[Federal Register Volume 59, Number 43 (Friday, March 4, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-4990]
[[Page Unknown]]
[Federal Register: March 4, 1994]
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 261
[SW-FRL-4844-5]
Hazardous Waste Management System; Identification and Listing of
Hazardous Waste; Proposed Exclusion
AGENCY: Environmental Protection Agency.
ACTION: Proposed rule and request for comment.
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SUMMARY: The Environmental Protection Agency (EPA or Agency) is
proposing to grant a petition submitted by Bethlehem Steel Corporation
(BSC), Sparrows Point, Maryland, to exclude certain solid wastes
generated at its facility from the lists of hazardous wastes contained
in Sec. 261.31 and Sec. 261.32. This action responds to a delisting
petition submitted under Sec. 260.20, which allows any person to
petition the Administrator to modify or revoke any provision of Parts
260 through 265 and 268 of Title 40 of the Code of Federal Regulations,
and under Sec. 260.22, which specifically provides generators the
opportunity to petition the Administrator to exclude a waste on a
``generator-specific'' basis from the hazardous waste lists. The
proposed decision is based on an evaluation of waste-specific
information provided by the petitioner. If this proposed decision is
finalized, the petitioned waste will be conditionally excluded from
regulation as a hazardous waste under the Resource Conservation and
Recovery Act (RCRA).
The Agency is also proposing the use of a fate and transport model
to evaluate the potential impact of the petitioned waste on human
health and the environment, based on the waste-specific information
provided by the petitioner. This model has been used in evaluating the
petition to predict the concentration of hazardous constituents that
may be released from the petitioned waste, once it is disposed of.
DATES: EPA is requesting public comments on today's proposed decision
and on the applicability of the fate and transport model used to
evaluate the petition. Comments will be accepted until April 18, 1994.
Comments postmarked after the close of the comment period will be
stamped ``late''.
Any person may request a hearing on this proposed decision by
filing a request with the Director, Characterization and Assessment
Division, Office of Solid Waste, whose address appears below, by March
21, 1994. The request must contain the information prescribed in
Sec. 260.20(d).
ADDRESSES: Send three copies of your comments to EPA. Two copies should
be sent to the Docket Clerk, Office of Solid Waste (5305), U.S.
Environmental Protection Agency, 401 M Street, SW., Washington, DC
20460. A third copy should be sent to Jim Kent, Delisting Section,
Waste Identification Branch, CAD/OSW (5304), U.S. Environmental
Protection Agency, 401 M Street, SW., Washington, DC 20460. Identify
your comments at the top with this regulatory docket number: ``F-94-
B8EP-FFFFF''.
Requests for a hearing should be addressed to the Director,
Characterization and Assessment Division, Office of Solid Waste (5304),
U.S. Environmental Protection Agency, 401 M Street, SW., Washington,
DC. 20460.
The RCRA regulatory docket for this proposed rule is located at the
U.S. Environmental Protection Agency, 401 M Street, SW., Washington, DC
20460, and is available for viewing (Room M2616) from 9 a.m. to 4 p.m.,
Monday through Friday, excluding Federal holidays. Call (202) 260-9327
for appointments. The public may copy material from any regulatory
docket at no cost for the first 100 pages, and at $0.15 per page for
additional copies.
FOR FURTHER INFORMATION, CONTACT: For general information, contact the
RCRA Hotline, toll free at (800) 424-9346, or at (703) 412-9810. For
technical information concerning this notice, contact Shen-yi Yang,
Office of Solid Waste (5304), U.S. Environmental Protection Agency, 401
M Street, SW., Washington, DC 20460, (202) 260-1436.
SUPPLEMENTARY INFORMATION:
I. Background
A. Authority
On January 16, 1981, as part of its final and interim final
regulations implementing section 3001 of RCRA, EPA published an amended
list of hazardous wastes from non-specific and specific sources. This
list has been amended several times, and is published in Sec. 261.31
and Sec. 261.32. These wastes are listed as hazardous because they
typically and frequently exhibit one or more of the characteristics of
hazardous wastes identified in Subpart C of part 261 (i.e.,
ignitability, corrosivity, reactivity, and toxicity) or meet the
criteria for listing contained in Secs. 261.11(a)(2) or (a)(3).
