Delisting Petition JD Ankeny Draft 8-26-2013.docx

DELISTING PETITION FOR F006/F019 

FILTER CAKE 

JOHN DEERE DES MOINES WORKS 

825 SW IRVINEDALE DRIVE

ANKENY, IOWA

Prepared for:

John Deere Des Moines Works

of Deere and Company

825 SW Irvinedale Drive 

Ankeny, Iowa 

Prepared by: 

Project Integrated, Inc. 

1900 South Highway 101, Suite 4A Greer, SC 29650 

January 

2014

Note to Reviewers: This delisting petition has been formatted to conform to Appendix A: 

Framework for Delisting Petitions included in the EPA guidance document entitled, EPA RCRA 

Delisting Program, Guidance Manual for the Petitioner, March 23, 2000.
JD Ankeny Delisting Petition 1-22-14.docx

TABLE OF

CONTENTS 

Part A: Delisting Administrative Information................................................................................ 1 

1. Name of Petitioner................................................................................................................. 1 

2. People to Contact for Additional Information Pertaining to this Petition..................... 1 

3. Facility Responsible for Generating Petitioned Waste ..................................................... 1 

4. Location of Petitioned Waste ............................................................................................... 1 

5. Description of Proposed Delisting Action.......................................................................... 1 

6. Statement of Need and Justification for the Proposed Action......................................... 2 

7. Signed Certification Statement ............................................................................................ 3 

Part B: Delisting Waste and Waste Management History Information...................................... 4 

1. Description of Petitioned Waste .......................................................................................... 4 

2. Physical Form of Petitioned Waste ..................................................................................... 4 

3. Estimation of Percentage of Solids in Petitioned Waste................................................... 4 

4. History of Waste Generation ............................................................................................... 4 

5. Volume of Petitioned Waste................................................................................................. 4 

6. History of Waste Management Methods ........................................................................... 5 

Part C: Delisting Process Information.............................................................................................. 7 

GENERAL OPERATIONS AT THE GENERATING FACILITY

1. Description of Facility Business and Operations .............................................................. 7 

2. List and Description of Manufactured Products............................................................... 7 

3. List and Description of Wastes Generated at the Facility ................................................ 9 

4. Description of Manufacturing and Waste Treatment Areas and Units .......................13

5. Regulatory Status of On-Site Waste Treatment Storage and Disposal Units ..............18

CONTRIBUTING MANUFACTURING PROCESSES
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6. Description of Pre-Process Steps ......................................................................................19

7. Description of Manufacturing Process Contributing to the Petitioned Waste............19

8. Description of Manufacturing Process Where Petitioned Waste is Generated...........20

9. List of Process Equipment With Description...................................................................20

10. Description of Facility Operating Cycles..........................................................................20

11. History and Potential for Operational or Waste Variability..........................................21

12. Description of Potential for Waste Variability with Manufacturing Variability ........22

13. Contribution of Waste Treatment Process to Petitioned Waste ....................................22

CONTRIBUTING WASTE TREATMENT PROCESS

14. Description of Waste Treatment Processes Contributing to the Petitioned Waste.....23

15. Description of Location of Petitioned Waste Generation...............................................23

16. Description of Waste Inputs and Outputs .......................................................................23

17. Description of Non-Process Wastes Entering the Waste Treatment Process ..............24

18. Description of Process Equipment ....................................................................................24

19. Description of Facility Operating Cycles..........................................................................24

20. History and potential for Operational or Waste Variability Due to 

Treatment Processes ............................................................................................................ 24 

21. Description of Potential for Waste Variability with Manufacturing Variability ........25

22. Management of Petitioned Waste in a Land Based Unit................................................25

WASTE MANAGEMENT OPERATIONS

23-24. Waste Management Operations ........................................................................................26

PROCESS MATERIALS

25. List of Materials Contributing to the Petitioned Waste..................................................26
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26. List of Material Safety Data Sheets....................................................................................26

27. Description of Oils, Greases, and Hydraulic Fluids Which Enter the Process............26

SPECIAL INFORMATION

28. Request for Upfront Exclusion of Waste to be Generated .............................................28

29-31. Information on Bench-Scale or Pilot Scale Waste Characterization..............................28

32. Request for Exclusion for Waste from Multiple Waste Treatment Facility .................28

33-34. Information on Procedures at Multiple Waste Treatment Facilities.............................28

Part D: Analytical Plan Development............................................................................................29

1. Complete List of Constituents of Concern for the Petitioned Waste............................29

2. Mass Balance Demonstration for Constituents of Concern for which

Analyses Were Not Conducted .........................................................................................31

3. Rationale for Exclusion of Constituents from the List of Constituents

of Concern ............................................................................................................................31

4. Explanation of Why Petitioned Waste Does Not Exhibit Any Hazardous

Waste Characteristic for Which Analyses Were Not Conducted..................................31

Part E: Sampling and Analysis Information.................................................................................32

1. Submittal of Draft Sampling and Analysis Plan to EPA ................................................32

WASTE SAMPLING INFORMATION

2. Waste Sampling Information .............................................................................................33

SAMPLING STRATEGY

3. Sampling Plan Information................................................................................................34

a. Description of Sampling Locations ...................................................................................34

b. Selection of Sampling Locations........................................................................................34

c. Description of Sampling Procedures ................................................................................35

d. Description of Sampling Devices ......................................................................................36

e. Discussion of Sampling Plan Deviations.......................................................................... 36 

f. Discussion of Sample Representativeness........................................................................37

SAMPLE SPECIFIC INFORMATION

4. Number of Samples of Petitioned Waste Collected........................................................38
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5. Individual Sample Information .........................................................................................38

a. Sample Information.............................................................................................................38

b. Description of Sample Collection......................................................................................38

c. Description of Sampling Locations ...................................................................................39

d. Description of Compositing Methods...............................................................................39

e. Physical Description of Sample at Time of Collection....................................................39

f. Time and Date of Grab and Composite Sample Collection...........................................40

g. Handling and Preparation Techniques.............................................................................40

OTHER GENERAL INFORMATION

 

6. Description of Weather Conditions During Sampling................................................... 42 

7. Ongoing Facility Activities That May Have Affected Sample 

Representativeness .............................................................................................................. 42 

8. Description of Sampling Device Decontamination......................................................... 42 

9. Chain-of-Custody Procedures ........................................................................................... 42 

10. Description of Quality Control Procedures During Transportation

to the Laboratory ................................................................................................................. 43 

LOCALIZED AREA OF CONTAMINATION

11. Sample Collection to Determine the Presence of a Localized

Area of Contamination .......................................................................................................43

12-15. Information on Characterizing Hot Spots........................................................................43

MULTIPLE WASTE TREATMENT FACILITY

16. Samples for Characterization of Waste from a Multiple Waste 

Treatment Facility................................................................................................................ 43 

17-20. Information of Waste from Multiple Waste Treatment Facility.................................... 43 

WASTE ANALYSIS INFORMATION

21. Identification of Sample Analyses Staff............................................................................ 44 

a. Name and Address of Laboratory Performing Analyses............................................... 44 

b. Resumes of Laboratory Analysts....................................................................................... 44 

22. Laboratory Data Reports .................................................................................................... 44 

23. Sample and Analysis Information..................................................................................... 44 

24. Names and Model Numbers of Analytical Equipment.................................................. 45 

25. Other Information Necessary to Interpret Data .............................................................. 45 

26. Information on Matrix or Surrogate Spike and Spike Duplicate Analysis .................. 46 
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27. Correction of Analytical Data Based on Quality Control Results................................. 46

28. Explanation of Inconsistencies or Deviations found in Reported 

Analytical Results ................................................................................................................ 47 

29. Calculations for Oily Waste Testing ................................................................................. 48 

Part F: Ground Water Monitoring Information...........................................................................49

1. Management of Petitioned Waste in a Land-Based Unit ...............................................49

2-9. Information on Groundwater Monitoring ....................................................................... 50 

10. Description of Other Disposal Units Used and Waste Characterization..................... 50 

11. Description of Why Groundwater Monitoring is Not Required................................... 50 

List of Tables

Table Title

1 Summary of Filter Cake Testing for Approved Constituent of Interest (COI)

2 Filter Cake Sample Results for Filter Cake 1

3 Filter Cake Sample Results for Filter Cake 2

4 Filter Cake Sample Results for Filter Cake 3

5 Filter Cake Sample Results for Filter Cake 4

6 Filter Cake Sample Results for Filter Cake 5

7 Filter Cake Sample Results for Filter Cake 6

8 Filter Cake Sample Results for Initial Filter Cake Sample

9 Filter Cake Case Narrative and Evaluation

 10A Filter Cake Test Data

 10B Oily Waste Test for Mobile Metal Concentration

List of Figures 

Figure Title

1 Site Location Map

2 Facility Wastewater Diagram

List of Appendices 

The following items are included only on enclosed disk:

Appendix Title

A Significant Agency Correspondence

B Field Sampling Activity Notes

C Calculations for Oily Waste Sample Analysis

D Analytical Data Package, September 8, 2011 Initial Sampling Episode

E Analytical Data Package, December 3, 2012 Sampling Episode (Filter Cake #1)

F Analytical Data Package, December 6, 2012 Sampling Episode (Filter Cake #2)

G Analytical Data Package, December 10, 2012Sampling Episode (Filter Cake #3)

H Analytical Data Package, December 14, 2012 Sampling Episode (Filter Cake #4)

I Analytical Data Package, December 17, 2012Sampling Episode (Filter Cake #5)
JD Ankeny Delisting Petition 1-22-14.docx

J Analytical Data Package, December 19, 2012 Sampling Episode (Filter Cake #6)

K Project Personnel

L Laboratory QA Manual

M List of Acronyms and Abbreviations

N Sampling and Analysis Plan (SAP) for Delisting of F009 and F019 Sludge Filter 

 Cake, January 2012, revised June 2012 

O Quality Assurance Project Plan (QAPP) for Delisting of F009 and F019 Sludge 

 Filter Cake, March 2011, revised June 2012
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PART A: DELISTING ADMINISTRATIVE INFORMATION 

1. Name of Petitioner

1.1 Name of Firm Submitting Petition: John Deere Des Moines 

Works of Deere & 

Company (“John 

Deere”)

1.2 Mailing Address: 825 SW Irvinedale Drive

1.3 Fax Number

Ankeny, Iowa 50023

515-289-3478

2. People to Contact for Additional Information Pertaining to this Petition

2.1 Name

Mr. Charles Busch 

Title

Environmental Engineer

PhoneNumber

515-289-3429 

2.2 

Mr. Tom Noble 

Mailing Address 

Environmental Professional 515-289-3445 

Same as A.1.2 

3. Facility Responsible for Generating Petitioned Waste

3.1 Name of Facility: John Deere Des Moines Works

3.2 Location of Facility: 825 Irvinedale Drive 

Ankeny, Iowa

3.3 RCRA ID Number: IAD069624500 

4. Location of Petitioned Waste

Same as Item A.3.2 

5. Description of Proposed Delisting Action

This petition requests the exclusion of a specific waste stream generated at the John Deere

Des Moines Works facility at 825 SW Irvinedale Drive from the list of hazardous waste 

identified in 40 CFR Part 261, Subpart D. The waste for which this petition is filed is a 
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filter cake generated from the treatment of wastewaters associated with electroplating and 

chemical conversion coating and listed as F006/F019 treatment sludge. The filter cake 

does not exhibit any of the hazardous waste characteristics identified in 40 CFR Part 261, 

Subpart C, and does not contain the constituents for which the waste was listed at 

significant levels.

In 2011, John Deere began the process of requesting that the F006 filter cake be delisted 

based on the belief that the chrome electroplating process was the only operation at the 

facility generating a RCRA listed hazardous waste. However, in early 2012, it was 

determined that a small quantity of aluminum parts was present in large cotton pickers 

processed in the phosphate conversion coating line. John Deere processes electroplating 

wastewater and phosphating wastewater together. This process generates one waste 

treatment water sludge or filter cake. While it was determined that the wastewater from

the chemical conversion coating of aluminum parts was not a RCRA characteristic 

hazardous waste, it is estimated that the filter cake generated from treatment of this 

wastewater may be a listed F019 hazardous waste. Therefore, this petition requests the 

exclusion of the filter cake from the F006 and the F019 listing (the Petitioned Waste).

6. Statement of Need and Justification for the Proposed Action

John Deere is submitting this petition as the generator of a filter cake or wastewater 

treatment sludge at the Ankeny Iowa facility. The facility generates a filter cake that is 

listed as F006 because the sludge resulted from treatment of electroplating operation

wastewater. The same filter cake may be listed as F019 because the filter cake results from 

the treatment of wastewater from the phosphate conversion coating of large cotton pickers

containing a small quantity of aluminum parts.

