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The Standard
October 2009 - Page 2

Dry Cleaner-Focused Remediation Projects
Environmental Standards is actively involved at several dry cleaner release sites – the same question is raised at virtually every work site. Property owners typically want to know if “waste containing tetrachloroethylene (otherwise known as perchloroethylene or PCE) generated from soil found beneath a former dry-cleaner business is a listed hazardous waste?” The question is asked so often that we decided to address the issue in this forum.

dry cleaningPCE-contaminated media may be regulated as a listed hazardous waste because contaminated environmental media are subject to regulation when the media contain hazardous waste. Generally, US EPA considers contaminated media to contain hazardous waste when it exhibits a characteristic of hazardous waste or is contaminated with concentrations of hazardous constituents from listed hazardous wastes that are above health-based levels (Management of Remediation Waste Under RCRA, EPA530-F-98-026). In addition, spent PCE used in dry cleaning is classified as “F002” (hazardous waste code) when the spent solvent formulation meets the 10%-criterion (by volume) in the listing (Call Center Monthly Report Question; October 1992, RCRA Online #13565). Contaminated media that contain spent PCE meeting the F002 listing description in §261.31 are, therefore, regulated as F002.

US EPA stipulates that a generator must know the source and the before use concentration of PCE in order to determine if the F002 listing applies. If the source of the PCE is from a product spill (e.g., unused solvent), it could be a U210 listed waste. A facility owner or operator must make a good faith effort to determine if a material is a listed hazardous waste. If an owner or operator cannot make such a determination because documentation regarding a source of contamination, contaminant, or waste is unavailable or inconclusive, the owner or operator may assume the source, contaminant, or waste is not a listed hazardous waste - provided that the material in question does not exhibit a characteristic of hazardous waste, RCRA requirements do not apply (Management of Remediation Waste Under RCRA, EPA530-F-98-026).

Furthermore, media that becomes contaminated with hazardous waste must be managed as if it were hazardous waste until it no longer exhibits hazardous waste characteristics or no longer contains the listed waste. US EPA believes that such levels for contaminated media are most appropriately determined on a site-specific basis by the US EPA Region (or authorized state agency) overseeing cleanup of such materials (Management of Remediation Waste Under RCRA, EPA530-F-98-026).

Additional guidance regarding the applicability of the F002 hazardous waste code is available in the following documents:

  • Call Center Monthly Report Question; May 1991 (RCRA Online #13469).
  • Memo, Lowrance to Wassersug; September 22, 1989 (RCRA Online #11470).

Additional guidance regarding contaminated media is available in the following documents:

  • Memo, Fields and Herman to RCRA/CERCLA Senior Policy Managers; October 14, 1998 (RCRA Online #14291).
  • Memo, Shapiro to Wright, September 15, 1995 (RCRA Online #11948).
  • Memo, Lowrance to Ely; March 26, 1991 (RCRA Online #11593)
  • Memo, Cannon to Jorling; June 19, 1989 (RCRA Online #11434).

 

SW-846 Update IV Creates Confusion For Regulators, Laboratories, And Stakeholders
Significant issues have developed in the environmental community since the US EPA published the notice of the availability of SW-846 Update IV (“Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”) in the Federal Register in January 2008. To state that regulators, laboratories, and stakeholders are confused would be an understatement.

SW-846 Update IV presented new or revised methods, deleted “obsolete” methods, and revised sample handling requirements. Questions about existing regulatory consent decrees or permits, the specific method version to use and what QC to apply, the development of multiple standard operating procedures, and laboratory accreditation must be answered. The consensus is that stronger language and clarification is required from the Agency.

Technical Director of Chemistry Rock J. Vitale, CEAC, CPC, is a member of the Environmental Laboratory Advisory Board, which is in the final stages of its recommendation process. Environmental Standards will be closely following this issue. Please look for “updates” in future editions of The Standard.

 

 


 

 

 

Eleven Phase I Environmental Assessments Conducted To Support Major Business Transaction
Teaming with Pittsburgh-based law firm Buchanan Ingersoll & Rooney, Environmental Standards assisted Sapa, a wholly owned subsidiary of Norwegian ORKLA ASA, in the recent acquisition of Indalex Aluminum (Indalex). Environmental Standards, the environmental consultant for the transaction, conducted 11 Environmental Site Assessments (ESAs) within a 5-week period.