Individual waste streams may vary, however, depending on raw
materials, industrial processes, and other factors. Thus, while a waste
that is described in these regulations generally is hazardous, a
specific waste from an individual facility meeting the listing
description may not be. For this reason, Sec. 260.20 and Sec. 260.22
provide an exclusion procedure, allowing persons to demonstrate that a
specific waste from a particular generating facility should not be
regulated as a hazardous waste.
To have their wastes excluded, petitioners must show that wastes
generated at their facilities do not meet any of the criteria for which
the wastes were listed. See Sec. 260.22(a) and the background documents
for the listed wastes. In addition, the Hazardous and Solid Waste
Amendments (HSWA) of 1984 require the Agency to consider any factors
(including additional constituents) other than those for which the
waste was listed, if there is a reasonable basis to believe that such
additional factors could cause the waste to be hazardous. Accordingly,
a petitioner also must demonstrate that the waste does not exhibit any
of the hazardous waste characteristics (i.e., ignitability, reactivity,
corrosivity, and toxicity), and must present sufficient information for
the Agency to determine whether the waste contains any other toxicants
at hazardous levels. See Sec. 260.22(a), 42 U.S.C. 6921(f), and the
background documents for the listed wastes. Although wastes which are
``delisted'' (i.e., excluded) have been evaluated to determine whether
or not they exhibit any of the characteristics of hazardous waste,
generators remain obligated under RCRA to determine whether or not
their waste remains non-hazardous based on the hazardous waste
characteristics.
In addition, residues from the treatment, storage, or disposal of
listed hazardous wastes and mixtures containing listed hazardous wastes
are also considered hazardous wastes. See Secs. 261.3 (a)(2)(iv) and
(c)(2)(i), referred to as the ``mixture'' and ``derived-from'' rules,
respectively. Such wastes are also eligible for exclusion and remain
hazardous wastes until excluded. On December 6, 1991, the U.S. Court of
Appeals for the District of Columbia vacated the ``mixture/derived
from'' rules and remanded them to the Agency on procedural grounds
(Shell Oil Co. v. EPA, 950 F.2d 741 (D.C. Cir. 1991)). On March 3,
1992, EPA reinstated the mixture and derived-from rules, and solicited
comments on other ways to regulate waste mixtures and residues (57 FR
7628). The Agency plans to address issues related to waste mixtures and
residues in a future rulemaking.
B. Approach Used To Evaluate This Petition
This petition requests a delisting for a listed hazardous waste. In
making the initial delisting determination, the Agency evaluated the
petitioned waste against the listing criteria and factors cited in
Secs. 261.11(a)(2) and (a)(3). Based on this review, the Agency agreed
with the petitioner that the waste is non-hazardous with respect to the
original listing criteria. (If the Agency had found, based on this
review, that the waste remained hazardous based on the factors for
which the waste was originally listed, EPA would have proposed to deny
the petition.) EPA then evaluated the waste with respect to other
factors or criteria to assess whether there is a reasonable basis to
believe that such additional factors could cause the waste to be
hazardous. The Agency considered whether the waste is acutely toxic,
and considered the toxicity of the constituents, the concentration of
the constituents in the waste, their tendency to migrate and to
bioaccumulate, their persistence in the environment once released from
the waste, plausible and specific types of management of the petitioned
waste, the quantities of waste generated, and waste variability.
For this delisting determination, the Agency used such information
to identify plausible exposure routes (i.e., ground water, surface
water, air) for hazardous constituents present in the petitioned waste.
The Agency determined that disposal in a landfill is the most
reasonable, worst-case disposal scenario for BSC's petitioned waste,
and that the major exposure route of concern would be ingestion of
contaminated ground water. Therefore, the Agency is proposing to use a
particular fate and transport model to predict the maximum allowable
concentrations of hazardous constituents that may be released from the
petitioned waste after disposal in a regulated municipal solid waste
landfill and to determine the potential impact of disposal of BSC's
waste on human health and the environment. Specifically, the Agency
used the maximum estimated waste volume and the maximum reported
leachate concentrations as inputs to estimate the constituent
concentrations in the ground water at a hypothetical receptor well
downgradient from the disposal site. The calculated receptor well
concentrations (referred to as compliance-point concentrations) were
then compared directly to the health-based levels used in delisting
decision-making for the hazardous constituents of concern.