Testing has determined that the dewatered F006/F019 filter cake generated by the on-site 

wastewater treatment plant does not exhibit any hazardous waste characteristics as 

identified in 40 CFR 261, Subpart C, nor does the Petitioned Waste exhibit any other 

factors that could cause the waste to be a hazardous waste. This petition and supporting 

data are required to document that the waste for which this petition is filed is not

hazardous. Delisting the waste will reduce the substantial cost of handling and disposing 

the sludge as a listed hazardous waste. 
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7. Signed Certification Statement

I certify under penalty of law that I have personally examined and am familiar with the

information submitted in this demonstration and all attached documents, and that, based 

on my inquiry of those individuals immediately responsible for obtaining this information, 

I believe that the submitted information is true, accurate and complete. I am aware that 

there are significant penalties for submitting false information, including the possibility of 

fine and imprisonment. 

Authorized Representative’s Signature: 

Typed Name:

Title:
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PART B: DELISTING WASTE AND WASTE MANAGEMENT

INFORMATION 

1. Description of Petitioned Waste

The Petitioned Waste (F006/F019 filter cake) is a solid waste generated as a filter cake 

from dewatering sludge generated by the plant wastewater treatment facility.

Common name of Petitioned Waste: Filter Cake 

EPA Hazardous Waste Number: F006; F019 

Hazardous Waste Description: Dewatered wastewater treatment sludge

from electroplating operations (F006) and chemical conversion coating of aluminum 

(F019) 

2. Physical Form of Petitioned Waste

Petitioned Waste (F006/F019 filter cake) is a slightly damp, sticky solid that resembles 

clay in its appearance and texture. 

3. Estimation of Percentage Solids in Petitioned Waste

Based on analyses performed for this delisting petition, the Petitioned Waste (F006/F019 

filter cake) contains between 24% and 30% solids. This is consistent with the normal 

solids for material from the filter press.

4. History of Waste Generation

The Petitioned Waste (F006/F019 filter cake) is currently being generated at the facility.

John Deere will continue to generate wastewater treatment filter cake in the future. 

5. Volume of Petitioned Waste

The Petitioned Waste (F006/F019 filter cake) is generated on a continuous basis by the 

facility. The F006 filter cake volume for the period of 2009 through 2012 is listed below

(density of approximately 80 lb/ft3 to 85 lb/ft3). The facility has manufacturing 

capacity that may generate a larger wastewater flow and therefore a larger quantity of 

the petitioned waste.
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The facility estimates the facility has manufacturing capacity that may generate 

Hazardous Waste at 600 ton/year. 

Filter Cake Generation

BASIS DATA

CY 2009 189.3 tons

CY 2010 261.2 tons

CY 2011 207 tons

CY 2012 301 tons

Facility Capacity 600 tons/year

Petition Request 50 ton/month

100,000 lb/month

6. History of Waste Management

6a. Present Waste Management Methods

The wastewater treatment plant including the sludge treatment system and the sludge 

container is inside a building. The Petitioned Waste (F006/F019 filter cake) is accumulated 

in a roll-off container located directly under the Recessed Chamber Press (RCP). The 

container when full is moved by the transporter with an empty container placed under the 

RCP. The Petitioned Waste (F006/F019 filter cake) is then transported in the container

from the site to the following RCRA Subtitle C facility for treatment and disposal: 

Envirite of Illinois 

16345 South Center Avenue 

Harvey IL 60426 

ID ILD000666206

708-596-7040 

6b. Past Waste Management Methods

The Petitioned Waste (F006/F019 Filter Cake) was previously sent for treatment and 

disposal to:
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Peoria Disposal Company

PDC #1 Landfill 

4349SouthportRoad

Peoria, IL 61615 

ILD000805812 

309-676-4893 

6c. Proposed Waste Management Methods for Delisted Waste

When the Petitioned Waste (F006/F019 f ilter c ake) is successfully delisted, John 

Deere expects to send the filter cake to:

Metro Park East Landfill 

12181 University Avenue, NE 

Mitchellville, IA 50169 

515-967-2076 
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PART C: DELISTING PROCESS INFORMATION 

GENERAL OPERATIONS AT THE WASTE GENERATING 

FACILITY

1. Description of Facility Business and Operations

The John Deere facility is located at 825 SW Irvinedale Drive in Ankeny, Iowa. The facility 

covers over 451 acres including manufacturing areas (approximately 180 acres) and testing 

farmland.

The John Deere facility produces agricultural equipment. There may be some seasonal 

variability for each product line but overall production is fairly even. The facility can 

operate up to 24 hours per day, 7 days per week, with the exception of periodic planned 

shutdowns for routine maintenance. The Primary Standard Industrial Code for this 

facility is 3523 (NAICS 333111). 

The manufacturing area includes four major manufacturing buildings (Buildings 1, 2, 3, 

and 4) and several smaller supporting and/or expansion buildings. A portion of the site 

originally was used for the manufacture of munitions during World War II. The main 

buildings including the wastewater building were acquired by John Deere and modified 

for agriculture equipment manufacture. 

The manufacturing area of the property is either covered by pavement or gravel, and is

relatively flat with surface runoff to drains and subsurface storm piping. General 

drainage is to the perimeter of the manufacturing area, with most of the storm piping 

discharging to a storm water pond at the southeast of the area.

2. List and Description of Manufactured Products

The Ankeny facility assembles agricultural equipment including:
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Cotton picking equipment; 

Spraying equipment; 

Tillage (plowing) equipment; and

Grain drills (seeding) 

The Ankeny facility manufactures these products as follows:

Steel metal parts – cutting, punching, stamping, welding; cleaning, plating, and 

painting; plating includes chrome surface hardening for cotton picking spindles 

(this is the electroplating operation generating the F006 filter cake); cleaning 

includes wash lines prior to painting and embedded wash stations in paint lines; 

these operations are the major source of wastewater

Aluminum metal parts – a few different parts are manufactured from aluminum 

to be corrosion resistant; these parts are cleaned in the wash lines which include

operations considered chemical conversion of the steel parts.

o Chemical conversion coating is a metal finishing process which involves 

the application of a coating (e.g., by spray or dip tank) to a previously 

deposited metal or a base metal to increase corrosion protection and to 

prepare the surface for additional coatings, or the formulation of a 

special surface appearance; 

o Most conversion coating operations are used for steel parts, 

including chromating and phosphating.

o Aluminum parts are not a major manufacturing item, but small 

volumes will continue to be a part of the manufacturing facility using

the wash line

Plastic tanks (on-site contractor) – forming tanks; this is a minor source of 

wastewater

Assembly – touch up painting, testing; this is a small source of wastewater and 

generates a minor amount of storm water from outside operations.
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3. List and Description of Wastes Generated at the Facility

The Petitioned Waste (F006/F019 filter cake) is generated from treatment of wastewater 

from sources within the manufacturing plant. The facility is a Large Quantity Generator 

of hazardous wastes including: spent chemicals; lab packs; and paint. These wastes are 

generated from operations that are independent from the source of the Petitioned Waste. 

The facility also generates non-hazardous solid wastes such as: cleaning compounds;

Universal Wastes; cardboard; non-hazardous process sludges; used oil; and trash. 

Wastewater Sources

The wastewater sources are listed and described below and further identified by 

Building and Department where the wastewater is generated. The table also includes 

some precipitation sources from open areas where equipment is washed. The sources 

of the listed waste are: 

F006 chrome electroplating, Building 2, Department 39

F019 chemical c onversion, Building 2, Department 19, Stages 3 and 5 

The table identifies wastewater flows that include: 

 Continuous flow from wash line rinse water and from and cooling water; flow is 

estimated from flow rate and operating time

 Periodic flow from open washing systems

 Periodic tank/bath dumps for some tanks in the systems; not all tank dumps are 

discharged to the Waste Water Reclamation Authority (via the Ankeny sewer) 

with some transported to other wastewater treatment systems (e.g., Some periodic

wash tank/bath dumps and/or system cleanouts are shipped offsite to John 

Deere Waterloo Works; flow is estimated from frequency and tank volume
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Limited precipitation collected from open areas

Bldg Dept Description

Tank, 

gal Dumps

Flow, 

gpd Comments

28 1 Wash Booth 2,000

Equipment Wash 500 Approximate

Boot Area 500 Precipitation

Puck Storage Area 1,000 Precipitation

2 39 Chrome

Electroplating

15,000 F006 Source

1062 Cr Rinse Overflow 5,000 5 gpm@2 shift

7153 Cr Rinse Overflow 10,000 10 gpm@2 shift

Bath No Sent Offsite

2 19 E-Coat System 54,000 F019 Source

Stage 1 Dump 7450 2 months 100 Alkaline Cleaner

Stage 2 Dump 3150 1 wk 500 Water Rinse

Stage 2 Overflow 15,000 10 gpm@3 shift

Stage 2a Dump 3450 1 wk 500 Zn Activator

Stage 3 Dump 5275 - Sent Offsite

Stage 3 Oberland 3,000 Filter release

Stage 4 Dump 2800 1 wk 400 Water Rinse

Stage 4 Overflow 15,000 10 gpm@3 shift

Stage 5 Dump 2800 1/qtr <100 Cr Sludge Dump

Stage 5 Overflow 3,000 2 gpm@3 shift

Stage 6 Dump 2800 1 month <100 DI Rinse (w/ Cr)

Stage 6 Overflow 15,000 10 gpm@3 shift

Stage 7 Overflow - Flows into Stage 6

E-Coat Post Rinse 4 5000 1.5/week 1,000 Permeate

Anolyte Has flow meter

18

20C Manual Wand

Wash

1,000

Hand operated wand 1,000 Estimate

2 38 Heat Treat 10,000

Bearings Cooling 10,000 Water

3 20A Wash Pretreatment 5,000

Wash Stage 1 4495 3 months <100 Flashkleen 1414

Rinse Stage 2 2980 1 day 3,000 Water Rinse

Rinse Stage 3 2980 3 months <100 Corcoat 618

Rinse Stage 4 1540 1 day 1,500 Water Rinse

Rinse Stage 5 940 1 week 100 RO Rinse

14 55 Garage Area 1,500

Booth Washer 1,500 2 gpm @ 1 shift
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Bldg Dept Description

Tank,

gal Dumps

Flow,

gpd Comments

18 20C Wash Line 16,000

18 20C Wash Stage 1 To drain 4,000 Coralite 500 or

18 20C Rinse Stage 2 To drain 4,000 DI/RO Rinse or

18 20C Rinse Stage 2 To drain 4,000 CEM 173WW11 or

18 20C Rinse Stage 2 To drain 4,000 Flashkleen 1414

28 1 Wash Booths 1,500

Inside Booth 800 1 gpm @ 1 shift

Outside Booth 700

16 55 WWTF 100

Outside Tank 100 Precipitation (~31”/yr)

ALL SOURCES 106,000

Additional information for each source:

Building 28, Department 1 Wash Booth – 

o Area is approximately 50 feet by 130 feet 

o Equipment after field testing is cleaned with power washers

o Storm water estimated at 50 inch/year precipitation

Building 2, Department 39 Chrome Electroplating – 

o Includes two complete multi-stage plating systems and wet scrubber

o Spent rinse waters and scrubber blowdown are directed to a separate 

Hexavalent Chrome Reduction Unit for the reduction of hexavalent 

chromium (the plating chemical) to trivalent chromium by chemically 

treating with sodium bisulfite

o This pre-treated spent rinse water then is discharge to the facility WWTP

o This pre-treated rinse water is <14% total flow to facility WWTP 

Building 2, Department 19 E-Coat System 

o 7-stage pre-paint wash system with a 3-stage post e-coat rinse 

system

o Wastewater generated from 7 wash stages embedded in the line

o Line may include the occasional cleaning of aluminum parts, but
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these aluminum parts are processed through the iron phosphate 

stage

o Continuous overflow from wash/rinse operations (stages 2, 4, 6)

Building 2, Department 38 Heat Treatment – 

o this includes four heat treating furnaces; cooling water for the furnaces is 

reused in subsequent processes before being sent to the to the facility 

WWTP 

Building 3, Department 20A Wash Pretreatment 

o 5 stage wash system prior to painting of parts

Building 14, Department 55 Garage Wash Area – 

o This is a wash booth for site vehicles and other small site miscellaneous 

wash off needs. 

