
NELAP
accredited
fields
of
testing
are
indicated
by
the
letters
NELAP
under
the
Certification
column.
All
quality
control
criteria
applicable
to
the
test
methods
employed
for
this
project
have
been
satisfactorily
met and
are
in
accordance
with
NELAP
except
where
noted.
The
following
report
shall
not
be
reproduced,
except
in
full,
without
the
written
approval
of
Tekiab,
Inc.
If
you
have
any
questions
regarding
these
tests
results,
please
feel
free to
call.
Sincerely,
,iuLki.-
A.
L&vv-
Heather
A.
Barnes
Project Manager
(618)344-1004
ex.20
IL
ELAP
and
NELAP
Accredited
-
Accredilallon
#100226
IDPH
RegIstry
#17584
Page
loff
5445
HORSESHOE
LAKE
ROAD
TEICI.JAB,
IN
C.
COLLINSVILLE,
ILLINOIS
62234
ENViRONMENTAL
TESTING
LABORATORY
TEL:
618-344-1004
-
-
FAX:
618-344-1005
Client:
U.S.
Steel-Granite.City
Works
REPORT
CONTENTS
Project:
Steelinaking
Slag
C-Fines
LabOrder:
07010380
Report
Date:
Januaiy
16,
2007
This
reporting
package
includes
the
following:
Analysis
Results
(
this
document)
4
pages
Chain
of
Custody
I
pages
Sample
Receipt
Checklist
I
pages
Associated
Information
NA
pages
Sample
Suminaiy
NA
pages
Dates
Report
NA
pages
,
QCReport
NA
pages
Sub
Contracted
Lab
Report
NA
pages
MDL
Report
NA
pages
IL
EL?
and
NEI.AP
Accredited
-
AccreditatIon
#100226
.
IDPH
Reglstiy
#17584
Page
2
of
4
5445
HORSESHOE
LAKE
ROAD
T
EKLAB,
INC.
COLLINSV1LLE,
ILLI
NOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
TEL:618-344-1004
-
-
FAX:
618-344-1005
Client:
U.S.
Steel-Granite
City
Works
CASE
NARRATIVE
Project:
Steelmaking
Slag
C-Fines
LabOrder:
07010380
Report
Date:
January
16,
2007
Cooler
Receipt
Temp
4.2
°C
Original
Chain
of
Custody
and
sample
receipt
checklist
are
on
file
at
Tekiab.
Qualifiers
DP
Dilution
Factor
B
-
Analyte
detected
in
the
associated
Method
Dianic
£
-Value
above
quantitation
range
Reporting
Limit
3
-
Analyte
detected
below
reporting
limits
H
-
Holding
time
exceeded
ND
-Not
Detected
at
the
Reporting
Umit
R
-
RPD
outside
accepted
recovety
limits
D
-
Diluted
out
of
sample
Surr
-
Surrogate
Standard
added
by
lab
S
-Spike
Recovery
outside
accepted
recovery
limits
MI
-
Matrix
interference
TNTC
-Toonumeroustocount
X
-Value
exceeds
Maximum
ContaminantLevel
DNJ
Did
Not
Ignite
IDI’H
fllinois
Department
of
Public
Health
NELAP
-
IL
ELAP
and
NELAP
Accredited
Field
of
Testing
IL
ELAP
and
NELAP
Accredited
-
Accreditation
#100226
IDPH
Registry
#17584
Page
3
rtf
4
5445
HORSESHOE
LAKE
ROAD
TEK.LAB,
INC.
COLLINSVILLE,
ILLINOIS
62234
ENVIRONMENTAL
TESTING
LABORATORY
TEL:
618-344-1004
FAX:
618-344-1005
Laboratory
Results’
CLIEN1’:
U.S.
Steel-Granite
City
Works
Client
Project:
Steelmaking
Slag
C-Fines
WorkOrder
07010380
Client
Sample
ID: Slag
C-Fines
Lab
ID:
07010380-001
CollectIon
Date:
1/12/2007
10:10:00
AM
Report
Date:
I 6-Jan-07
Matrix:
SOLID
Analyses
Certification
RL
Qua)
Result
Units
DF
Date
Analyzed
Analyst
SW-848
1312,
50O.