EPA believes that this fate and transport model represents a
reasonable worst-case scenario for disposal of the petitioned waste in
a landfill, and that a reasonable worst-case scenario is appropriate
when evaluating whether a waste should be relieved of the protective
management constraints of RCRA Subtitle C. The use of a reasonable
worst-case scenario results in conservative values for the compliance-
point concentrations and ensures that the waste, once removed from
hazardous waste regulation, will not pose a threat to human health or
the environment. Because a delisted waste is no longer subject to
hazardous waste control, the Agency is generally unable to predict and
does not control how a waste will be managed after delisting.
Therefore, EPA currently believes that it is inappropriate to consider
extensive site-specific factors when applying the fate and transport
model. For example, a generator may petition the Agency for delisting
of a metal hydroxide sludge which is currently being managed in an on-
site landfill and provide data on the nearest drinking water well,
permeability of the aquifer, dispersivities, etc. If the Agency were to
base its evaluation solely on these site-specific factors, the Agency
might conclude that the waste, at that specific location, cannot affect
the closest well, and the Agency might grant the petition. Upon
promulgation of the exclusion, however, the generator is under no
obligation to continue to manage the waste at the on-site landfill. In
fact, it is likely that the generator will either choose to send the
delisted waste off-site immediately, or will eventually reach the
capacity of the on-site facility and subsequently send the waste off
site to a facility which may have very different hydrogeological and
exposure conditions.
The Agency also considers the applicability of ground-water
monitoring data during the evaluation of delisting petitions. In this
case, the Agency determined that, because BSC is seeking an upfront
delisting (i.e., an exclusion based on data from waste generated from a
bench-scale treatment process), ground-water monitoring data collected
from the areas where the petitioner plans to dispose of the waste in
the future are not necessary. Because the petitioned waste is not
currently generated or disposed of, ground-water monitoring data would
not characterize the effects of the petitioned waste on the underlying
aquifer at the disposal sites and, thus, would serve no purpose.
Therefore, the Agency did not request ground-water monitoring data.
BSC petitioned the Agency for an upfront exclusion (for waste that
has not yet been generated) based on descriptions of the proposed
stabilization process that will be used to treat BSC's dewatered filter
cake, characterization of dewatered (unstabilized) filter cake, and
results from the analysis of waste subjected to BSC's proposed
stabilization process.
Similar to other facilities seeking upfront exclusions, this
upfront exclusion (i.e., an exclusion based on information
characterizing the process and waste) would be contingent upon the
analytical testing of the petitioned waste once stabilization is
initiated at BSC's Sparrows Point facility. Specifically, BSC will be
required to collect representative samples of stabilized filter cake to
verify that the stabilization process is on-line and operating as
described in the petition. The verification testing requires BSC to
demonstrate that the proposed stabilization process, once on-line, will
generate a non-hazardous waste (i.e., a waste that meets the Agency's
verification testing conditions).
From the evaluation of BSC's delisting petition, a list of
constituents was developed for the verification testing conditions.
Tentative maximum allowable leachable concentrations for these
constituents were derived by back calculating from the delisting
health-based levels through the proposed fate and transport model for a
landfill management scenario. These concentrations (i.e., ``delisting
levels'') are the proposed verification testing conditions of the
exclusion.
The Agency encourages the use of upfront delisting petitions
because they have the advantage of allowing the applicant to know what
treatment levels for constituents will be sufficient to render specific
wastes non-hazardous, before investing in new or modified waste
treatment systems. Therefore, upfront delistings will allow new
facilities to receive exclusions prior to generating wastes, which,
without upfront exclusions, would unnecessarily have been considered
hazardous. Upfront delistings for existing facilities can be processed
concurrently during construction or permitting activities; therefore,
new or modified treatment systems should be capable of producing wastes
that are considered non-hazardous, and managed as such sooner than
otherwise would be possible. At the same time, conditional testing
requirements to verify that the delisting levels are achieved by the
fully operational treatment systems will maintain the integrity of the
delisting program and will ensure that only non-hazardous wastes are
removed from Subtitle C control.