Building 18, Department 20C Hand Wash Line

o Bay with a hand wand for treating oversize parts and small assemblies

Building 28, Department 1 

o Building for cleaning equipment such as agricultural units after testing 

o Outside area used for some cleaning with collection drain to facility 

WWTP

Building 16 WWTP Collection/Equalization Tank

o Tank surface area is 33 feet by 133 feet with direct rainfall into the open 

tank
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Information on the chemicals used in each operation in included in the Petition

Appendix N (Sampling and Analysis Plan for Delisting F006 and F019 Sludge Filter

Cake, January 2012, revised June 2012 in the SAP Appendix B).

Filter Cake (Petitioned Waste)

The Petitioned Waste (F006/F019 filter cake) is produced through the dewatering of

wastewater sludge generated at the on-site wastewater treatment plant (Building 16). 

This waste is stored on-site for less than 90 days and is then sent to a RCRA-permitted 

treatment, storage, and disposal (TSD) facility for disposal. 

Sanitary Sewage

This non-hazardous waste stream consists primarily of sanitary sewage and cooling 

tower blowdown along with other minor wastewater discharges. Discharge is regulated 

by the WRA Waste Water Discharge Permit A10138. 

Other solid wastes

Other solid waste streams consist of non-hazardous miscellaneous solid wastes 

generated at the facility as discussed previously. The non-hazardous industrial solid 

wastes are disposed of at a RCRA Subtitle D landfill. 

4. Description of Manufacturing and Waste Treatment Areas and Units

Manufacturing

The John Deere manufacturing operations do not generate the Petitioned Waste. 

Wastewater Treatment

The wastewater treatment processes that generate the Petitioned Waste (F006 filter

cake) include the main WWTP and a separate hexavalent chrome reduction treatment 

unit at the Department 38 Chrome electroplating unit. All site industrial wastewaters, 

including the Department 38 Chrome electroplating wastewater after hexavalent 

chrome reduction processing, are collected in a central equalization tank and then 

treated for discharge in the main WWTP. The filter cake is generated from the WWTP 

process. The individual treatment operations are described below. 
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Hexavalent Chrome Reduction Unit

The Hexavalent chrome treatment unit is located in Building 2 near the electroplating 

process line. The treatment unit receives mainly spent rinse waters from the chrome

plating system plus some blowdown from a scrubber for the process area. The 

treatment unit is a steel tank with overall dimensions of approximately 12 ft length

by 4 ft width by 4 foot height. The tank includes two internal baffles to form three

treatment zones. 

Zone 1 receives the spent rinse waters where they are pH adjusted. The pH 

probe controls the acid feed. Discharge from this zone is an underflow 

opening in the internal baffle. 

Zone 2 used to treat the hexavalent chrome in the rinse water. The

chemical sodium bisulfite is metered into this zone based on the ORP 

meter value. 

Zone 3 allows additional resonance time for the reaction to complete. ORP is 

displayed from this zone as an indicator of the completeness of the chrome 

treatment. The treated wastewater is discharged to the plant industrial waste 

water sewer where it flows to the WWTP equalization tank. 

Control monitoring of the chrome treatment unit includes the pH and ORP levels via a 

continuous transmittal to a central database display accessible by PC. Control testing 

includes at least one test per shift for presence of hexavalent chrome using the “powder 

pillow” technique manufactured by Hach. Chemical addition can be manually adjusted 

to maintain the ORP should the pillow tests indicate this is required.

The chrome electroplating concentrated baths are not discharged into this chrome 

treatment unit or into the facility WWTP. The spent bath solution is pumped to a 

hazardous waste tank and then removed by a permitted contractor for proper

transfer and treated for recycling off-site. 

The two chrome electroplating lines are each in a separate containment system with no 

plumbed outlet lines. Small leaks and spills are rare and may be pumped into the 

chrome reduction system for treatment prior to sending to industrial waste treatment. 

Any large release to the containment area would be contained and managed by the
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same process to manage concentrated chrome bath disposition. 

Wastewater Treatment and Discharge

The wastewater treatment plant (WWTP) is located at/in Building 16. There is an inground concrete equalization tank outside the building (Tank 1). The building foundation 

serves as the walls of the process tanks inside. These foundation/tanks are concrete with 

the inside wall exposed inside the building’s basement and the outside wall in-ground 

outside the building. 

Overall Flow: Water from Tank 1 is pumped into the building tanks where it 

flows through two flocculation/clarification units operated in series (Tank 2 

and Tank 3) and an equalization stage (Tank 4) before being discharged to the

public sewer. Settled solids from the flocculation/clarification units are 

pumped to a holding tank (Tank 5a) and then to a sludge thickener (Tank 5), 

with the thickened sludge dewatered in a plate and frame filter press. 

Tank 1 Equalization/Holding: The tank is an in-ground concrete structure 

with dimensions of 33 feet by 133 feet and 14 foot side wall (capacity 460,000 

gallons). Normal operating level ranges from 4 to 10 foot depth (operating 

volume 130,000 to 330,000 gallons). The tank is mixed with blowers and 

diffusers along the tank bottom. Chemicals added to this tank include pH 

adjustment (normal is acid with iron; caustic if needed), flocculent (normal 

cationic polymer), and anti-foam. Capability is present to add sodium 

bisulfite for hexavalent chrome reduction if there is any detection from 

the chrome treatment unit testing. With a normal/typical wastewater flow 

rate of 106,000 gpd, the equalization tank has a holding capacity of 1.5 to 3 

days.

Tank 2 Stage 1 Flocculation/clarification: The tank is a concrete cell 

approximately 20 ft by 20 ft by 15 ft depth, with an operating level from 10 to 

12 feet. A steel package-type circular flocculation/contact unit in the center of 

the tank is fed wastewater from the equalization Tank 1. Normal flow is 

approximately 60 to 160 gpm (based on typical 106,000 gpd flow). Chemicals 

added to the tank (Petition Appendix N includes the SAP with chemicals listed 

in Table 1.2 of that document) include pH adjustment (normal is caustic), 
JD Ankeny Delisting Petition 1-22-14.docx Page 16 of 50

emulsion breaker, ferric sulfate (to promote floc formation), and flocculent 

(normal cationic polymer). Flocculated solids are maintained as a sludge 

blanket in the unit with blowdown to the sludge thickener initiated by sludge 

depth (electronic eye sludge blanket detector initiates a timed pump cycle). 

Tank is configured to maintain flow through the sludge blanket for solids 

formation. Clarified water flows by gravity into a weir and then into the 

contact unit in the Stage 2 unit. 

Tank 3 Stage 2 Flocculation/clarification: Same configuration as Tank 2. 

Chemical addition includes only the flocculent (normal cationic polymer). 

Flocculated solids are less dense and a lower quantity than Tank 2 with 

blowdown initiated by sludge depth (similar to Tank 2). Clarified water flows 

by gravity into a weir and then into Tank 4. 

Tank 4 pH Adjustment: The tank is a concrete cell approximately 20 ft by 20ft 

by 15 ft depth with an operating level of about 4 feet. Inlet discharges by 

underflow into tank with overflow pipe for discharge to the public sewer. 

Tank also includes a sampling station. 

Tank 5 Sludge Thickener: The tank is a cone-bottom steel tank placed inside 

the concrete cell (cell is dry). Tank is 12 foot diameter by 15 ft height. Chemical 

addition includes coagulant (normal is cationic polymer). Overflow is directed 

back to Tank 1. Thickened sludge is feed to the plate and frame filter press. 

Wastewater treatment can operate 24-hours per day continuously. However, 

discharge is limited to time when the operator is present, normally 2 shifts per 

day. Discharge is regulated by the WRA Waste Water Discharge Permit 

A10138. 
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Sludge Treatment

Sludge is dewatered in a Netzch plate and frame filter press, including 40 plates (nominal 

50 cubic foot capacity) with automatic plate opener. Dewatering typically is for two cycles 

in an operating day with 1 to 2 operating days required for each calendar week.

Pre-coat is not required. The filter cake normally is approximately 24 to 30% dry solids,

reddish brown color, and clay-like consistency. Cake is dropped directly into a roll-off 

container. 

The filter cycle includes cake formation, dewatering, and extended dewatering for tramp

water removal. The unit prevents any filtrate leakage into the roll-off container during 

the dewatering cycle with a water collection pan draining to Tank 1. The drop cycle 

includes removing the pan, then automatic opening of each frame with the sludge

dropping into the container. Each sludge cake is broken into several pieces during the 

drop.

Filter Cake Storage and Disposal

The roll-off container for the Petitioned Waste (F006/F019 filter cake) is lined and located 

in the treatment building. The container will normally hold filter cake from 12 treatment 

cycles with removal and replacement of a full container every 2 to 3 weeks. The filter

cake was tested in 2009 and before that in 2007. (Petition Appendix N includes the SAP 

with the prior filter cake data in the SAP Appendix C). The key results were: 

Filter cake had no TCLP organic materials (2009 test) – waste codes D012 

through D043 

Filter cake had no total cyanide (2009, 2007) 

Filter cake only had TCLP detections for chromium (0.009 mg/L in 2009 and 

2007) and nickel (3.1mg/L in 2009; 0.55 mg/L in 2007). 

In February 2011, there was a process change in Department 19 that resulted in a 
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cessation of the site’s major source of zinc and nickel . The testing in this petition is 

representative of the current and planned operations at the facility.

5. Regulatory Status of On-Site Waste Treatment, Storage and Disposal Units

The plant generates the Petitioned Waste (F006/F019 filter cake) which is stored on-site

for less than 90 days and then sent to a RCRA-permitted TSD facility for disposal. The

plant has the following permits: 

Media Permit Number Issuing Agency

Water Contribution Permit A10138 Waste Water Regulation 

Authority (City of Des 

Moines)

Storm water NPDES GP-1 IA-4963-4832 Iowa DNR

Storm water NPDES GP-2 IA-20202-19970 Iowa DNR

Hazardous Waste IAD069624500 US EPA

Air Title V Permit 04-TV-017 Polk County – Air Division, 

Iowa
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CONTRIBUTING MANUFACTURING PROCESSES

6. Description of Pre-Process Steps

Major raw material is the steel for parts, some plastic for a limited number of other parts,

and coatings (paint). 

The significant pre-process steps include the following:

Metal parts – cutting, punching, stamping, welding 

Metal parts – cleaning and surface preparation (predominately steel) 

(Note: Chemical conversion treatment of aluminum parts in the E-coat 

line is the operation causing the F019 listing)

Metal parts – painting (E-coat line; some hand touch-up painting)

Metal parts – plating: chrome surface hardening for cotton picking spindles

(this is the electroplating operation generated the F006 filter cake 

Plastic tanks (on-site contractor) – forming tanks; this is a minor source of 

wastewater

Support for research and development 

7. Description of Manufacturing Process Contributing to the Petitioned Waste 

The manufacturing processes that contribute to the Petitioned Waste (F006/F019 filter

cake) include: 

Chrome electroplating of certain metal parts (F006) 

Location: Building 2, Department 39 

Process: Two complete multi-stage plating systems

Wastewater: Spent rinse waters (concentrated baths disposed off-site as

Hazardous Waste) 

Other wastewater: Wet scrubber for process emissions
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Aluminum chemical conversion coating (F019)

Location: Building 2, Department 19 

Process: Multi-stage E-coat line

Wastewater: Spent rinse waters (concentrated baths disposed off-site as

Hazardous Waste) 

8. Description of Generation of Petitioned Waste 

The Petitioned Waste is generated from the treatment of wastewater in the wastewater

treatment plant and not from a manufacturing process. The electroplating units which 

are the source of the wastewater were described in Item C. 7 in this petition. 

9. List of Process Equipment With Description

The process equipment and their descriptions as well as their operating ranges are 

described in Section C.7.

10. Description of Facility Operating Cycles

The manufacturing plant operates 24 hours/day, 7 days/week, 365 days/year with 

the exception of periodic planned shutdowns for routine maintenance. 

The Hexavalent Chrome Reduction Unit can operate 24-hours per day continuously.

However, the treatment is normally one or two shifts per day to correspond to operation

production needs. The pre-treated wastewater from the Reduction Unit is discharged to 

the plant sewer and wastewater plant equalization basin.

Wastewater Treatment Plant can operate 24-hours per day but treatment and discharge is 

limited to time when the operator is present, normally 2 shifts per day. Discharge is 

regulated by the WRA Waste Water Discharge Permit A10138. Dewatering typically is for

two cycles in an operating day with 1 to 2 operating days required for each calendar week.

