Field Office Compliance - Assistance

Assistance ID - 46395

Linwood Mining Flyash - 310203857

12116 115th Ave Buffalo, IA 52804

Scott County

FO 6

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File Name	File Type	File Date	Note

Comments

Date	Comment	Commenter
4/3/2012	Tom Barnett, the Environmental Manager at the Arcelor Mittal (AM) Steel Mill in East Chicago, Indiana, called me to check into an Iowa regulatory matter. AM has been sending 30,000 tons/year of coal combustion residue (CCR) to the Linwood mine in Scott County where various kiln dusts and CCRs have been designated as a beneficial reuse material to backfill the limestone mine. AM recently changed the coal source for their coke plant and now the CCR concentration exceeds Iowa’s Beneficial Reuse lead standard of 0.15 ppm, as determined by the synthetic precipitation leaching procedure (SPLP). Once this characteristic was identified, AM immediately stopped sending CCR to Linwood, and is now land filling it in Indiana. Mr. Barnett wanted to know the probability of successfully applying to the DNR for a waiver to allow up to 0.75 ppm lead in the SPLP extract, so they could again send the CCR to Linwood. I reviewed the beneficial reuse regulation (Chapter 567 IAC 108) with Mr. Barnett, which states that SPLP leachate concentrations in a beneficial reuse material cannot exceed 10 times the drinking water MCLs (which is 0.015 ppm for lead and therefore 0.15 ppm for lead in the SPLP leachate). I also checked with DNR’s Matt McDonald who indicated that it was very unlikely the DNR would grant a waiver of the requirements in 567 IAC 108.6(1)a. I apprised Mr. Barnett of this opinion.	DAVID MILLER

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