Finally, the Hazardous and Solid Waste Amendments of 1984
specifically require the Agency to provide notice and an opportunity
for comment before granting or denying a final exclusion. Thus, a final
decision will not be made until all public comments (including those at
public hearings, if any) on today's proposal are addressed.
II. Disposition of Delisting Petition
Bethlehem Steel Corporation, Sparrows Point, Maryland.
A. Petition for Exclusion
Bethlehem Steel Corporation (BSC), located in Sparrows Point,
Maryland, is involved in the production of tin and chromium plated
parts and steel strip. BSC petitioned the Agency to exclude its
chemically stabilized wastewater treatment filter cake presently listed
as EPA Hazardous Waste No. F006--``Wastewater treatment sludges from
electroplating operations except from the following processes: (1)
Sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel;
(3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5) cleaning/stripping
associated with tin, zinc and aluminum plating on carbon steel; and (6)
chemical etching and milling of aluminum''. The listed constituents of
concern for EPA Hazardous Waste No. F006 waste are cadmium, hexavalent
chromium, nickel, and cyanide (complexed) (see part 261, appendix VII).
BSC petitioned the Agency to exclude its stabilized filter cake
because it does not believe that the waste, once generated, will meet
the criteria of the listing. BSC claims that its treatment process will
generate a non-hazardous waste because the constituents of concern in
the waste are either not present or are in an essentially immobile
form. BSC also believes that the waste will not contain any other
constituents that would render the waste hazardous. Review of this
petition included consideration of the original listing criteria, as
well as the additional factors required by the Hazardous and Solid
Waste Amendments (HSWA) of 1984. See section 222 of HSWA, 42 U.S.C.
6921(f), and 40 CFR 260.22(d)(2)-(4). Today's proposal to grant this
petition for delisting is the result of the Agency's evaluation of
BSC's petition.
B. Background
On January 2, 1991, BSC petitioned the Agency to exclude its
stabilized filter cake from the lists of hazardous wastes contained in
Sec. 261.31 and Sec. 261.32, and subsequently provided additional
information to complete its petition. Specifically, BSC requested that
the Agency grant an upfront exclusion (i.e., an exclusion that applies
to waste not presently generated) for dewatered filter cake that will
be stabilized using lime kiln dust and powerplant fly ash at its
Sparrows Point facility.
In support of its petition, BSC submitted: (1) Detailed
descriptions of its manufacturing, waste treatment, and stabilization
processes, including schematic diagrams; (2) Material Safety Data
Sheets (MSDSs) for all trade name products used in the manufacturing
and waste treatment processes; (3) results from total constituent
analyses for the eight Toxicity Characteristic (TC) metals listed in
Sec. 261.24, nickel, cyanide, zinc, and sulfide from representative
samples of the dewatered (unstabilized) filter cake and the stabilized
filter cake; (4) results from the EP Toxicity Test and the Toxicity
Characteristic Leaching Procedure (TCLP, SW-846 Method 1311) for the
eight TC metals (except for barium and selenium) and nickel from
representative samples of the dewatered (unstabilized) filter cake,
uncured stabilized filter cake, and the cured stabilized filter cake;
(5) results from total oil and grease analyses from representative
samples of the dewatered (unstabilized) filter cake and stabilized
filter cake; (6) results from the Multiple Extraction Procedure (MEP,
SW-846 Method 1320) for the eight TC metals (except for barium and
selenium) and nickel from representative samples of the stabilized
filter cake; (7) test results and information regarding the hazardous
characteristics of ignitability, corrosivity, and reactivity; (8)
results from the TCLP analyses for the TC volatile and semivolatile
organic compounds from representative samples of the dewatered
(unstabilized) filter cake; and (9) results from total constituent
analyses for hexavalent chromium from representative samples of
dewatered (unstabilized) filter cake.