Cleaning and maintenance operations are performed annually at designated time periods.
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11. History and Potential for Operational or Waste Variability

The manufacturing plant began operation in 1943 as a munitions plant. The plant 

was converted to the manufacture of farm equipment from about 1947 to 1950 and 

has manufactured similar equipment since then. 

The electroplating unit has been in operation since the early 1960s. The electroplating 

line normally runs 1 to 3 shifts per day with actual operation depending on specific 

demand for plated parts. The Hexavalent Chrome Reduction unit runs as needed.

During the test period of December 3 to 17, 2012, the electroplating unit was in 

operation.

The wash lines, which include the small quantity of aluminum parts, run continuously 

except for scheduled downtime for maintenance. During the test period of December 3 

to 17, 2012, the wash lines were in operation. 

Manufacturing operations generally run at about 90% of plant capacity. During the test 

period of December 2 to 17, 2012, manufacturing was at 

100% capacity.

The consistent operations at the manufacturing plant lead to little variability in 

wastewater composition. The composition of the filter cake should not vary from

sample to sample. 
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12. Description of Potential for Waste Variability with Manufacturing Variability 

Plant wastewater flow is approximately 100,000 to 110,000 gpd. The major sources for

this wastewater are continuous or nearly continuous operations as follows:

Wash lines – about 70,000 gpd (E-coat; other) 

Hexavalent Chrome Reduction Unit – about 15,000 gpd 

Other wash units – about 15,000 gpd 

Manufacturing operations are consistent to meet quality control standards (e.g., for 

parts, coatings, finished surfaces) and only minor variability in the composition of 

the wastewater from the manufacturing process may occur. 

The Petitioned Waste (F006/F019 filter cake) is generated from physical-chemical 

wastewater treatment using well-known chemistry and substantial plant-specific 

experience with chemical feed rates and with equipment capabilities. The wastewater

treatment facility has been in compliance with the discharge permit. 

The Petitioned Waste (F006/F019 filter cake) is generated using well-proven equipment 

(Netzch filter press). The filter cake has a consistent physical appearance. 

The conclusion is that the wastewater treatment process will generate a Petitioned Waste 

(F006/F019) with little variability.

13. Contribution of Waste Treatment Process to Petitioned Waste

The Petitioned Waste (F006/F019 filter cake) is generated from the treatment of plant 

wastewater at the WWTP. The plant wastewater contains treated wastewater from an 

electroplating line (F006 source). The electroplating line includes a small amount of 

rinse water from a wash line where large cotton pickers containing a small quantity 

of aluminum parts may be subject to chemical conversion coating (F019 listed source). 
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CONTRIBUTING WASTE TREATMENT PROCESSES

14. Description of Waste Treatment Processes Contributing to the Petitioned Waste 

The Petitioned Waste (F006/F019 filter cake) is generated from the treatment of

wastewater generated from the chrome electroplating process line (Building 2,

Department 39) and aluminum chemical conversion coating (Building 2, Department 19). 

The actual Petitioned Waste is a filter cake from the dewatering of the sludge solids

generated from treatment of all industrial wastewater generated at the manufacturing 

facility. For information, the typical/ average flows are: 

Hexavalent Chrome Reduction Unit (treated wastewater from the Chrome

Electroplating process) = 15,000 gpd 

Total industrial wastewater = 106,000 gpd 

The treatment processes were described in Section C.4. 

15. Description of Location of Petitioned Waste Generation

The Petitioned Waste (F006/F019 filter cake) is generated in Building 16 which contains 

the Wastewater Treatment Plant (WWTP). The Netzch filter press is located in a 

separate bay inside the building with the unit on an elevated platform with an adjacent 

walkway for operator observation. Underneath the filter press is a movable roll-off 

container into which the filter cake is dropped at the completion of the treatment cycle. 

A cake breaker is used to distribute the cake through the container. The full container is 

pulled from the building by the waste hauler. A tarp cover is placed over the material 

and the material is transported to a RCRA Subtitle C facility. The waste hauler places an 

empty container under the filter press to complete the process

16. Description of Waste Inputs and Outputs

The wastewater sources were described in Section C.3. The chemicals used in the WWTP

consist of the common chemical categories (Petition Appendix N includes the SAP with

WWTP chemicals listed in the SAP Table 1.2): 

Sulfuric acid and caustic – for pH adjustment
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Coagulants (polyelectrolyte) – for solids coagulation and settling 

Sodium bisulfite – available for use if hexavalent chrome is detected in the

WWTF feed tank

Defoamer – available for use in T-1 holding tank

The waste product includes: 

Treated wastewater – discharged to the WRA (via the Ankeny public sewer)

Filter Cake – the Petitioned Waste (F006/F019 Filter Cake) 

17. Description of Non-Process Wastes Entering the Waste Treatment Process

There are no non-process wastes which are discharged to the WWTP. The sanitary 

wastewater generated at the plant is discharged directly to the municipal sanitary sewer. 

18. Description of Process Equipment

The list and description of WWTP equipment was furnished in section C.4. 

19. Description of Facility Operating Cycles

The overall facility operates continuously with planned shutdowns for overall 

plant maintenance about once per year. 

The electroplating unit can operate up to 24 hours per day, 7 days per 

week.

The wash lines operate continuously 

The WWTP operates continuously with normal discharge for 2 shifts per day.

Dewatering typically is for two cycles in an operating day with 1 to 2 operating 

days required for each calendar week.

20. History and Potential for Operational or Waste Variability Due to Treatment

Processes

The WWTP is described in Section C.4. The WWTP has consistently met permit limits. 

The WWTP average flow is 106,000 gpd with the system including a large equalization 

tank (operating volume ranges 130,000 to 330,000 gallons; maximum capacity 460,000 

gallons). The treatment process uses well-established physical-chemical treatment 

operations with a conservative (low) hydraulic loading. The sludge generated from the 

treatment is accumulated in a sludge thickener prior to dewatering. The total retention 
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times indicate a stable sludge generation rate with limited variability.

21. Description of Potential for Waste Variability with Manufacturing Variability 

The manufacturing activity is addressed in Section C.11. The facility operates with

essentially the same manufacturing operations and production rates on a 365 day/year 

and 24hr/day schedule. 

22. Management of Petitioned Waste in a Land-Based Unit

The Petitioned Waste has never been managed in an on-site land-based unit. All 

F006/F019 filter cake was sent for off-site disposal to commercial RCRA Subtitle C 

facilities as listed in Section B.6. 
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WASTE MANAGEMENT OPERATIONS

23-24. Waste Management Operations

Not applicable. The Petitioned Waste has never been managed in a land-based unit. All 

Petitioned Waste (F006/F019 Filter Cake) has been transported to off-site RCRA facilities.

PROCESS MATERIALS

25. List of Materials Contributing to the Petitioned Waste

Petition Appendix N includes the Sampling and Analysis Plan for Delisting of F006 and 

F019 Sludge Filter Cake. The SAP Appendix Table 1 has a list of materials which could 

contribute to the F006 and F019 filter cake, the process in which they are used, and their 

function in the process. 

26. List of Material Safety Data Sheets

Petition Appendix N includes the Sampling and Analysis Plan for Delisting of 

F006/F019 filter cake. The SAP Appendix A includes copies of the Material Safety Data 

Sheets (MSDS) for the materials listed in the appendix. 

27. Description of Oils, Greases, and Hydraulic Fluids Which Enter the Process 

There is the potential for minor amounts of oils, greases, and hydraulic fluids to enter 

the plant wastewater as discussed below: 

Building 28 Department 1 Wash Booth – this area is approximately 50 feet by 13 

feet; this area does not clean oily parts

Building 2, Department 19 E-Coat System – this is a multi-stage paint line;

wastewater is generated from several wash stages embedded in the line; the line 

removes tramp oil on steel parts before painting 
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Building 2, Department 20C Manual Wand Wash System – this is a bay to 

remove dust and tramp oils from assembled products before final touch-up 

painting. This unit is being removed in early 2014.

Building 2, Department 39 Chrome Electroplating – this includes two complete 

multi-stage plating systems; the line does not clean oily parts

Building 3, Department 20A Wash Pretreatment – this is a 5 stage wash system 

prior to painting of parts; the line does not clean oily parts; tramp oil on steel 

parts is possible

Building 3, Department 38 Heat Treatment – While the furnace water is used as 

non-contact cooling, the wash unit directly after the heat treatment process 

removes tramp oils before the tempering process.

Building 14, Department 55 Garage Wash Area – this is a small wash bay for

cleaning equipment such as site vehicles and other small site miscellaneous wash 

off needs; there is the potential for trace amounts of oil in this wastewater from 

lubricants on the agricultural equipment 

Storm drains (several locations) – there are 3 locations where outside activities that 

can generate wastewater are drained to the facility WWT; there is the potential for

trace amounts of oil from these areas 
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SPECIAL INFORMATION

28. Request for Upfront Exclusion of Waste to be Generated

John Deere is not requesting an upfront exclusion for a waste that is not currently 

generated. The F006 and F019 filter cake is currently generated and will continue to be 

generated in the future. Therefore, John Deere requests that EPA consider its petition for 

a standard exclusion. 

29-31. Information on Bench-Scale or Pilot Scale Waste Characterization

Not applicable. 

32. Request for Exclusion for Waste from Multiple Waste Treatment Facility

John Deere is not requesting an exemption for a waste generated by a multiple waste 

treatment facility.

33-34. Information on Procedures at Multiple Waste Treatment Facilities

Not applicable.
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PART D: ANALYTICAL PLAN DEVELOPMENT 

1. Complete List of Constituents of Concern for the Petitioned Waste

The approach for developing the Constituent of Concern list is fully described in the 

Sampling and Analysis Plan (SAP) for Delisting of F006 and F019 Sludge Filter Cake, 

January 2012, revised June 2012. The SAP is included in Appendix N of this Petition. 

The testing included an initial sample that was analyzed for a full-range of constituents 

consistent with the nature of manufacturing operations. The results of that initial 

sample and process knowledge were used to focus on a selected constituent of concern 

list. The approach is described below. 

Constituents for Initial Sample 

The approach was to first include all required parameters for an initial testing of the 

filter cake (Petitioned Waste). That list was prepared as summarized below: 

Identify the constituents of concern for which the waste was originally listed:

o F006 , cadmium, hexavalent chromium, nickel and cyanide (complexed); 

o F019 – hexavalent chrome and cyanide (complexed). 

Add constituents required by EPA in 40 CFR 260.22 (d) and the constituents 

recommended in the March 1996 EPA guidance document entitled “Region 6

RCRA Delisting Program Guidance Manual for the Petitioner.”

o 40 CFR 261, Appendix VIII

o Six constituents not found in Appendix VIII: acetone, ethylbenzene, 

isophorone, 4-methyl-2-pentanone, styrene, and total xylenes

o It was determined that isophorone and 4-methyl-2-pentanone would 

not reasonably be expected to be present in the filter cake, so these 

constituents were not included with the initial list (see discussions 

Petition Section D.4) 
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Include Total Toxic Organic (TTO) constituents regulated by EPA under 40 CFR

433, the Metal Finishing Point Source Category,

o Pesticides, 

o Polychlorinated biphenyls (PCBs) 

o It was determined that 2,3,7,8-TCDD (dioxin) would not reasonably be 

expected to be present in the filter cake, so these constituent was not 

included with the initial list (see discussions Petition Section D.4) 

Review Material Safety Data Sheets (MSDS) for the major chemicals used at the 

facility that could potentially appear in the F006 and F019 filter cake

The Analysis of an initial sample included the complete list of constituents as described 

above (Petition Appendix N includes the list in the SAP Table 2). The complete list of

constituents was used for the initial sample event performed July 20, 2011. 

Constituents to Complete Testing 

The results of the initial sample event were presented to EPA in a letter dated September

8, 2011 and approved by EPA. (Petition Appendix A includes these letters). The selected 

constituents included:

Filter cake will be analyzed for total and extract concentrations of the following 

metals: barium, chromium, copper, lead, mercury, nickel, zinc, and vanadium.

Filter cake will be analyzed for Total Cyanide and Total Hexavalent chromium 

because of their detection in the initial sample. 

Filter cake will be analyzed for the RCRA hazardous waste characteristics of

ignitability, corrosivity, and reactivity.

Filter cake will be analyzed for oil and grease. 

Filter cake will be analyzed for the total concentration of the volatile organic 

chemicals noted in the initial sample: acetone, 2-butanone 
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Evaluation of Oily Waste 

The Sampling and Analysis Plan required testing a sample for the Mobile Metal Content, 

using the Extraction Procedure for Oily Wastes, Method 1330, if the results for Oil and 

Grease exceeded 1%. The sample with the highest Oil and Grease was selected for testing 

by this method.

