COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

PA G E 3 (Portland cement) is intended for placement on the land,if the ARM were to exceed the STLC, CEMEX must demonstrate that the ARM is so physically bound up in or chemically reacted with the ultimate product that the constituents of the ARM will not leach out of the Portland cement product in concentrations that would exceed the STLC. It must be demonstrated that the hazardous constituents in the recyclable material are bound in the product so that they would not exceed the applicable STLC, even when eliminating the effect of dilution by other ingredients (22 66266.21(b)(5)). These special requirements for products placed on the land are consistent with the general waste determination requirements for all generators of potentially hazardous waste and do not require any special preapproval from either the California Department of Toxic Substances Control (DTSC) or the local Certified Unified Program Agency (CUPA). These general requirements allow a generator to make such determination at the point of generation by either: 1) testing the waste (22 CCR 66262.11 (c)(1)) or 2) applying knowledge of the hazardous characteristics of the waste in light of the materials or the processes used and the characteristics (22 CCR 66262.11.(c)(2)). In the highly unlikely event that the resulting product would fail the STLC, then this product may not be applied to the land. KIS would take responsibility for and commit to paying for the costs of managing and disposing of the Portland cement. As a result, in either event,there will be no threat to public health or the environment. In summary, under the HWCA regulatory requirements, any ARM sent to a cement kiln must undergo two tests: First,the ARM itself must satisfy the federal TCLP. If so, it may be used in the cement kiln (as ERM) without regulatory pre-approval even if it were to fail the STLC. Second, if the ultimate product, Portland cement passes the state STLC, it may be used in land-based applications (e.g., concrete). However, if such product does not pass the STLC, it cannot be used in a product that is applied to the land. In neither event would there be any threat posed to public health or the environment.