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-

     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

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.


Ann Burke Sarno
Environmental Protection Specialist
Waste Identification Branch (WH-562B)