2. Mass Balance Demonstration for Constituents of Concern for Which Analyses

Were Not Conducted

Not applicable.

3. Rationale for Exclusion of Constituents from the List of Constituents of Concern

Addressed in Petition Section D.1 

4. Explanation of Why Petitioned Waste Does Not Exhibit Any Hazardous Waste 

Characteristic for Which Analyses Were Not Conducted

Hazardous waste characteristic analysis was performed on all samples taken at the plant 

for the purposes of this delisting petition. 
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PART E: SAMPLING AND ANALYSIS INFORMATION 

1. Submittal of Draft Sampling and Analysis Plan to EPA

The Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP) were 

prepared pursuant to discussions held January 27, 2011, between representatives of John 

Deere and the United States Environmental Protection Agency (EPA) Region 7. The SAP 

and QAPP were prepared in accordance with the EPA RCRA Delisting Program 

Guidance Manual for the Petitioner dated March 23, 2000. The SAP and QAPP were 

approved by EPA July 7, 2011 (Petition Appendix A). 

The initial sample event to confirm constituents of concern was completed July 20, 2011. 

After reviewing data from the event and after discussions with EPA, the SAP was 

updated with selected Constituents of Concern and samples (Revised January 2012). The 

Quality Assurance Project Plan (March 2011) also was approved and updated (Revised 

January 2012). 

In early 2012, it was determined that a small quantity of aluminum parts had gone 

through the chemical conversion process and that the wastewater generated from this 

operation was a small fraction of the wastewater discharged into the treatment facility.

The sludge generated from treatment of this wastewater may be a listed F019 hazardous 

waste. After discussions with EPA, the SAP and QAPP (as revised January 2012) were 

further updated to specifically add F019 to the discussions and submitted to EPA for

approval (Revised June 2012). 

The Sampling and Analysis Plan (Revised June 2012) and Quality Assurance Project 

Plan (Revised June 2012) prepared for the sampling events have been included with this 

delisting petition in Appendix N and Appendix O, respectively. 
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WASTE SAMPLING INFORMATION

2. Waste Sampling Information

The Sampling and Analysis Plan was prepared by: 

Project Integration LLC

1907 Highway 101 South 

Suite D16 

Greer, SC 29561 

The samples were collected by representatives of MWH Consulting:

MWH Americas, Inc. 

11153 Aurora Avenue 

Des Moines, IA 50322-7904 

Office: 515-253-0830 

Fax: 515-253-9592 

The samples were shipped by overnight courier to the laboratory:

Test America Laboratories, Inc. 

Test America Chicago

2417 Bond Street 

University Park, IL 60484 

Tel: (708)534-5200 

A listing of the key personnel performing work is included in Petition Appendix K. 
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SAMPLING STRATEGY

3. Sampling Program

The sampling strategy is described below. Note that the overall approach included

collection and analysis of an Initial Filter Cake sample (July 2011) for all Appendix VIII

and IX constituents identified and wait for results prior to embarking on the remainder

of the testing. After the results were obtained, John Deere confirmed the sampling

protocol (number of additional samples and Final Constituents of Concern) for the

remainder of the project and reviewed the protocol with EPA to verify approval. Then

the Petitioned Waste (F006/F019 filter cake) was characterized using 6 additional sample

events each analyzed for the Final Constituents of Concern listing. The field notes for

this testing are included in Petition Appendix B.

3a. Sample Locations (Waste Description)

The Petitioned Waste (F006/F019 filter cake) is a dewatered filter cake generated from the

wastewater treatment plant filter press. The John Deere WWTP (a pretreatment plant

discharging to the local wastewater plant) treats wastewater associated with an

electroplating process. The resultant sludge drops from the single filter press into a 25

cubic yard roll-off container. The filter cake is a reddish-brown solid (approximately

30% solids) and has a density of approximately 80 to 85 pounds per cubic foot. The filter

cake contains detectable concentrations of certain metals with fairly low oil content. 

3b. Sampling Techniques

John Deere confirmed prior to the initial sample collection that operation was typical for

the facility regarding processes, products and raw materials. Due to the uniformity of

the process and the consistency of the wastewater discharge, temporal (time) variability

of the waste filter cake is not a concern. Therefore the approach for collecting each event

was to collect the sample from the roll-off container sample after the dewatering cycle 
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and filter cake drop. The sample was prepared by collecting three individual aliquots

and then preparing a composite sample, except for the volatile constituent test which

was a discrete sample. 

3c. Sample Collection and Transfer Procedures

All samples were collected with a clean sample spoon that was wiped clean of gross

solids between aliquots. The sample aliquots were placed in a clean stainless steel bowl

and mixed to form a composite sample, and a sample of this composite placed in clean,

laboratory-supplied sample containers. The sample for VOC analysis was collected

from approximately the center of the roll-off with a clean sample spoon and placed

immediately into a clean, laboratory-supplied glass VOC sample jar. 

Sample aliquots were collected from three locations within the roll-off container and

transferred to a stainless steel mixing bowl. The bowl and sample collection were

cleaned prior to and between each sample event using a solution of Aloconox detergent

and distilled water, followed by a triple rinse with distilled water. To minimize the

potential for sample contamination, clean latex sampling gloves were worn during all

sample handling procedures, and only clean, laboratory-supplied sample containers

were used for all samples. A sample of a blank chain-of-custody and sample label is

described in the Quality Assurance Project Plan (included as Petition Appendix O). 

The sample containers were sealed, labeled and placed on ice in a sample cooler for

shipment to the analytical laboratory under strict chain-of-custody procedures. The

sample cooler was shipped to the laboratory for next-day delivery. 

The quality assurance methods included an equipment blank and trip blank for each

sample event. The equipment blank was prepared in the field by pouring laboratory

furnished Deionized Water into the clean bowl and spoon with a sample of this water

poured into the container for transport to the laboratory. The trip blank was prepared in 
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the laboratory and accompanied the sample containers. Duplicate samples

were obtained for two sample events. 

The work in December 2012 included collecting sample and two duplicates for

six events as follows: 

Event Day of

Week

Date Sample

Number

Type Description

Initial Friday 7-20-2011 36909 Grab

FC #1 Monday 12-3-2012 52882 Grab

Duplicate 

New; 1st Dropped Load

FC #2 Tuesday 12-4-2012 53034 Grab 3rd Dropped Load

FC #3 Monday 12-10-2012 53120 Grab 5th Dropped Load

FC #4 Friday 12-14-2012 53315 Grab

Duplicate 

10th Dropped Load

FC #5 Monday 12-17-2012 53342 Grab New; 1st Dropped Load

FC #6 Wednesday 12-19-2012 53491 Grab 2nd Dropped Load

The field notes for the December 2012 samples are included in Petition Appendix B.

3d. Sampling Devices

A stainless steel spoon was used to collect the sample. This approach was

appropriate since the solid waste was freshly dropped for each sample event and

was a thin layer of material on top of the roll-off container surface.

3e. Deviations from Sampling Plan and Strategy

There were no deviations from the sample plan or strategy. Additional oil and grease

testing was performed, as per the sampling plan.
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3f. Basis for Samples to be Considered Representative 

The selected sampling point is the roll-off container immediately after a filter cake drop

from the press. This represents freshly generated waste and is a safe, efficient way to

collect a representative sample. The WWTP treats and discharges approximately

106,000 gallons of wastewater per day. All raw wastewater is combined in one

equalization basin with 1.5 to 3 day detention time. Typical filter press operation is two

filter press cycles for one or two operating days each calendar week. The roll-off can

hold numerous filter cake drops and is typically filled in two to three weeks.

The sample approach included a fresh sludge batch for each sample event. The sample

was prepared using three aliquots (except for VOC testing) which minimizes the impact

of slight differences within the filter press sludge. 

The collection included two samples per week for 3 weeks. The day of week was varied

to include consecutive days and separate days. This provides comparison of results for

short-term (next day) variability as well as longer term (week 1 to week 3) results. 

Finally, the sampling was performed by an independent consultant with support from

John Deere persons familiar with the treatment process. Therefore the six samples are

considered representative of typical operation. 
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SAMPLE SPECIFIC INFORMATION

4. Number of Samples of Petitioned Waste Collected

The sampling strategy for the Petitioned Waste (F006/F019 filter cake) was to collect an

initial composite sample, prepared from three separate aliquots. This was completed

July 20, 2011, consistent with the Sampling and Analysis Plan. 

The strategy for continued testing for the Petitioned Waste (F006/F019 filter cake) was to

collect six (6) samples and test each of these for the final Constituents of Interest (COI)

confirmed from the Initial Sample. The sampling was completed according to this plan. 

5. Individual Sample Information

Field notes are furnished for each sample collected in December 2012 in Petition 

Appendix B.

a. Sample Information

All samples were collected from the roll off container underneath the sludge filter press. 

b. Description of Sample Collection

All samples were collected following similar methods as described previously.

Step 1. Assemble sample containers, sample equipment, custody and seal forms, and

shipping container

Step 2. Collect the equipment blank using laboratory furnished deionized water to

wash the sample bowl and sample spoon

Step 3. Collect filter cake sample for VOC analysis: collect sample from center of

roll-off container; place in stainless steel bowl; break up into pieces that fit

into the VOC sample container; fill completely; seal container. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 39 of 50

Step 4. Collect filter cake sample composite: divide the roll-off container into three

equal parts; collect aliquots from the approximate center of the three parts;

place aliquots into stainless steel bowl; mix ; place mixed sample into sample

containers; seal containers 

c. Description of Sampling Locations

Samples were all collected from the roll-off container. The container was divided into

thirds and the sample aliquots collected from the approximate center of the third for the

composite sample. The VOC sample was collected from the approximate center of the

roll-off container. 

d. Description of Compositing Method

The F006 filter cake samples were composited as follows: 

1. The sample material from the three locations were placed into a clean stainless

steel bowl and mixed to form a composite sample. 

2. The composite sample was placed in clean, laboratory supplied glassware and

then sealed, labeled on ice in a cooler for shipment to the laboratory under chainof-custody.

The sample for VOC analysis was collected as a grab sample from the center of the rolloff container. 

e. Physical Description of Sample at time of Collection

The filter cake was described as follows: 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 40 of 50

Identification Sampling Date Sample Description

Initial Sample

Filter Cake

July 20, 2011

Filter Cake #1 December 3, 2012 Solid clayey texture, med. Soft to hard;

Gray, slight septic odor, uniform color

Filter Cake #2 December 6, 2012 Solid clayey texture, med. Soft to hard;

Gray, slight septic odor, uniform color

Filter Cake #3 December 10, 2012 Solid clayey texture;

Gray, slight septic odor

Filter Cake #4 December 14, 2012 Sludge

Filter Cake #5 December 17, 2012 Solid clayey filter cake;

Gray, slight septic odor

Filter Cake #6 December 19, 2012 Solid clayey texture, med. Soft to hard;

Gray, slight septic odor

f. Time and Date of Grab and Composite Sample Collection

Identification Sampling Date Sample

Time

Filter Press Sample

Number

Initial Sample

Filter Cake

July 20, 2011 1415 - 1520 36909

Filter Cake #1 December 3, 2012 1350 – 1415 New box/ 1st drop 52882

Filter Cake #2 December 6, 2012 1415 – 1430 3rd drop 53034

Filter Cake #3 December 10, 2012 1410 – 1420 5th drop 53120

Filter Cake #4 December 14, 2012 10th drop 53315

Filter Cake #5 December 17, 2012 1430 – 1450 New box/ 1st drop 53342

Filter Cake #6 December 19, 2012 1410 - 1445 2nd drop 53491

g. Handling and Preparation Techniques

The following handling and preparation techniques were used for each sample: The

composited filter cake sample was placed into laboratory supplied containers. After

sampling, all sample containers were immediately placed in an ice chest and iced

down. 

The sample containers were pre-labeled with all information. The sampler filled out a

sampling log with the following information: 

• The sample ID number. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 41 of 50

• The date and time that each of the grab samples were taken.

• The date and time of completion of the composite sample. 

• Any decontamination procedures and when new sampling equipment was

used.

• The physical description of the sample at the time of collection. For example,

its color, odor 

• Any deviations from the sampling plan or strategy.

Custody seals were placed across the top of each sample container and across the

front and back of the ice chest lids.

Chain-of-custody control forms were initiated by the person responsible for

obtaining each sample. The custody control form was transferred to and signed by

each responsible party taking possession of the sample. 