Similar to other facilities seeking upfront exclusions, once BSC's
proposed stabilization system is on-line at its Sparrows Point,
Maryland facility, BSC would be required to submit additional
analytical data for the petitioned waste to verify that the on-line
stabilization system meets the treatment capability of the
stabilization process as described in the petition and the verification
testing conditions specified in the exclusion (see Section F--
Verification Testing Conditions).
BSC's Sparrows Point, Maryland facility is involved in
electroplating operations producing tin and chromium plated parts and
steel strip. Three plating lines contribute wastes to the wastewater
treatment plant generating BSC's chromium high density filter cake,
namely, a tin free steel-chromium type (TFSCT) plating line and two
halogen tinning lines.
The TFSCT plating line is designed to deposit a layer of chromium
on the steel strip with an additional outer protective covering of
chromium oxides. The TFSCT plating line consists of five major
sections: The Entry Section, the Pre-Treatment Section, the Plating
Section, the Post-Treatment Section, and the Delivery Section. The
purpose of the entry section is to join the ends of the steel coils in
preparation for subsequent continuous processing in the following
sections. The pre-treatment section cleans and prepares the steel to be
plated. The strip passes through an electrolytic cleaning system, brush
scrubber, and pickle and pickle rinse cells to remove oil, dirt, rust,
and other foreign substances. In the plating section, the steel strip
passes through the plater conditioner cell prior to entering the
plating cell. The chromium and chromium oxide layers are
electrolytically plated onto the steel strip. The steel strip is
rinsed, after it leaves the plater, in the dragout and rinse cells. In
the post-treatment section, the coated steel strip is washed, dried,
and oiled prior to being coiled for shipping or storage. The oil film
helps to prevent scratching of the coated strip during handling, serves
as a lubricant for punching and forming operations, and retards
oxidation and corrosion. The delivery section consists of the equipment
required for strip tension control, storage, measurement and
inspection, and shearing and winding into coils.
During the TFSCT plating process overflow chromic acid solution
from the plater conditioner, overflow rinse waters from the dragout and
rinse cells of the plater section, and overflow rinse waters from the
final washer cell are sent to a sump (the chromium sump) which collects
only chromium-bearing wastewaters. The collected wastewater is then
pumped from the chromium sump to the chromium High Density Sludge (HDS)
Wastewater Treatment Plant. In addition, if it is necessary to shut
down the TFSCT plating line for repairs or in the event of a strip
break, chromium-bearing wastewaters from the plater conditioner and
plater section are sent to a storage tank for subsequent treatment via
the chromium HDS wastewater treatment plant.
The two halogen tinning lines are designed to deposit a thin layer
of tin on metal strip with an outer protective covering of a very thin
film of chromium and chromium oxides. The two halogen lines also
consist of five major sections: the Entry Section, the Pre-treatment
Section, the Tin Plating Section, the Post-Treatment Section, and the
Delivery Section. The purpose of the entry section is to join the ends
of the coils in preparation for subsequent continuous processing in the
following sections. The pre-treatment section cleans and prepares the
metal strip to be plated. The metal strip is cleaned in a hot, alkaline
solution. A brush scrubber removes loosened dirt and any remaining
caustic film, then a sulfuric acid solution is used to remove metal
oxides. A second brush scrubber removes the remaining acid film. In the
plating section, the cleaned, prepared metal strip is electroplated
with tin. In the tin plating unit, the strip rides on top of the
halogen plating solution, while a series of soluble anodes below the
surface provide the tin for plating. The metal strip is sprayed and
rinsed, after it leaves the plater, to remove any residual plating
solution. After being dried, the metal strip passes through the
electrical induction reflow (melting) process where the plated tin is
converted from a matte (as plated) finish to a bright finish. The post-
treatment section consists of a chemical treatment tank and a washer.
In the chemical treatment tanks sodium dichromate is used to produce a
thin uniform chromium and chromium oxide layer on the tinned surface
via cathodic electrolysis. The film serves to stabilize or
``passivate'' the tinned surface preventing the undesirable tin oxides
from forming. This section is completed with a dryer, Trion oiler, and
a bridle roll. The delivery section consists of the delivery looping
tower, a bridle roll, inspection and a recoil area where the metal
strip is cut and transferred to empty reels.
