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Industrial Services Testing Methods and Standards: In an effort to demonstrate to the Department of Toxic Substance Control("DTSC")that recycling ARMs (consisting of spent industrial materials such as Copper Slag, Garnet, Steel Shot, Aluminum Oxide,Ferric Iron Chloride, and Alumina Catalyst)meet the excluded recyclable requirements discussed above,KIS voluntarily submitted three(3)ARM samples and twelve(12) Portland cement samples to a State Certified laboratory for analysis by the California W.E.T. test. ARM samples: KIS three (3) ARM samples are from three (3) batches of material. Each batch is comprised of composite material collected from a number of generators. Each separate material collected from the generators was sampled and tested in accordance with 22 CCR §66260.200 and determined to be a non-RCRA, Excluded Recyclable Material (ERM) under California Health and Safety Code 25143.2(d)(5). Portland Cement Samples: KIS twelve (12) samples are in reality six (6) discrete samples. These six (6) samples were split into equal parts with two (2) splits of each of the six(6) samples. Twelve (12) samples total were submitted to the lab. Of the six (6) samples, three (3) contained no ARMs. The other three (3) Portland cement samples contained ARMs as an ingredient. Testing Results- STLC: The samples which did not contain ARMs are composites from product silos containing all non- ARM cement. In order to account for the variability, we used the following testing methodology: We took three (3) samples of non-ARM cement to determine the degree of variability that exists between non- ARM cements, and three (3) is the minimum statistical number needed. Three (3) samples of ARMs containing cement were collected from product silos where the entire silo contained cement manufactured with ARMs. Three (3) samples were collected to determine the variability between the different silos. Together,the six(6) samples comprise an adequate data set to indicate any differences observed in concentrations to be accurate. The data set is strengthened even more by the fact that each sample was run in duplicate. Testing each sample two times accounts for variability of error. This is important to KIS because a small error in testing could lead to KIS being out of compliance, due to the multiplication of the dilution factor (usage rate 5%, dilution factor of 20) to the W.E.T. test results. The summary below shows the mean (average) of the duplicate runs performed for each sample. Test data determined the specific metals exceeding W.E.T.(Waste Extraction Test) test limits are Cu (25.0 ppm),Pb (5.0 ppm),and Zn(250.0 ppm). ARM sample W.E.T. results are as follows (results are ppm); Element ERM 1 ERM 2 ERM 3 Mean Concentration: Cu 69.10 414.00 133.00 205.37 Pb 6.53 7.36 9.01 9.63 Zn 332.00 3,050.00 954.00 1,445.30 5 0 O a k C t . S u i t e 2 1 0 D a n v i l l e C A 9 4 5 2 6 P h o n e : 9 2 5 . 8 3 1 . 9 8 0 0 - F a x : 9 2 5 . 8 3 1 . 9 1 8 3 C:\KIS DOCS\Cement_Kilns\Demonstration_Testing_13'\NC140205-02_Demo_Test_for_Distribution.doc 3