The ice chests were shipped to the laboratory via overnight courier. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 42 of 50

OTHER GENERAL INFORMATION

6. Description of Weather Conditions During Sampling

All process and water treatment activities occur inside enclosed buildings, as did the

sample collection activities. Therefore, weather conditions do not play a role in sample

representativeness at this plant. 

7. Ongoing Facility Activities That May Have Affected Sample

Representativeness

There were no ongoing facility activities that would have affected sample

representativeness during the sample collection December 2012. The WWTP operation

was normal and there were no unusual wastewater discharges into the plant sewer. 

8. Description of Sampling Device Decontamination

All sampling equipment was thoroughly decontaminated prior to being brought to the

site using the following procedure: an Alconox wash, followed by tap water rinse,

followed by three (3) rinses with deionized water. 

Upon completion of the sampling, the sampling equipment was

cleaned/decontaminated, triple rinsed with distilled water, and wrapped.

9. Chain-of-Custody Procedures

Chain-of-custody control documentation was maintained for each sample. Custody

control forms were initiated by the person responsible for obtaining each sample. The

custody control form was transferred to and signed by each responsible party taking

possession of the sample. The complete chain-of-custody records for all sample events

are included in the Data Packages in Petition Appendices D-J.
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 43 of 50

10. Description of Quality Control Procedures During Transportation to the

Laboratory

Following sample collection, the filled and labeled sample container was placed in the

sample shipping container with sufficient packing material and wet ice to insure arrival

at the laboratory cool (40 C) and intact. A sealed plastic bag containing two (2) copies of

the completed chain-of-custody form was taped to the inside lid of the shipping

container. Two custody seals, signed and dated by the sampler, were secured to the top

of the shipping container in such a manner that the seals would be broken upon opening

of the container. A copy of the chain of custody forms is included with the Analytical

Report packages (Appendices). 

LOCALIZED AREA OF CONTAMINATION

11. Sample Collection to Determine the Presence of a Localized Area of

Contamination

Based on plant operating cycles and WWTP operating cycles, including the frequency of

F006 filter cake generation and disposal, there was no knowledge of localized areas of

contamination. 

12-15. Information on Characterizing Hot Spots

Not applicable. See Item 11 above. 

MULTIPLE WASTE TREATMENT FACILITY

16. Samples for Characterization of Waste from a Multiple Waste Treatment

Facility

The F006/F019 filter cake is not generated by a multiple waste treatment facility.

17-20. Information on Waste from Multiple Waste Treatment Facility

Not Applicable. See Item 11 above. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 44 of 50

WASTE ANALYSIS INFORMATION

21. Identification of Sample Analyses Staff

a. Name and Address of Laboratory Performing Analyses 

Laboratory analysis was performed by a commercial laboratory:

Test America Laboratories, Inc.

Test America Chicago

2417 Bond Street

University Park, IL 60484 

Tel: (708)534-5200 

b. Resumes of Laboratory Analysts

The resumes of key laboratory analysts are found in Petition Appendix L.

22. Laboratory Data Reporting Forms

The laboratory data reporting forms, including all analyses and Quality Control analyses

can be found in Petition Appendices D-J. 

23. Sample and Analysis Information

The analytical results for all of the nine cake samples are summarized in several tables

included in the Petition (data reports are in Appendices D-J). 

Table 1 All Filter Cake Sample Analytic Results for COI

Tables 2 – 8 Individual Filter Cake Results for COI including Blanks and Narrative 

Sample and analysis information for each sample can be found in Appendices D-J. This

includes the following information: 

(a) Laboratory Sample ID Numbers 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 45 of 50

(b) Type of Sample 

(c) Date of Sample Receipt of Laboratory 

(d) Sample Preparation Method and Reference 

(e) Date of Sample Preparation

(f) Name of Analyst

(g) Date of Extraction and Analysis

(h) Test Method Used and Reference

(i) Constituent Analyzed 

(j) Test Results

(k) Basis for Analysis 

(l) Quantitation Limits 

24. Names and Model Numbers of Analytical Equipment

An identification number (code) assigned to each instrument utilized for analyses is

listed on the Level 3 Analytical Report furnished by Test America (in Appendices DJ). The detailed laboratory QA Manual includes information on laboratory 

equipment in Petition Appendix L.

25. Other Information Necessary to Interpret Data

Equipment blanks and trip blanks were prepared and submitted with each sampling

event. In addition, a duplicate sample (field split) was collected with four sample events

(Filter Cake #1 December 3, 2012 and Filter Cake #4 December 14, 2012). 

Each Laboratory report includes a Case Narrative which identifies quality assurance

issues with the data reported in that report. The Case Narratives are included with the

data in Tables 2 – 7 for the individual filter cake analyses and discussed with the data

interpretation. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 46 of 50

26. Information on Matrix or Surrogate Spike and Spike Duplicate Analysis

Quality Assurance (QA) Summary Reports for each filter cake sample are included with

the Level 2 Analytic Data Packages included in Petition Appendices D-J. The detailed

QA Reports are available (CD format) in the Level 3 Analytic Data Packages include the

following:

(a) Name of Spike Analyte Added

(b) Concentration of Spike Analyte in Unspiked Sample 

(c) Amount of Spike Analyte Added 

(d) Measured Amount of Spike in Both Spike Samples

(e) Calculated Percent Recovery of Spike 

(f) Acceptance criterion for recovery of each matrix spike

(g) Relative percent difference (RPD) between duplicate results 

(h) Acceptance criterion for the RPD 

The QA objectives are determined by the laboratory and are described in the Test

America Quality Assurance Manual (approximately 240 pages; furnished on CD). 

Each Laboratory report includes a Case Narrative which identifies quality assurance

issues with the MS/MSD results for the test batches associated with the data reported in

that report. The Case Narratives are included with the data in Tables 2 – 7 for the

individual filter cake analyses and discussed with the data interpretation. 

27. Correction of Analytical Data Based on Quality Control Results

Analytical data have not been corrected based on any quality control results. 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 47 of 50

28. Explanation of Inconsistencies or Deviations found in Reported Analytical 

Results

The laboratory reports include a Case Narrative for each sample that describes any

nonconforming test results. The Case Narratives are listed in Table 8 with an evaluation

of impact on the testing results. The conclusion is that the laboratory QA/QC is 

adequate for the use of these data. 

The actual results were found to be generally consistent between samples. The Table 1

lists ‘maximum’ detected levels for the constituents of interest and it was found that

these demonstrate a reasonable range of maximum to typical values. A statistical

evaluation for the results was not performed.

The variations in results that are considered sufficiently significant for further discussion

include the following:

Nickel – total nickel in filter cake ranged from 70.2 to 89.8 mg/kg for the December

2012 samples (6 results); however, the Initial Sample in July 2011 was reported at

1010 mg/kg; the Case Narrative for the Initial Sample reported the need for high

dilution of the sample due to Yttrium; this could have increased the sensitivity of

any nickel detection in the sample; the extracted nickel for the Initial Sample was

typical for the other filter cake samples 

CONCLUSION: the Initial Sample result is an outlier and does not affect the 

conclusions from the testing

Zinc – total zinc in filter cake ranged from 346 to 501 mg/kg for the December 2012

samples (6 results); however, the Initial Sample in July 2011 was reported at 3390

mg/kg; the Case Narrative for the Initial Sample reported the need for high

dilution of the sample due to Yttrium; this could have increased the sensitivity of

any zinc detection in the sample; the extracted zinc for the Initial Sample was

typical for the other filter cake samples
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 48 of 50

CONCLUSION: the Initial Sample result is an outlier and does not affect the 

conclusions from the testing 

The conclusion from this review of variability is that the Petitioned Waste (F006/F019 filter

cake) does not contain hazardous constituents that would make the materials a 

Hazardous Waste.

29. Calculations for Oily Waste Testing

The initial sample Oil and Grease was < 1% (6,920 mg/kg) but the range for the

subsequent samples did exceed 1% (8,910 to 21,500 mg/kg) which initiated the

requirement to test one sample for the Oily Waste test. As noted in the January 22, 2013

letter to EPA the FC2 sample was selected as the sample to be tested because it had the

highest Oil and Grease result. 

The Oily Waste test was required to determine if metal levels as measured by the Toxic

Characteristic Leaching Procedure (TCLP) may be under-reporting actual metal

mobility, for example, with oil. The test evaluated the sample with two additional

extractions: Tetrahydrofuran (THF) and Toluene (T) extractions, with metal in the three

extracts added to get the potential for Mobile Metal Concentration (MMC). 

The results showed slightly elevated concentrations in THF extract for Chromium,

Copper, Nickel, and Lead but not at low concentrations. These results are included in

Petition Appendix C.

The conclusion is that metal mobility is not affected by Oil and Grease levels found in 

the filter cake samples 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 49 of 50

Part F: GROUND-WATER MONITORING INFORMATION 

1. Management of Petitioned Waste in A Land-Based Unit

Indicate which of the following describes the management of the Petitioned Waste. 

a. The Petitioned Waste is currently managed in a land-based waste management unit 

(on-site or off-site), and ground-water monitoring is required pursuant to 40 CFR Part 

264, or 265 or authorized state equivalent, or other Federal, state, or local

requirements; or if ground-water monitoring information is otherwise available for the

unit. (If yes, go to Item F.2.) 

No.

b. The Petitioned Waste was once managed (but is no longer) in a land-based waste

management unit (on-site or off-site) and ground-water monitoring was required

pursuant to 40 CFR Part 264, or 265 or authorized state equivalent, or other Federal,

state, or local requirements; or if ground-water monitoring information is otherwise

available for the unit. (If yes, go to Item F.2.) 

No. 

1.1 The Petitioned Waste is currently managed, or was once managed, in a landbased waste management unit, but ground-water monitoring requirement has

been viewed. (If yes, go to Item F.9.) 

No.

1.2 The Petitioned Waste is currently managed, or was once managed, in one or

more land-based waste management units containing also significant amounts

of other wastes, and you consider ground-water data from these nondedicated units are immaterial in evaluation the Petitioned Waste’s impact on

ground-water quality. (If yes, go to Item F.10) 
Delisting Petition JD Ankeny Draft 8-26-2013.docxPage 50 of 50

No. 

1.3 None of the above management scenarios apply. (If yes, go to Item F.11.) 

No, they do not apply.

2-9. Information on Groundwater Monitoring

Not applicable. See Petition Section F.1. 

10. Description of Other Disposal Units Used and Waste Characterization

John Deere has disposed the Petitioned Waste (F006 filter cake) for off-site disposal at: 

Peoria Disposal Company 

PDC # 1 Landfill

4349 Southport Road

Peoria, IL 61615

ILD000805812

The plan is to dispose the filter cake after it is delisted at: 

Metro Park East Landfill 

12181 University Avenue, NE

Mitchellville, IA 50169

515-967-2076

The anticipated disposal rate will be 700,000 lbs/year (29.2 ton/month) or 

approximately 350 ton/year. 