826gB,
VOLATILE
ORGANIC
COMPOUNDS
IN
SPLP
EXTRACT
BY
GCIMS
1,1,1-TrlcNoroethane
NELAP
0.006
ND
mg/I
1
111512007
7:20:00
PM
GEK
1,1-Dichioroethene
NELAP
0.005
ND
mg!L
1
111512007
7:20:00
PM
GEK
1,2-Dichioroethane
NELAP
0.005
ND
mg/I
I
115/2007
7:20:00
PM
GEK
1.2-Diddoropropane
NELAP
0.005
ND
mg/I
1
1/15/2007
7:20:00
PM
GEK
Benzene
NELAP
0.002
ND
mg/L
1
1/15/2007
7:20:00PM
GE)<
s..-’
Bromodichioromethane
NELAP
0.005
ND
mg/I
1
1/15/2007
7:20:00
PM
GEK
Bromoform
NELAP
0.005
ND
mg/L
1
1115120077:20:00PM
GEK
Carbontetrachlodde
NELAP
0.005
ND
mg/I
I
1/1512007720:00PM
GEK
Chlorobenzene
NELAP
0.005
ND
mg!L
1
111512007
7:20:00PM
GEK
Chloroform
NEIAP
0.005
ND
mg/I
1
1/1512007
7:20:00
PM
GEK
ds-1,2-Dichloroethene
NELAP
0.005
ND
mg/I
1
111512007
7:20:00PM
GEK
Dlbromochloromethane
NELAP
0.005
ND
mg/I
1
1/15/2007
7:20:00PM
GEK
Ethyfbenzene
NELAP
0.005
ND
mg/I
1
1/15120077:20:00
PM
GEK
m,p-Xytenes
NELAP
0.005
ND
mg/I
1
1/1512007720:OOPM
GEK
o.Xylene
NELAP
0.005
ND
mg/I
I
1/15120077:20:OOPM
GEK
Styrene
NELAP
0.005
ND
mg/I
I
1/1512007720:OOPM
GEK
Tetrachioroethene
NELAP
0.005
ND
mg/I
1
1115/2007
7:20:00
PM
GEK
Toluene
NELAP
0.005
ND
mg/I.
1
1/15/2007
7:20:00PM
GEI(
trans-I
.2-Dichioroethene
NELAP
0.005
ND
mg/I
1
1/15/2007
720:00
PM
GEK
--Trichioroethene
NELAP
0.005
ND
mg/I
1
111512007
7:20:00PM
GEK
Vinyl chloride
NELAP
0.002
ND
mg/I.
1
1/1512007
7:20:00PM
GEK
Sum
1,2-Dlctiloroethane-d4
73.9-129
106.9
%REC
1
1/15/2007
720:00
PM
GEK
Sum4-Bromofluorobenzene
63-113
103.3
%REC
1
1/15/20077:20:00PM
GEK
Sum
Dibroniofluoromethene
83.9-118
85.5
%REC
1
1/15/2007
720:00
PM
GEK
Surr:Toluene-d8
85.5-115
96.6
%REC
1
1/1512007720:00PM
GEK
Sample
Narrative
IL
ELAP and
NELAP
Accredited
- AccreditatIon
#100226
.
IDPH
Registry
#17584
Page
4
of
4
wecnnoiogici
Ul,RWr5I7
I’
MinoraJe
a
SaJCIiaJe
1iwrJng
Bufldirig
• 1
14QQTp$fid
Ddve.
HouVhton.
MQn
4W31.1236
Inabtute
of
Materiala
Procoaning
9OI4a7-26OO
Fax: 90W487-2g21
CLIENT:
Westwood
Lands
INC.
110 Airport
Drive
V
Negaunee,
Michigan
49866
DATE:
V
7, 2007
RE:
IRON
(LGI)
Chemical
Analysis
Perfonned
by
Zhiyong
Xu,
Ph.D.
Chemical
Wi %
Compos
Won
l’otallron
14A8
Metallic
Iron
2.27
Fe203
8.87
V
FeO
5.44
P205
0.30
CaO
43.23
S102
19.40
A1203
4.68
MgO
11.20
MnO
V
0.09
K20
0.03
Na20
0.02
Carbon
0.64
Sulfur
3.76
T102
0.12
V
Zn
<0.003
Not
Detected
1
Below
Detection
Limit
Cd, Ag,
Se
VM
Cr,
Hg,
Pb, Ba
Please
review
attached
page
for specific
analyte
detection
limit
METHODS
OF
ANALYSIS:
V
Samples
were
quantitatively
analyzed
using
an
Inductively
Coupled
Plasma
CP)
Spectrometer.
Specimens
were
dissolved
with
a
four acid
(perchloric.
nitric,
hydrochloric,
and
hydroflouric)
digestion.
VV
APPROVED
BY:
V
V
Ttann-Yang
(Jim)
Hwang
4
Ph.D.
Director,
Instiuzie
of
Materials
Proccsing
inTu,thn
U.,tyi
an
thicoq
kO*QCWIY
oye’.
Piid
n
.qcd
P
EXHIBIT
H