DSHW-2024-005221

March 13, 2024
Christy Seiger Webster, Environmental Manager
McWane Ductile - Utah
2550 South Industrial Parkway
Provo, UT 84606
RE:Sampling & Analysis Plan for Legacy Coke FinesUTD988067351
Dear Ms. Seiger Webster:
In your August 1, 2023, email, you said“we will revise the SAP to include consideration of the metallurgical coke material analytical results.  I will send you an email update with a
better timeline for the SAP once we receive the laboratory results from the material testing or by September 1st.”
On November 29, 2023, McWane Ductile - Utah (MDU) submitted a summary report of analytical data for metallurgical coke to the Division of Waste Management and Radiation Control (Division)(DSHW-2023-212269).
According to the letter, MDU performed these analyses to assess the composition of metallurgical coke material in development of a sampling and analysis plan (SAP) for legacy of-specification
material and would like to discuss a reduced chemical analysis list and sampling matrix for the coke fines SAP.Complete analytical data packages were submitted to the Division on January
11, 2024.
While these analytical results confirm that the sampled coke fines are not hazardous waste, these results do not(cannot?)show that the Legacy Coke Fines are not hazardous and because
of the lack of homogeneity of the material, does not confirm that metallurgical coke is a non-hazardous material (as concluded in MDU’s letter).
Please submit a revised SAP that focuses on benzene.(They want to only sample for benzene, not the full suite of analytes that was suggested. I think we can draw the conclusion that
it is not necessary to run TCLP)
On March 6, 2024, you sent an email to Judy Moran asking if MDU is allowed to repair a ramp constructed of Legacy Coke Fines. MDU must submit an official request ….
Waste generated while repairing/replacing the ramp will need to be characterized and managed based on the resulting characterization.
If you have any questions, please call Judy Moran at [phone].
Sincerely,
Deborah Ng
Hazardous Waste Program Manager, Division of Waste Management and Radiation Control
DSN/JAM/jk
c:Eric Edwards, Health Officer, Utah County Health Department
Tyler Plewe, Deputy Director, Utah County Health Department
Jason Garrett, Environmental Health Director, Utah County Health Department
Annette Maxwell, U.S. EPA, Region VIII (ENF)
Christy Webster, Environmental Manager, McWane Ductile (Email and Hardcopy) [e-mail]
Paige Walton, Division of Waste Management and Radiation Control, UDEQ
Brian Speer, Division of Waste Management and Radiation Control, UDEQ
Dan Griffin, Division of Water Quality, UDEQ [e-mail]
Haley Sousa, Assistant Attorney General, Utah Attorney General’s Office [e-mail]