11. Description of Why Groundwater Monitoring is not Required.

Not applicable. See Item F.1. above.
TABLES
John Deere Des Moines Works

Ankeny IA

Table 1 Summary of Filter Cake Testing Results 

for Each Constituent of Interest

Delisting Petition fror

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 1 All Results

Sample ID FC 1 FC 1 FC 2 FC 3 FC 4 FC 4 FC 5 FC 6 FC 6 Initial FC

Duplicate DUPLICATE DUPLICATE pH 10.03

LAB Sample ID 52882-1 52882-3 53034-1 53120-1 53315-1 53315-2 53342-1 53491-1 53491-2 36909-1,2

Date Sampled Maximum 12/3/2012 12/3/2012 12/6/2012 12/10/2012 12/14/2012 12/14/2012 12/17/2012 12/19/2012 12/19/2012 7/20/2011

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 643 350 368 377 385 346 326 409 643 619 322

COPPER mg/Kg 959 814 809 959 958 834 784 693 748 707 278

CHROMIUM mg/Kg 15000 8710 9210 9290 10300 14400 13200 14200 15000 15000 9430

NICKEL mg/Kg 1010 70.2 71.6 78.7 88.6 89.8 86.4 77.4 85.5 86.1 1010

LEAD mg/Kg 291 228 222 261 291 209 188 250 253 244 165

VANADIUM mg/Kg 253 147 156 158 174 241 221 238 253 251 24.8

ZINC mg/Kg 3390 346 359 381 457 481 451 441 501 499 3390

Metals: TCLP (ICP) Units

BARIUM mg/L <0.500 0.0141 0.0272 < 0.500 < 0.500 0.0194 <0.500 < 0.500 0.0103 <0.500 <0.500

COPPER mg/L 0.442 0.0172 0.0345 0.0355 0.0267 0.0487 0.0483 <0.0250 0.442 0.0547 0.0897

CHROMIUM mg/L 0.826 <0.0250 0.0685 0.0524 <0.0250 <0.0250 0.0120 0.166 0.826 <0.0250 0.0121

NICKEL mg/L 0.744 0.0547 0.59 0.646 0.0462 0.0549 0.0582 0.531 0.744 0.0624 0.103

LEAD mg/L <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500 <0.0500

VANADIUM mg/L <0.0250 <0.0250 0.00529 <0.0250 <0.0250 <0.0250 <0.0250 0.00669 0.0164 <0.0250 0.0171

ZINC mg/L 0.404 <0.100 0.148 0.0685 <0.100 <0.100 <0.100 0.0502 0.404 <0.100 <0.100

Mercury: TCLP (CVAA) Units

MERCURY mg/L <0.00020 0.00011 <0.0000200 0.0000559 0.0000664 <0.00020 <0.00020 <0.000200 0.000702 <0.00020 <0.00200

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.635 0.425 0.383 0.635 0.625 0.543 0.248 0.321 0.232 0.237 0.116

MERCURY mg/L

General Chemistry Units

FLASHPOINT Deg F >176 >176 >176 >176 >176 >176 >176 >176 >176 >176 >176

HEXAVALENT CHROMIUM mg/Kg 13.6 3.89 13.6 4.31 7.05 3.97 4.08 <3.33 <3.75 <3.99 6.88

CYANIDE (TOTAL) mg/Kg <2.04 1.92 0.816 <1.81 <2.04 0.745 0.765 0.905 1.15 1.29 0.613

SULFIDE mg/Kg 817 253 223 223 332 739 774 798 778 817 166

SULFIDE, REACTIVE mg/Kg <49.3 <49.1 <49.1 <48.6 <48.4 <48.6 <49.3 <48.7 <48.5 <49.3 <47.0

pH SU 9.52 9.61 9.02 9.51 9.50 9.58 9.59 9.79 9.87 9.35

HEM (OIL & GREASE) mg/Kg 21500 19500 12600 21500 13200 11100 8910 13200 16600 17000 6920

TOTAL SOLIDS % 26.4 25.9 27.0 24.0 26.0 26.0 30.0 26.0 25.0 27.1

HEM (OIL & GREASE) mg/L

HEXAVALENT CHROMIUM mg/L

CYANIDE mg/L

SULFIDE mg/L

SULFIDE, REACTIVE mg/L

% SOLIDS % 26.4 25.9 27.4 24.3 25.9 26.3 30.0 26.5 25.1 27.1

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 191 29.2 38.6 72.6 189 145 191 28.2 11.8 19.5 53.8

ACETONE ug/Kg 9130 3190 2390 9130 8630 4220 8710 3200 7020 7150 6670
John Deere Des Moines Works

Ankeny IA

Table 2 Filter Cake Sample Results for Each Constituent of Interest

Sample FC 1 12/3/2012

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 2 FC-1 3-Dec-2012

Sample ID FC Discrete 1 FC Discrete 1 FC TB 1

Duplicate Duplicate pH 2.88 pH 7.0 pH 13.0

LAB Sample ID 52882-1 52882-2 52882-3 52882-4 52882-5 52882-7 52882-6 52882-8 52882-9

Date Sampled 12/3/2012 12/3/2012 12/3/2012 12/3/2012 12/3/2012 12/3/2012 12/3/2012 12/3/2012 12/3/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 350 V 368

COPPER mg/Kg 814 V 809

CHROMIUM mg/Kg 8710 V 9210

NICKEL mg/Kg 70.2 V 71.6

LEAD mg/Kg 228BV 222 B

VANADIUM mg/Kg 147 V 156

ZINC mg/Kg 346 V 359

Metals: TCLP (ICP) Units

BARIUM mg/L 0.0141 J 0.0272 J 0.00087 J 0.0201 J <0.500 0.0154 J

COPPER mg/L 0.0172 J 0.0345 <0.0100 0.0274 0.0323 0.926

CHROMIUM mg/L <0.0250 0.0685 0.00589 J 0.0522 <0.0250 0.673

NICKEL mg/L 0.0547 0.59 <0.0100 0.543 <0.0250 0.0199 J

LEAD mg/L <0.0500 <0.0500 0.00166 J <0.0500 <0.0500 <0.0500

VANADIUM mg/L <0.0250 0.00529 J 0.00065 J <0.0250 <0.0250 0.0569

ZINC mg/L <0.100 0.148 0.00924 J 0.0636 J <0.100 <0.100

Mercury: TCLP (CVAA) Units

MERCURY mg/L 0.00011 J <0.0000200 <0.000200 0.0000854 0.00000506 JB

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.425 0.383

MERCURY mg/L

General Chemistry Units

FLASHPOINT Deg F >176 >176

HEXAVALENT CHROMIUM mg/Kg 3.89 13.6

CYANIDE (TOTAL) mg/Kg 1.92 0.816 J

SULFIDE mg/Kg 253 223

SULFIDE, REACTIVE mg/Kg <49.1 <49.1

pH SU 9.52 9.61

HEM (OIL & GREASE) mg/Kg 19500 12600

TOTAL SOLIDS % 26.4 25.9

HEM (OIL & GREASE) mg/L 1.53 J

HEXAVALENT CHROMIUM mg/L <0.0100

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 26.4 24.0 25.9 25.6

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 29.2 38.6 <5.00 <5.00

ACETONE ug/Kg 3190 2390 <5.00 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

V Serial dilution exceeds the control limits

FC Composite 1 FC Composite 1 FC EB 1 FC Composite 3 FC Composite 3 FC Composite 3
John Deere Des Moines Works

Ankeny IA

Table 3 Filter Cake Sample Results 

for Each Constituent of Interest

Sample FC 2 12/6/2012

Delisting Petition for

 F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 3 FC-2 6-Dec-2012

LAB Sample ID FC Discrete 2 FC TB 2 FC EB 2

LAB ID 53034-1 53034-2 53034-4 530343

Date Sampled 12/6/2012 12/6/2012 12/6/2012 12/6/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 377 B

COPPER mg/Kg 959

CHROMIUM mg/Kg 9290

NICKEL mg/Kg 78.7

LEAD mg/Kg 261 B

VANADIUM mg/Kg 158

ZINC mg/Kg 381

Metals: TCLP (ICP) Units

BARIUM mg/L < 0.500 <0.0100

COPPER mg/L 0.0355 <0.0100

CHROMIUM mg/L 0.0524 <0.0100

NICKEL mg/L 0.646 <0.0100

LEAD mg/L <0.0500 <0.00500

VANADIUM mg/L <0.0250 <0.00500

ZINC mg/L 0.0685 J <0.0200

Mercury: TCLP (CVAA) Units

MERCURY mg/L 0.0000559 JB

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.635

MERCURY mg/L <0.000200

General Chemistry Units

FLASHPOINT Deg F >176

HEXAVALENT CHROMIUM mg/Kg 4.31

CYANIDE (TOTAL) mg/Kg <1.81

SULFIDE mg/Kg 223

SULFIDE, REACTIVE mg/Kg <48.6

pH SU 9.02

HEM (OIL & GREASE) mg/Kg 21500

TOTAL SOLIDS % 27.0

HEM (OIL & GREASE) mg/L <5.35

HEXAVALENT CHROMIUM mg/L <0.0100

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 27.4 28.7

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 72.6 <5.00 <5.00

ACETONE ug/Kg 9130 <5.00 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

FC Composite 2
John Deere Des Moines Works

Ankeny IA

Table 4 Filter Cake Sample Results

 for Each Constituent of Interest

Sample FC 3 12/10/2012

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 4 FC-3 10-Dec-2012

LAB Sample ID FC Discrete 3 FC EB 3 FC TB 3

LAB ID 53120-1 53120-2 53120-3 53120-4

Date Sampled 12/10/2012 12/10/2012 12/10/2012 12/10/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 385

COPPER mg/Kg 958

CHROMIUM mg/Kg 10300 B

NICKEL mg/Kg 88.6

LEAD mg/Kg 291 B

VANADIUM mg/Kg 174

ZINC mg/Kg 457

Metals: TCLP (ICP) Units

BARIUM mg/L < 0.500 <0.0100

COPPER mg/L 0.0267 0.00131 J

CHROMIUM mg/L <0.0250 0.00231 J

NICKEL mg/L 0.0462 <0.0100

LEAD mg/L <0.0500 <0.00500

VANADIUM mg/L <0.0250 <0.00500

ZINC mg/L <0.100 <0.0200

Mercury: TCLP (CVAA) Units

MERCURY mg/L 0.0000664 JB

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.625

MERCURY mg/L <0.000200

General Chemistry Units

FLASHPOINT Deg F >176

HEXAVALENT CHROMIUM mg/Kg 7.05

CYANIDE (TOTAL) mg/Kg <2.04

SULFIDE mg/Kg 332

SULFIDE, REACTIVE mg/Kg <48.4

pH SU 9.51

HEM (OIL & GREASE) mg/Kg 13200

TOTAL SOLIDS % 24

HEM (OIL & GREASE) mg/L <5.24

HEXAVALENT CHROMIUM mg/L 0.0044 J

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 24.3 26.5

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 189 <5.00 <5.00

ACETONE ug/Kg 8630 16.9 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

FC Composite 3
John Deere Des Moines Works

Ankeny IA

Table 5 Filter Cake Sample Results

for Each Constituent of Interest

Sample FC 4 12/14/2012

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 5 FC-4 14-Dec-2012

LAB Sample ID FC Discrete 4 FC Discrete 4 FC EB 4 FC TB 4

DUPLICATE DUPLICATE

LAB ID 53315-1 53315-2 53315-3 53315-4 53315-6 53315-5

Date Sampled 12/14/2012 12/14/2012 12/14/2012 12/14/2012 12/14/2012 12/14/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 346 326

COPPER mg/Kg 834 784

CHROMIUM mg/Kg 14400 V 13200 V

NICKEL mg/Kg 89.8 V 86.4 V

LEAD mg/Kg 209BV 188 B

VANADIUM mg/Kg 241 V 221 V

ZINC mg/Kg 481 V 451 V

Metals: TCLP (ICP) Units

BARIUM mg/L 0.0194 J <0.500 0.00058 JB

COPPER mg/L 0.0487 0.0483 0.00303 J

CHROMIUM mg/L <0.0250 0.0120 JB 0.00312 JB

NICKEL mg/L 0.0549 0.0582 <0.0100

LEAD mg/L <0.0500 <0.0500 0.00214 LB

VANADIUM mg/L <0.0250 <0.0250 <0.00500

ZINC mg/L <0.100 <0.100 0.00724 L

Mercury: TCLP (CVAA) Units

MERCURY mg/L <0.00020 JB <0.00020 JB

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.543 0.248

MERCURY mg/L 0.000102 J

General Chemistry Units

FLASHPOINT Deg F >176 >176

HEXAVALENT CHROMIUM mg/Kg 3.97 4.08

CYANIDE (TOTAL) mg/Kg 0.745 JB 0.765 JB

SULFIDE mg/Kg 739 774

SULFIDE, REACTIVE mg/Kg <48.6 <49.3

pH SU 9.50 9.58

HEM (OIL & GREASE) mg/Kg 11100 8910

TOTAL SOLIDS % 26.0 26.0

HEM (OIL & GREASE) mg/L <5.20

HEXAVALENT CHROMIUM mg/L <0.0100

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 25.9 26.3 28.9 28.2

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 145 191 <5.00 <5.00

ACETONE ug/Kg 4220 8710 13.0 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

V Serial Dilution exceeds the control limits

FC Composite 4 FC Composite 4
John Deere Des Moines Works

Ankeny IA

Table 6 Filter Cake Sample Results

for Each Constituent of Interest

FC 5 12/17/2012

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 6 FC-5 17-Dec-2012

LAB Sample ID FC Discrete 5 FC EB 5 FC TB 5

LAB ID 53342-1 53342-2 53342-3 53342-4

Date Sampled 12/17/2012 12/17/2012 12/17/2012 12/17/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 409

