DSHW-2024-009283

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January 4,2007
Mr. William Beebe
Metal Management Arizona
3640 South 35th Avenue
Phoenix, Arizona 85009
SUBJECT: RESPONSE TO UDEQ LETTER DATED DECEMBER 1,2006
METAL MANAGEMENT WEST
SALT LAKE CITY, UTAH
Mr. Beebe:
Envirosure Solutions, LLC (Envirosure) has prepared this letter to respond to
comments 2 through 4 of the Request for lnformation letter prepared by the Utah
Department of Environmental Quality (UDEO) on December 1, 2006. The UDEQ
comment is stated below, followed by Envirosure's responses.
UDEQ Comment 2: Justification for sample temperatures submitted to analytical
laboratories. EPA requires submittal of all samples at or below 4 degrees
Celsius.
Envirosure Response: A number of sampling methods included in EPA's "SW-
846" guidance include a 4 degree Celsius sample preservation requirement.
However, Envirosure does not believe that sample refrigeration is required or
appropriate for the Shredder Waste field sampling activities it conducts due to the
unique nature of Shredder Waste and the intense processing and preparation
field samples must undergo to prepare a sample for analysis. However, after
field samples are submitted to the analytical laboratory, the sample refrigeration
procedures are adhered to during sample storage prior to processing and
analysis.
SW-846 is generally considered guidance, as EPA has acknowledged. Fact-
specific circumstances may justify appropriate deviations and modifications from
the prescribed methods. Shredder Waste, as EPA and several states have
acknowledged, is a very unique waste due to its heterogeneous nature, and the
relatively large volume of material that must be collected to generate a
p.o. box 27296, tempe, arizona 85285 ph: 480-784-4621 fax: [phone]
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representative sample and an adequate number of aliquots for analysis. lt is
readily apparent from these factors alone that typical sampling equipment and
methods are impractical, and appropriate for modification. For example, SW-846
calls for the use ol 125 ml wide mouth sample containers for sample collection
(see Section 4.1.2, Sample Handling and Preservation), which simply will not
work for the required 2000 gram sample of Shredder Waste, which typically
includes fist-size pieces of foam, rubber, plastic, etc.
Field samples of Shredder Waste also undergo an intense and unusual amount
of processing and preparation in order to develop an appropriate sample for
analysis. As detailed in the Arizona protocol, the Shredder Waste field sample
must be mixed, subdivided and composited, and cut or ground to fit through a 9.5
mm screen. It is very difficult to reduce Shredder Waste to the appropriate size
due to the heterogeneity and size of the Shredder Waste components e.g. fist-
size pieces of plastic, rubber, foam, etc., and this process can take several
hours. This laborious and detailed processing period entails thorough
manipulation and handling of the Shredder Waste, and therefore suggests limited
if any value in refrigerating the samples prior to being processed.
The specific sampling methods themselves also suggest that refrigeration of field
samples is not mandatory, but rather discretionary. Method 1311 Toxicity
Characteristic Leaching Procedure (TCLP) is one of the SW-846 methods that is
mandatory in order to evaluate waste against hazardous waste TC levels.
However, Envirosure understand the TCLP to suggest, but not to require,
refrigeration of field samples. Specifically, Section 6.4 of the TCLP instructs that
"samples may be refrigerated..." (emphasis added). Section 6.5 state "samples
should be collected in Teflon-lined septum capped vials and stored at 4 C.
Samples should be opened only immediately prior to extraction" (emphasis
added). These procedures are clearly suggestive, rather than mandatory, and
impractical for Shredder, as we are not aware of containers meeting these
specifications in the size required for Shredder Waste field samples.
Furthermore, Section 7.3.6, Procedure When Volatiles are Involved, states
"Wastes and appropriate reduction equipment should be refrigerated, if possible,
to 4 C prior to particle size reduction." Again, this instruction is consistent with a
non-mandatory refrigeration criteria.
Given these circumstances, Envirosure has concluded that refrigeration of field
samples is impractical and inappropriate.
ln summary, Envirosure used available guidelines, the Arizona Method for
sampling Shredder Waste, and the ensuing Utah Method to develop a unique
procedure to collect and handle this unique material. The field samples were
delivered to the laboratory under chain of custody where they were immediately
placed on ice. The laboratory processed the material to pass the 9.5mm screen
and then placed the samples back on ice unti! analyzed.
p.o. box 27296, tempe, arizona 85285 ph. 480-784-4621 fax: [phone]
www. e nvi ros u resol utio ns. com
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UDEQ Gomment 3: Justification for sample reporting levels for volatile organics
and semi-volatiles.
Envirosure Response: Envirosure confirmed with Mr. Ken Baker, Project
Manager, of Test America, that the applicable analytical methods are used to set
the reporting levels for each analyte (i.e., 8260b,8270c,8081, etc.)
UDEQ Comment 4: Justification for no TCLP analysis for volatiles and semi-
volatiles when detected above reporting levels.
Envirosure Response: According to section 1.2 of Method 1311 Toxicity
Characteristic Leaching Procedure, "lf a total analysis of the waste demonstrates
that individual analytes are not present in the waste, or that they are present but
at such low concentrations that the appropriate regulatory levels could not
possibly be exceeded, the TCLP need not be run." Based on the concentrations
of total volatiles and semi-volatiles and using the "Rule of Twenty", none of the
total concentrations exceeded the appropriate regulatory Ievels. The "Rule of
Twenty" is used in the industry to convert total concentrations to TCLP
concentrations. The TCLP value is calculated by dividing the total concentration
for the analyte (in milligrams per kilogram) by 20.
This "Rule of Twenty" is discussed in the Federal Register A/ol. 68, No.
117Wednesday, June 18,2003, page 36530: "For a waste that is a physical
solid, the maximum theoretical leachate concentration can be calculated by
dividing the total concentration of the constituents by twenty. This twenty-fold
dilution is part of the TCLP protocol and represents the liquid to solid ratio
employed in the test procedure." This is actually the most conservative TCLP
estimate as it assumes that 100 percent of the constituent leaches from the
waste.
PIease call me at 480-7844621 if you have questions or need additional
information.
Sincerely,w@
Todd Mehall
Envirosure Solutions, LLC
p.o. box 27296, tempe, arizona 85285 ph: 480-784-4621 fax: [phone]
www. e nvi ros u resol utions. com