During the halogen tinning process, rinse waters from the chemical
treatment washer are sent to the chemical treat sump and further pumped
to the chromium HDS treatment system. This is the only wastewater
entering the chromium HDS wastewater treatment system from the Halogen
Tinning Lines.
The waste streams from the TFSCT plating (chromium sump) and
Halogen Tinning (chemical treat sump) lines are combined in a 50,000-
gallon storage tank. From the storage tank the wastewater is pumped to
a 10,000-gallon reduction reactor where the pH of the wastewater is
adjusted by the addition of sulfuric acid. In addition, liquid sulfur
dioxide (SO2) is added to reduce hexavalent chromium to trivalent
chromium. The reduced chromium wastewater is next transferred to a
7,000-gallon neutralization tank and mixed with lime and previously-
precipitated solids. The wastewater then flows by gravity to a 1,200-
gallon flocculator tank where a polymer is added to promote
flocculation of the metal hydroxides. The neutralized wastewater,
containing approximately 2-5 percent solids, is then sent through a 50-
foot diameter gravity thickener, where thickened sludge is removed and
subsequently dewatered by a rotary drum vacuum filter to 35-55 percent
solids. The thickener effluent is filtered and the filtrate is
discharged to the Tin Mill Canal for further wastewater treatment prior
to discharge to a receiving surface water body. The filtrate from the
vacuum filter and the filter backwash are returned to the flocculator
tank. The dewatered filter cake is discharged to a collection hopper
and currently shipped to/treated at a permitted hazardous waste
treatment facility (Envirite Corporation, York, Pennsylvania) before
disposal.
In its petition, BSC proposed to stabilize the dewatered filter
cake using lime kiln dust and powerplant fly ash. This process is based
on the pozzolanic reaction that adsorbs and/or encapsulates the heavy
metals present in the chromium filter cake into a calcium-alumino-
silicate matrix. Based on bench-scale studies of its proposed
stabilization process, BSC proposed using 3 parts lime kiln dust, 2
parts powerplant fly ash to 5 parts dewatered filter cake (by weight)
and 2 parts water to form the stabilized filter cake. Once delisted,
BSC plans to dispose of the stabilized filter cake at an on-site to-be-
constructed Subtitle D landfill.
BSC initially collected a total of four composite samples of its
dewatered filter cake during a four-week period between April 1, 1988
and April 28, 1988. The samples were collected using a scoop as sludge
was discharged from the end of the vacuum filter press. Each composite
sample was comprised of grab samples collected over a period of
approximately five days. Portions of the composite samples were then
stabilized using lime kiln dust and powerplant fly ash in a bench-scale
process. Specifically, 1,000 grams of dewatered filter cake were mixed
with 600 grams of lime kiln dust, 400 grams of powerplant fly ash, and
water and allowed to cure until air-dried.
BSC provided analysis results for samples of dewatered
(unstabilized) filter cake, filter cake samples that had just been
stabilized, and filter cake samples that were allowed to cure for 15
days. Four composite samples of dewatered (unstabilized) filter cake
and four composite samples of stabilized filter cake samples were
analyzed for the total concentrations (i.e., mass of a particular
constituent per mass of waste) of the eight TC metals, nickel, cyanide,
zinc, sulfide, and total oil and grease content. Composite samples of
dewatered (unstabilized) filter cake, uncured stabilized filter cake,
and cured stabilized filter cake were also analyzed for EP Toxicity and
TCLP leachate concentrations (i.e., mass of a particular constituent
per unit volume of extract) of the eight TC metals (except for barium
and selenium) and nickel.
On March 18, 1992, BSC submitted additional information which
included results from the analysis of four composite samples of
dewatered (unstabilized) filter cake. These samples were collected over
a period of four weeks from January 15, 1992 to February 10, 1992.
Using a stainless steel scoop, BSC collected grab samples from the
middle and both ends of the filter drum to ensure a representative
sample. Each daily composite sample was comprised of 5 grab samples.
