MAR 18, 1986
Mr. Ronald Shiver
Staff Engineer
K.W. Brown & Associates, Inc.
6A Graham Rd.
College Station, TX 77840
Dear Mr. Shiver:
I have reviewed the ground water monitoring data you submitted on behalf
of Falcon Steel, Kaufman, Texas. The
increase in conductivity is not, in itself, sufficient reason to deny
a delisting petition. Unfortunately, data for the
remainder of the EP toxic metals and nickel (in addition to lead and
chromium) were not included in the 1984 and 1985 monitoring reports; ground
water data for these constituents is also necessary to insure that no contamination
has occurred. As a result of the Hazardous and Solid Waste Amendments of
1984, we are required to consider all factors (including additional constituents)
when evaluating delisting petitions, if these factors may reasonably cause
the waste to be hazardous. (The EP toxic metals, nickel, and cyanide
are reasonably expected to be present in the waste as a result of the operations
performed at the facility, i.e., the tanks and steel involved).
I also, once again, reviewed the closure plan submitted in February,
1985. I want to clarify what will be required
in order to submit a complete delisting petition. The following
information will be needed:
1) all information under 40 CFR 260.22(b) and (i) (1-120);
2) a detailed list, description
and schematic of all
manufacturing
processes, including surface and
equipment preparation,
cleaning and/or degreasing,
coating or painting
processes, which may have contri-
buted waste,
wastewater, painting or rinse water to the
waste petitioned
for exclusion;
3) a complete list of all raw materials
used, including
chemical compositions,
and material safety data
sheets, if available,
identifying all solvents, acids,
cleaners, surface
preparation agents, paints, etc.,
used in the
manufacturing process which may have
entered the
waste petitioned for delisting;
4) an explicit statement verifying
that the number
of samples collected
and analyzed is representa-
tive of any
variation in constituent concentrations,
and the basis
for such a conclusion;
5) a detailed description of the
sampling methodology
and analysis
methods used on the representative
waste samples;
6) data indicating that representative
samples were test-
ed for the ignitable,
reactive, and corrosive charac-
teristics outlined
in Subpart C 261.21-13.
The following testing requirements must be performed on samples collected from each impoundment. The impoundments should be divided into quadrants; at least four core samples should be collected in each quadrant and composited (at least four composites are needed from each impoundment).
7) total constituent analyses of
the waste (complete acid
digestion) for
each of the EP toxic metals, and nickel
on a representative
number of samples (but not less
than four);
8) total analysis for cyanide on
a representative number
of samples (but
not less than four); if the cyanide
concentration
exceeds 1 ppm, then tests should be
run for free
cyanide on representative samples;
9) an EP leachate analysis */ of
the waste for each of the
EP toxic metals
nickel, and cyanide (using distilled
water for the
CN analyses ) on a representative number
of samples (but
not less than four);
10) a determination of the total oil
and grease content of
the waste be
testing a representative number of samples
(but not less
than four) using the enclosed method;
11) amount of waste present in each impoundment
after neutral-
ization;
12) describe quality assurance procedures
followed during
sampling and
analysis. For example, results from the
method of standard
additions for the EP toxicity tests
should be included.
*/ If the oil and grease level of the waste exceeds one percent,
the EP for oily waste metholology should be followed during
analysis.
If after reviewing the data specified above, the Agency finds that organic toxic constituents or other toxic metals are used in the facilities manufacturing processes, you may be required to submit representative test data quantifying these constituents in the waste.
If you have any questions about these information requests, please call me at (202) 382-4519. In addition, the final guidance manual is available through NTIS if you have not already acquired it.
Sincerely,
Ann Burke Sarno
Environmental Protection Specialist
Waste Identification Branch (WH-562B)