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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.11(84)
Key Words: EP Toxicity
Regulations:
Subject:
Addressee:
Originator:
Evaluation of EP Toxicity on the Basis of Total Chromium
Miton A. Cerny, Plant Engineer, Iowa Industries, Inc.,
P. 0. Box 768, Burlington, Iowa 52601
Barbara L. Bush, Environmental Protection Specialist, Waste
Identification Branch
Source Doc: #9443.11(84)
Date:
Summary:
12-03-84
EPA will continue to evaluate EP toxicity on the basis of total chromium,
rather than on the basis of hexavalent chromium only. The decision is based on
concerns raised over the potential for both trivalent and hexavalent chromium
to leach from landfilled wastes and subsequently contaminate drinking water
sources. A waste that fails the EP toxicity characteristic for total chromium
is considered hazardous.
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9443. 11 I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
-. "'
DcC03B84
SCLIO WASTE
RE: WIBBB0621
Mr. Miton A. Cemy
Plant Engineer
lova Industries, Inc.
P. 0. Box 768
Burlington, Iowa 52601
Dear Mr. Cemy:
This letter is to confirm our telephone conversation of
October 29, 1984, concerning the total chromium levels reported
in the exclusion petition submitted by Iowa Industries for
dewatered solids from electroplating and pickling operations,
presently listed as EPA Hazardous Waste Nos. F006 and K062.
The data presented in the petition demonstrates that your
waste typically and frequently exhibits the Extraction Procedure
(EP) toxicity characteristic for total chromium. In particular,
the data in your petition indicates that total chromium levels in
the EP extract from your sludge are variable, ranging from 1.0 to
65 mg/l.]_/ Since samples of Iowa Industries' waste fails the E?
toxicity characteristic for total chromium, the waste is considered
hazardous.
Until as recently as one month ago, it appeared likely that
the Agency would change the basis of the EP toxicity characteristic
from total chromium to hexavalent chromium.£/ However, recent
decisions at EPA indicate that the proposal will not be made
final; in fact, the Agency is making preparations to withdraw
this proposal entirely. This decision is based on concerns.
raised over the potential for both trivalent and hexavalent chromium
to leach from landfilled wastes and subsequently contaminate
drinking water sources. Therefore, EPA will continue to evaluate
EP toxicity on the basis of total chromium. Based on this decision,
Iowa Industries' petition requesting a delisting of their electroplating
and pickling waste would be denied.
]_/ Total chromium levels reported were 1.0, 18, 65, 3.7, 30,
and 50 mg/1.
2/ The original proposal was made October 30, 1980. (See 45 FR
72029.) ~~
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However, if Iowa Industries can modify its manufacturing
process or treat the waste to decrease the total chromium in
the EP extract, then the delisting petition can be reconsidered.
The Agency is now using a Vertical and Horizontal Spread (VHS)
model to predict worst case contamination levels in well water
500 feet from the "contamination source. The VHS model assumes
an in-line source-to-receptor dispersion and includes factors for the
concentration of the constituent in the EP extract and the total
amount of waste to be land disposed. According to the VHS model,
in order that the concentration of chromium at the receptor
well not exceed the National Interim Primary Drinking Water
Standard of 0.05 ppm, the concentration of chromium in the EP
extract cannot exceed 2.5 ppm, using the maximum volume of waste
generated annually at your facility. 3/ If Iowa Industries can .
modify its prodecures to obtain this level or lower of total chromium
in the EP extract, then the petition can be reconsidered.
Since you intend to attempt to lower the total chromium
levels in the EP extract, we will keep your file open until we
receive additional data from you. In the event that chromium
cannot be lowered to the specified levels, we will be forced to
deny your petition. However, before a denial notice is published
in the Federal Register, you will be given the option to withdraw
your petiton.
I hope thac this letter more fully explains the position
of Iowa Industries' delisting petition with regard to the total
:hromium issue. Please keep me informed of your treatment progess
and call me at (202) 382-4690 if you have any questions.
Sincerely,
Barbara L. Bush
Environmental Protection Specialist
Waste Identification Branch (WH-562)
3/ The Agency will be asking for public comment on the VHS model
when it is published in the Federal Register with the next package
of proposed exclusions sometime before January 1, 1985. Any
comments received may lead to procedural changes'within the
model, but are also not expected to result in significant
alterations.
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