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mer-ser-177 1041r rMUM TO 87792939712099484910 P.03 <br /> 0 0 Fin <br /> Mr. Brian Piper <br /> Shields National incorporated <br /> September 30, 1992 <br /> Page 3 <br /> The fish bioassay demonstrate that the 96-hour 0 exceeded 750 /L which <br /> was greater than the regulatory mInimum requirement of 500 mg/L„ <br /> DISCrUSSION <br /> The pH testing performed indicates that the ash sample did not meet the criteria <br /> for corrosivity described in 22 CC1t4 Section 66261.22, lbe criteria for a <br /> hazardous waste require that a material have a p "...less than or equal to 2 or <br /> greater than or equal to 12S..."; the pH of the ash sample was 10.3. <br /> The metals and bioassay testing performed indicates that the ash sample did not <br /> meet the criteria for toxicity descn'bed in 22 CCP, Section 6621.24. The Total <br /> Threshold Limit Concentration C) regulatory levels were not exceeded by . <br /> any metal detected in the ash sample. No analyses were performed to determine <br /> the Soluble Threshold Limit Concentration (S'TLC) levels; however, potential <br /> soluble metal concentrations were extrapolated from total metals concentrations. <br /> A11 metals detected are well below STLC levels. The concentration of arsenic, <br /> at 0.80 was below the T= and STLC levels of 500 m 5.0 <br /> milligrams per Hter ( / ), respectively; barium, at 13 mg/]Kg, was below the <br /> TMC and SILC levels f 10t000 mg/Kg and 100 nVA, respectively; ' c, at 3 <br /> mg/K& was belowe TrW and S1= levels of 5, mg/Kg and 250 <br /> respectively. <br /> The 96-hour LC50 results for fathead tainnows were reported as greater than 750 <br /> /L. Wherefore, the waste does not meet the toxicity criteria described in 22 <br /> CCR, Section 66261.24 (6). In order for a waste to be non-hazardous by this <br /> toxicity criteria, the 96-hour LC50 must be less than or equal to 500 mg/L <br /> ignitability and reactivity testing was not performed on the ash sample because <br /> in the Judgement of ATT; the ash generation process would not produce a waste <br /> that meets the criteria for ignitability or reactivity described in 22 CCR, Sections <br /> 66261.21 and 66261.23, respectively. <br /> Similarly,concentrations of volatile organic compounds(VOCS)and semi-volatile <br /> organic compounds (SOCs), which may also contribute to the toxicity <br /> characteristic were not tested in the ash sample. 'mese tests were not performed <br /> because in the judgement of AIT, the ash generation process, high beat <br /> fim .arr <br />