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• <br />1. Where groundwater monitoring is deemed appropriate, it is recommended that a <br />representative suite of indicator elements be developed from site specific CKD leach tests <br />and ambient groundwater conditions. Because clay compositions differ from site to site, <br />a single set of parameters would not be appropriate. <br />2. Ivtonitoring parameters should ideally consist of elements or compounds that consistently <br />report above detection limits in groundwater samples and that consistently report above <br />regulated limits in CKD leach tests. <br />3. Where sewer sludge, compost, or other organic materials or amendments may come into <br />contact with the CKD, or where reducing conditions can be expected [o result, Mn might <br />be used as a monitoring parameter. NIn is a typical component of limestone and can be <br />mobilized under reducing conditions. Use of i~tn for monitoring might be given extra <br />consideration [o account for current uncertainty by EPA about the actual health-based <br />toxicity of manganese. Where Mn (or other regulated parameter) excursions might raise <br />local alarms without leading to health-based protections, its selection as a monitoring <br />parameter should be weighed. <br />4. Even though high alkalinity is a feature of "fresh" CKD weathering, it is not <br />recommended that pH alone be used as a monitoring parameter where pollution from <br />high pH might be anticipated. Because pH is a logarithmic representation of hydrogen <br />ion activity, a unit shift in pH represents a 10-fold increase (or decrease) in H' activity. <br />For instance, a pH 8 solution contains 1000 times greater hydrogen ion activity than a pH <br />I 1 solution; thus, unless the pH 11 solution comprises an extremely high percentage of a <br />pH 8 and pH l 1 solution mixture, pollution by [he high pH solution would be masked and <br />not detectable. A 50:50 mixture could not be detected. <br />5. Until the degree of variability on the dust source is well established, periodic leach <br />testing of the CKD should be conducted. The technical revision for the Holnam <br />Boettcher Plant, for instance, requires TCLP testing on CKD samples semi-annually. <br />REFERENCES <br />Merritt, F.S., Standard Handbook for Civil Engineers. Third Edition, McGraw-Hill, Inc. <br />ASTM D X050-96, "Standard Guide for the Commercial Use of Lime Kiln Dusts and Portland <br />Cement Kiln Dusts." <br />Adelaide Brighton Cement, Birkenhead Division, "CKD Product Information." <br />EPA Federal Register Document, August 1999, "Standards for the Management of CKD." <br />University of Illinois, Materials Science and Engineering, "Concrete Scientific Principles." <br />cc: Mike Long <br />!im Pendleton <br />m:\min\hhp\ckd disposal 3.doc <br />