After the last grab sample was taken each day, the samples of filter
cake were thoroughly mixed to form the daily composite. All four
dewatered (unstabilized) filter cake composite samples were analyzed
for total chromium, hexavalent chromium, and TCLP leachate
concentrations of the TC volatile and semivolatile organic compounds.
BSC claims that due to consistent manufacturing and waste treatment
processes, the analytical data obtained from the two sampling events
are representative of any variation in the chemically stabilized
wastewater treatment filter cake constituent concentrations. BSC
further explained in its petition that the samples collected in January
and February 1992 represent filter cake generated specifically when
different combinations of the three plating lines were operating.
C. Agency Analysis
BSC used SW-846 Method 7000 to quantify the total constituent
concentrations of arsenic, barium, cadmium, lead, nickel, selenium,
silver, and zinc in the filter cake samples. BSC used an Agency
approved Bethlehem Steel Standard Method\1\ to quantify the total
constituent concentration of chromium in the filter cake samples. BSC
used SW-846 Method 3060 to digest the samples, and then followed Method
7195 to analyze/quantify hexavalent chromium concentrations in the
dewatered (unstabilized) filter cake samples. BSC used ``Determination
of Mercury in Water By Gold-Film Analyzer'', to quantify the total
constituent concentration of mercury in the filter cake samples. BSC
used SW-846 Method 9010 to quantify the total constituent concentration
of cyanide in the filter cake samples. BSC used ``Methods for Chemical
Analysis of Water and Wastes'' Method 376.1 to quantify the total
constituent concentration of sulfide in the filter cake samples.
---------------------------------------------------------------------------
\1\Bethlehem Steel Standard Method. ``Methods of Sampling and
Analysis Vol. I Iron and Steel'' - Chromium by the Persulfate
Oxidation Method. Additional descriptive information about this
method is included in the RCRA public docket for today's notice.
---------------------------------------------------------------------------
Using SW-846 Method 9071, BSC determined that its stabilized filter
cake had a maximum oil and grease content of 0.099 percent; therefore,
the leachate analyses did not have to be modified in accordance with
the Oily Waste EP methodology (i.e., wastes having more than one
percent total oil and grease may either have significant concentrations
of constituents of concern in the oil phase, which may not be assessed
using the standard leachate procedures, or the concentration of oil and
grease may be sufficient to coat the solid phase of the sample and
interfere with the leaching of metals from the sample).
BSC used SW-846 Method 1310 (EP)/Method 7000 to quantify the EP
leachable concentrations of arsenic, cadmium, chromium, lead, mercury,
nickel, and silver in the filter cake samples, and used modified SW-846
Method 1310 (using distilled waster, instead of acetate buffer, in the
extraction) and Method 9010 to quantify the EP leachable concentration
of cyanide in cured stabilized samples. BSC used SW-846 Method 1311
(TCLP)/Method 7000 to quantify the TCLP leachable concentrations of
arsenic, cadmium, chromium, lead, mercury, nickel, and silver in the
filter cake samples. BSC used SW-846 Method 1320 (MEP)/Method 7000 to
quantify the MEP leachable concentrations of the TC metals (except for
barium and selenium) and nickel in the cured stabilized filter cake.
Table 1 presents the maximum total constituent concentrations of
the eight TC metals, nickel, cyanide, zinc, and sulfide for the
dewatered (unstabilized) filter cake and stabilized filter cake.
Table 1.--Maximum Total Constituent Concentrations (ppm)\1\ Filter Cake
------------------------------------------------------------------------
Dewatered Stabilized
Constituents (unstabilized) filter cake
filter cake
------------------------------------------------------------------------
Arsenic.................................... <2.0 52
Barium..................................... <100 <100
Cadmium.................................... 0.55 0.50
Chromium (total)........................... 240,000 55,000
Chromium (hexavalent)...................... 45 ...........
Lead....................................... 140 350
Mercury.................................... 0.087 0.091
Nickel..................................... 96 85
Selenium................................... <1.0 <1.0
Silver..................................... <6.0 <6.0
Cyanide (total)............................ 342 52
Zinc....................................... 120 90
Sulfide.................................... 220 160
------------------------------------------------------------------------