The acquisition of Indalex will strengthen Sapa’s North American business. With networked facilities coast-to-coast in North America, Indalex supplies extruded aluminum solutions around the world. Sapa entered into an asset purchase agreement with the US aluminum extrusion company for the purchase of substantially all of Indalex’s assets in the US and Canada. Under the agreement, Sapa acquired Indalex’s 10 active plants (six in the US and four in Canada) with 29 presses and a total capacity of about 315,000 tons per year. Indalex’s sales in 2008 were about 200,000 tons, which represented sales of just above $900 million. Indalex has about 1,400 employees.

The purchase represented an underlying enterprise value of approximately $125 million for the business. The transaction allows Sapa to improve its geographical presence in North America, including an introduction into the Canadian region. Also, Sapa will be better positioned to service customers through improved painting, anodizing, and fabrication capabilities.

In addition, Sapa will now be able to optimize customer value through the combined knowledge, experience, and technical competence of the two companies. The combination has a significant potential of realizing cost synergies through plant restructuring and cost improvements in procurement, logistics, and shared services. The new company will have the ability to further develop new end-use applications in North America, thereby benefiting the customers and the extrusion industry as a whole.

“The agreement demonstrates Orkla’s and Sapa’s commitment to the North American extrusion market. Indalex is an excellent company with a long history in the industry. Combining the two companies will provide a wider product range and better geographic coverage than either company has alone. We will be able to offer our customers a range of products and services that is truly unique,” according to Jack Miller, Business Area President Sapa Profiles North America.

The agreement is part of a motion filed with the bankruptcy court in Delaware, along with sale and bid procedures, pursuant to Section 363 of the United States Bankruptcy Code. Final approval of Sapa’s agreement was announced at the end of July.

Sapa is the largest aluminum profiles producer in the world. The Sapa Group develops, manufactures, and markets value-added profiles, profile-based building systems, and heat exchanger strips in light-weight material aluminum. Sapa, which is divided into three business areas (Sapa Profiles, Sapa Building System, and Sapa Heat Transfer), is represented in Europe, North America, and Asia. The business concept is built on close cooperation with customers. Sapa is the leading company in its field of operation and has customers in the building, transport, engineering, telecom, and home and office industries. The Sapa Group has 12,000 employees world wide.

 

Radionuclides - When Total Metals May Not Be Total
periodic tableDuring environmental investigations, investigators occasionally include various radionuclides in the analytical suite for a project. Sometimes radionuclides can be present as naturally occurring radioactive materials and, in other cases, the radionuclides are anthropogenic. Like many analytes, radionuclides can be determined in environmental media by more than one analytical technique. Data users should understand the benefits and disadvantages of each technique and be aware that terminology can be deceiving.

Consider the analysis for total uranium and thorium, which can be performed by ICP/MS methods or isotopically by alpha spectroscopy. For total uranium, ICP/MS is a very sensitive technique for U-235 and U-238; however, ICP/MS cannot detect U-233, U-234, and U-236 or differentiate among the three. Alpha spectroscopy is the preferred technique for determining U-234, U-235, and U-238; typically, if U-233 or U-236 is detected by alpha spectroscopy, quantitation of the isotope is summed with U-234 or U-235, respectively.

Similarly for thorium, only Th-232 can be detected using ICP/MS because the specific activities unique to Th-230 and Th-228 are not detectable by ICP/MS.  If the objective is to determine total thorium, alpha spectroscopy is, therefore, the only option.  Essentially, ICP/MS is an extremely sensitive technique for Th-232 analysis and is a very good method for Th-232, but not a good method for total thorium.

Environmental Standards chemistry/quality assurance, geosciences, and information technologies staffs are providing site-wide quality assurance oversight for several high-profile projects on the East Coast, the West Coast, and the Northwest. For more information, contact Technical Director of Chemistry Rock J. Vitale, CEAC, CPC, at 610-935-5577.

 

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