SECTION FIVE
Performance Standards and Construction Quality Control
the ash from the pilot study were either non-detect or were below TCLP limits for characteristic
hazardous waste, so no fixation or stabilization was required prior to backfilling incinerator ash
on site. Some fly ash had TCLP metal concentrations above the drinking water standards.
A risk assessment concluded that full-scale operation of the incinerator at the SCS Site would not
pose a threat to public health. All of the estimated risks were within the range that is considered
acceptable for cleanup activities performed under the Superfund hazardous waste program.
The results from the trial burn demonstrated that the incinerator met the RCRA performance
standards of 40 CFR 264 and other regulatory and contractual requirements while burning site
soils spiked with POHCs and metals.
During full-scale operations, all treated soil batches met the cleanup criteria for Fenac after the
first pass; eight treated soil batches did not initially meet the cleanup goal for β -naphthylamine.
Of the total mass of soil treated, less than 3% required additional thermal treatment after the first
pass. Soil not meeting the cleanup criteria was sent back to the feed preparation building where it
was blended with the other soil, and then conveyed to the incinerator.
TCLP metals results for 2 batches of fly ash were greater than 25 times the drinking water
standard (once during a metals spiking test and the other time during full-scale operation). The
fly ash from these batches was stabilized prior to backfill.
Stack testing, perimeter air monitoring and ambient air monitoring performed in the community
near the project site met all specified objectives.
Data Quality
All trial burn testing was conducted in accordance with the source test sampling and analysis
protocols specified in the quality assurance plan for the trial burn. All data gathered during the
trial burn were found to be of acceptable quality to demonstrate that the incinerator met the
performance standards. The quality assurance/quality control (QA/QC) results were compared to
the data quality objectives specified in the Project Quality Assurance Plan contained in the Trial
Burn Plan. This comparison showed that greater than 90% of the accuracy, precision, and
method performance objectives were met.
The perimeter air sampling and off-site ambient air sampling were conducted in accordance with
the SCS Site Perimeter Air Sampling Plan, including the calibration, sampling and analytical
procedures. Other sampling and analysis activities during full-scale operations (e.g., soil and ash
tests) were conducted according to the protocols in the Chemical Quality Management Sampling
Plan.
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Slippery Chemical OU 3 Final RA Report