COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

Mr. Jay M. Grady November 17, 1995 Page 2 blasting grit used to manufacture the cement and of the cement product using the copper slag as an ingredient. Analyses of the cement product made with the spent grit indicated the concentrations of copper, lead, and chromium, which exceeded the STLCs in the spent grit, were below the STLCs in the cement product using the spent grit , after accounting for the effect of dilution in mixing the grit with other ingredients and after subtracting background concentrations of the same metals found in non-grit ingredients. In addition, zinc, which staff in our Region 4 office had reported to exceed the STLC in the spent grit slag, also fell below the STLC in the cement product, even after adjusting analytical results for dilution and non-spent grit ingredient background levels. The Management Memo also requires that a product made from recyclable materials, that may be placed on the land, exhibit no characteristics of a hazardous waste, other than those present in a comparable commercial product. CPC's and DTSC's testing indicated that the only constituents in the copper slag blasting grit to exceed regulatory thresholds are lead, copper, chromium and zinc. Testing of the product showed concentrations of these ' ketals to be well below the STLCs, as well as the applicable Total Threshold Limit Concentrations (TTLC)I. Finally, the Management Memo requires that the recyclable material, must be used beneficially. Specifically, the material itself and the product must meet an industry standard for the intended use of the material/product, and there shall be no indications of sham recycling. CPC has argued, and our research has confirmed, that there are no specific standards for materials being used in the manufacture of Portland cement; rather there are standards or specifications for the Portland cement product, that a cement manufacturer must meet by „juggling" the ingredients that go into the product. Consequently, CPC has stated they will provide certification that the Portland cement made with spent blasting grit meets the ASTM C--150 standard. Such certification will satisfy thls� Baal %;rzt-eria. Based on the information provided by CPC, including the characterization of the spent blasting grit and the assurance that they can acquire a certification that their product made with spent grit meets an appropriate ASTM specification, the DTSC concurs with CPC's determination that use of the spent slag grit in the manufacture of cement at CPC's Colton plant is not subject to the use constituting disposal 2 ibid.