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2019-07-23_REVISION - M1977348
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2019-07-23_REVISION - M1977348
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Last modified
1/6/2025 2:29:03 AM
Creation date
7/23/2019 1:47:58 PM
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Template:
DRMS Permit Index
Permit No
M1977348
IBM Index Class Name
Revision
Doc Date
7/23/2019
Doc Name
Adequacy Review Response
From
Golder Associates
To
DRMS
Type & Sequence
TR10
Email Name
AME
Media Type
D
Archive
No
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July 19,2019 18107649 <br /> Additionally, analytical testing of the CKD material was conducted by Secor and Holnam(Secor 1998). The results <br /> ' of the solids analysis are discussed below. <br /> 5.1 Bulk Testing <br /> Solid-phase chemical analysis was performed on the soil and rock samples(Golder 2014). The chemical analysis <br /> was performed in a two-step process including digestion of the sample in acid to release the elements into the <br /> solution phase (EPA Method M3010A)followed by analysis of the elements in the resulting digestion by <br /> inductively coupled plasma mass spectrometry(ICP-MS; EPA Method M6020). The results from solid-phase <br /> chemical analysis were used to make an inference regarding elements of potential environmental concern, <br /> although it should be understood that a high concentration of a particular element does not necessarily imply that <br /> this element will indeed be mobilized in concentrations that may lead to environmental impacts. The elemental <br /> compound concentrations from the solid-phase analysis conducted at part of the Golder program are detailed in <br /> Table 13. Additionally, samples of the CKD materials were analyzed for total metals once in 1991 and then <br /> quarterly beginning in the first quarter of 1993 through the first quarter of 2002, with the exception of 1994. <br /> Summary statistics of these results are provided in Table 14. Schoeller diagrams are provided in Figure 13 and <br /> Figure 14. <br /> ' Concentrations reported for the CKD testing conducted by Golder and the quarterly testing by Holcim are within <br /> the same range of values. The CKD material has elemental compounds that are higher than the native materials, <br /> including: boron, calcium, lead, potassium, selenium, thallium, and zinc. The lead, selenium, and thallium <br /> ' concentrations are elevated by at least a full order of magnitude. The CKD materials exhibited concentrations of <br /> arsenic, barium, chromium, and manganese that were similar to or less than the native materials. The <br /> concentrations of arsenic, barium, copper, manganese, thallium, uranium and zinc are greater in the CKD and <br /> native materials than in published concentrations for carbonates and sandstones(Price 1997). <br /> 5.2 Synthetic Precipitation Leaching Procedure <br /> The SPLP is a test where material such as soil or rock is saturated with a solution designed to mimic meteoric <br /> water or natural weathering solutions. The materials undergo grain size reduction such that all components pass a <br /> 0.375'sieve. The solution to rock ratio is 20 to 1, and the test concludes after 18 hours, at which point the <br /> leachate is collected. The chemical composition of the Ieachate is analyzed for the constituents of interest. Metals <br /> are generally analyzed by US EPA Methods 200.7 or 200.8 by ICP or ICP-MS, respectively. The Ieachate solution <br /> has a weakly acidic pH of 5.0 to approximate rainfall (extraction fluid#2 in US EPA Method 1312). The test is not <br /> designed to definitively predict long term water quality associated a material, as this is complicated by a number <br /> ' of variables such as surface area exposure,weathering rates, flow rates, and actual water to rock ratios. <br /> SPLP testing was performed as part of the Golder and Secor programs. The SPLP testing conducted under the <br /> Golder program was conducted on four samples of CKD, one sample of silt, four samples of limestone and two <br /> samples of sandstone. The analytical results for the SPLP Ieachate analysis are tabulated in Table 15. Schoeller <br /> diagrams are provided in Figure 15 and Figure 16. <br /> The SPLP Ieachate pH values are greater than 12 for the CKD material and between 7 and 10 for the native <br /> materials. Groundwater pH values in Site wells are between 7 and 9. These values are similar to values observed <br /> in the wells prior to CKD placement in area A2, and do not show an increase over time that would be expected if <br /> the waters were being influenced by CKD. In addition, the SPLP Ieachate concentrations were at least an order of <br /> magnitude higher for the CKD material than for the native materials for: arsenic, barium, chromium, lead, lithium, <br /> GOLDER 11 <br />
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