COPPER mg/Kg 693

CHROMIUM mg/Kg 14200

NICKEL mg/Kg 77.4 B

LEAD mg/Kg 250 B

VANADIUM mg/Kg 238

ZINC mg/Kg 441

Metals: TCLP (ICP) Units

BARIUM mg/L < 0.500 <0.0100

COPPER mg/L <0.0250 0.00616 J

CHROMIUM mg/L 0.166 <0.0100

NICKEL mg/L 0.531 <0.0100

LEAD mg/L <0.0500 0.00245 JB

VANADIUM mg/L 0.00669 J <0.00500

ZINC mg/L 0.0502 J 0.00789 J

Mercury: TCLP (CVAA) Units

MERCURY mg/L <0.000200

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.321

MERCURY mg/L <0.000200

General Chemistry Units

FLASHPOINT Deg F >176

HEXAVALENT CHROMIUM mg/Kg <3.33

CYANIDE (TOTAL) mg/Kg 0.905 J

SULFIDE mg/Kg 798

SULFIDE, REACTIVE mg/Kg <48.7

pH SU 9.59

HEM (OIL & GREASE) mg/Kg 13200

TOTAL SOLIDS % 30.0

HEM (OIL & GREASE) mg/L <5.36

HEXAVALENT CHROMIUM mg/L <0.0100

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 30.0 26.9

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 28.2 <5.00 <5.00

ACETONE ug/Kg 3200 16.9 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

FC Composite 5
John Deere Des Moines Works

Ankeny IA

Table 7 Filter Cake Sample Results

for Each Constituent of Interest

Sample FC 6 12/19/2012

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 7 FC-6 19-Dec-2012

LAB Sample ID FC Discrete 6 FC Discrete 6 FC EB 6 FC TB 6

DUPLICATE DUPLICATE

LAB ID 53491-1 53491-2 53491-3 53491-4 53491-5 53491-6

Date Sampled 12/19/2012 12/19/2012 12/19/2012 12/19/2012 12/19/2012 12/19/2012

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 643 619

COPPER mg/Kg 748 707

CHROMIUM mg/Kg 15000 15000

NICKEL mg/Kg 85.5 86.1

LEAD mg/Kg 253 B 244 B

VANADIUM mg/Kg 253 251

ZINC mg/Kg 501 499

Metals: TCLP (ICP) Units

BARIUM mg/L 0.0103 J <0.500 <0.0100

COPPER mg/L 0.442 0.0547 0.00111 J

CHROMIUM mg/L 0.826 <0.0250 <0.0100

NICKEL mg/L 0.744 0.0624 <0.0100

LEAD mg/L <0.0500 <0.0500 <0.00500

VANADIUM mg/L 0.0164 J <0.0250 <0.00500

ZINC mg/L 0.404 <0.100 <0.0200

Mercury: TCLP (CVAA) Units

MERCURY mg/L 0.000702 B <0.00020

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.232 0.237

MERCURY mg/L <0.000200

General Chemistry Units

FLASHPOINT Deg F >176 >176

HEXAVALENT CHROMIUM mg/Kg <3.75 <3.99

CYANIDE (TOTAL) mg/Kg 1.15 J 1.29 J

SULFIDE mg/Kg 778 817

SULFIDE, REACTIVE mg/Kg <48.5 <49.3

pH SU 9.79 9.87

HEM (OIL & GREASE) mg/Kg 16600 17000

TOTAL SOLIDS % 26.0 25.0

HEM (OIL & GREASE) mg/L <5.33

HEXAVALENT CHROMIUM mg/L <0.0100 H

CYANIDE mg/L <0.0100

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L <1.00

% SOLIDS % 26.5 25.1 25.9 27.6

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 11.8 J 19.5 <5.00 <5.00

ACETONE ug/Kg 7020 7150 <5.00 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

H Sample was prepped or analyzed beyond the specified holding time

FC Composite 6 FC Composite 6
John Deere Des Moines Works

Ankeny IA

Table 8 Filter Cake Sample Results

 for Each Constituent of Interest

Initial Filter Cake Sample

Delisting Petition for 

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 8 FC-Initial 20-July-2011

LAB Sample ID Initial EB Initial TB

pH 4.93 pH 7.00 pH 10.01

LAB ID 36909-1,2 36909-5 36909-6 36909-7 36909-4 36909-3

Date Sampled 7/20/2011 7/20/2011 7/20/2011 7/20/2011 7/20/2011 7/20/2011

Metals: TOTAL (ICP) Units

BARIUM mg/Kg 322

COPPER mg/Kg 278

CHROMIUM mg/Kg 9430

NICKEL mg/Kg 1010

LEAD mg/Kg 165

VANADIUM mg/Kg 24.8

ZINC mg/Kg 3390 B

Metals: TCLP (ICP) Units

BARIUM mg/L J 0.0135 J <0.500 <0.500 <0.0100

COPPER mg/L 0.094 0.0376 0.0897 0.00146 J

CHROMIUM mg/L <0.0250 <0.0250 0.0121 J 0.0124

NICKEL mg/L 0.635 0.0461 0.103 <0.0100

LEAD mg/L <0.0500 <0.0500 <0.0500 <0.00500

VANADIUM mg/L J 0.00511 J 0.00536 J 0.0171 J <0.00500

ZINC mg/L J 0.0398 J <0.100 <0.100 <0.0200

Mercury: TCLP (CVAA) Units

MERCURY mg/L <0.00200

Mercury: TOTAL (CVAA) Units

MERCURY mg/Kg 0.116

MERCURY mg/L <0.000200

General Chemistry Units

FLASHPOINT Deg F >176

HEXAVALENT CHROMIUM mg/Kg 6.88

CYANIDE (TOTAL) mg/Kg 0.613 J

SULFIDE mg/Kg 166

SULFIDE, REACTIVE mg/Kg <47.0

pH SU 9.35

HEM (OIL & GREASE) mg/Kg 6920 B B B B

TOTAL SOLIDS % 27.1

HEM (OIL & GREASE) mg/L 1.91

HEXAVALENT CHROMIUM mg/L <0.010

CYANIDE mg/L <0.010 28.7

SULFIDE mg/L <1.00

SULFIDE, REACTIVE mg/L

% SOLIDS % 27.1 28.7 28.7 28.7

VOC (GC/MS)

2-BUTANONE (MEK) ug/Kg 53.8 <5.00 <5.00

ACETONE ug/Kg 6670 <5.00 <5.00

Qualifiers

B Compound was found in the blank and sample

J Result is less than the RL but greater than or equal to the MDL and the concentraton is an approximate value

Initial FC Sample Initial FC Sample Initial FC Sample Initial FC Sample
John Deere Des Moines Works

Ankeny IA

Table 9 Filter Cake Sample Results for Each Constituent of Interest

Case Narrative and Evaluation

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 9 Case Narrative QAQC

Narrative Evaluation

Receipt The samples were received on 12/4/2012 10:30 am; the samples arrived in good condition, 

properly preserved and where required on ice. The temperature of the 2 coolers at receipt 

time were between 3.0 and 3.4 C

No issues

GC/MS VOA Method(s) 8260B: The matrix strike / matrix spike duplicate (MS/MSD) recoveries for 

Acetone and 2-Butanone were outside control limits. The associated laboratory control 

sample (LCS) met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Metals The contract required analysis (CRA) for batch 172271 recovered outside control limits for 

Hg.

Results are consistent with other filter cake 

samples. No affect on results.

Metals Method(s) 6010B: The serial dilution performed for the following sample, 500-52882-1, was 

outside control limits for Ba, Cr, Cu, Ni, Pb, V-, and Zn.

Results are consistent with other filter cake 

samples. No affect on results.

Metals Method(s) 6010B: The matix spike / matrix spike duplicate (MS / MSD) revoveries for 

sample 500-5288-2 were outside control limits for Ba, Ni, V-, and Zn. The assoicated 

laboratory control sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Metals Method(s) 7471A: The matrix spike / matrix spike duplicate (MS / MSD) recoveries for 

sample 500-52882-1 were outside control limits for Hg. The associated laboratory control 

sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

Method(s) 7196A: The hexavalent chromium soluble matrix spike / matrix spike duplicate 

(MS / MSD) recoveries done in separate batches for samples 500-52882-1 and -3 were 

outside control limits, as were the recoveries of the post-digestion spike on each sample. 

The insoluble MS and MSD recoveries and the recoveries of the associated soluble and 

insoluble laboratory control samples (LCS) met acceptance criteria

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

The Eh/pH analysis done on these samples indicated oxidizing matrices, but the sulfide 

content of both samples was quite high, possibly interfering with the lower level soluble 

spike recoveries.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

Method(s) 9034: The total sulfide matrix spike / matrix spike duplicate (MS / MSD) 

recoveries for sample FC Composite 1 (500-52882-1) in batch 172167 were outside control 

limits. The associated laboratory control sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

Method(s) 9034: The reactive sulfide matrix spike / matrix spike duplicate (MS / MSD) 

recoveries for sample FC Composite 1 (500-52882-1) in batch 172643 were outside control 

limits. The associated laboratory control sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

Method(s) 9071B: The oil and grease matrix spike / matrix spike duplicate (MS / MSD) 

reoveries for sample 500-52882-1 in batch 173330 were outside control limits. The 

precision RPD was also outside control limits. The associated laboratory control sample 

(LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Filter Cake 1 Sample 52882 December 3, 2012
John Deere Des Moines Works

Ankeny IA

Table 9 Filter Cake Sample Results for Each Constituent of Interest

Case Narrative and Evaluation

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 9 Case Narrative QAQC

Narrative Evaluation

 

Receipt The samples were received on 12/11/2012 9:45 am; the samples arrived in good condition, 

properly preserved and where required on ice. The temperature of the cooler at receipt 

was 3.3 C

No issues

GC/MS VOA Method(s) 8260B: Due to the high concentration of Acetone, the matrix spike / matrix spike 

duplicate (MS/MSD) for sample -2 could not be evaluated for accuracy and precision. The 

associated laboratory control sample (LCS) met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Metals No analytical or quality issues were noted. No issues

General 

Chemistry

No analytical or quality issues were noted. No issues

Receipt The samples were received on 12/11/2012 9:45 am; the samples arrived in good condition, 

properly preserved and where required on ice. The temperature of the cooler at receipt 

was 1.4 C

No issues

GC/MS VOA No analytical or quality issues were noted. No issues

Metals Method(s) 7470A: The matrix spike duplicate (MSD) recovery and %RPD were outside 

control limites for Hg. The associated laboratory control sample (LCS) recover met 

acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

Method(s) 9034: The total sulfide matrix spike / matrix spike duplicate (MS/MSD) 

recoveries for batch sample FC COMPOSITE 3 (500-53120-1) in batch 173039 were 

outside control limits. The associated laboratory control sample (LCS) recovery met 

acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Receipt The samples were received on 12/15/2012 9:41 am; the samples arrived in good condition, 

properly preserved and where required on ice. The temperature of the cooler at receipt 

was 2.7 C

No issues

GC/MS VOA Method(s) 8260B: Due to the high concentration of Acetone, the matrix spike / matrix spike 

duplicate (MS/MSD) for sample -3 could not be evaluated for accuracy and precision. The 

associated laboratory control sample (LCS) met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

GC/MS VOA Method(s) 8260B: One internal standard response was outside of acceptance limits for the 

following samples: FC D DISCRETE 4 (500-53315-4), FC DISCRETE 4 (500-53315-3). 

The samples were re-analyzed at a dilution for Acetone. All internal standard area 

responses were within limits in the diluted runs. Both sets of data have been provided. 

Results are consistent with other filter cake 

samples. No affect on results.

Filter Cake 2 Sample 53034

Filter Cake 3 Sample 53120

Filter Cake 4 Sample 53315 December 14, 2012
John Deere Des Moines Works

Ankeny IA

Table 9 Filter Cake Sample Results for Each Constituent of Interest

Case Narrative and Evaluation

Delisting Petition for

F006/F019 Filter Cake

Copy of PetitionTable 1-9 AnkenyJDData 6-10-2013.xlsx

Table 9 Case Narrative QAQC

Narrative Evaluation

Metals Method(s) 6010B: The serial dilution performed for the following sample, 500-53315-1, was 

outside control limits for: Ci, Ni, Pb, V-, and Zn.

Results are consistent with other filter cake 

samples. No affect on results.

Metals Method(s) 6010B: The matrix spike / matrix spike duplicate (MS/ MSD) recoveries for 

sample 500-53315-1 were outside control limits for Zn. The matrix spike duplicate (MSD) 

recovery for sample 500-53315-6 was outside control limits for Hg. The associated 

laboratory control sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

General 

Chemistry

No analytical or quality issues were noted. No issues

Receipt The samples were received on 12/18/2012 9:40 am; the samples arrived in good condition, 

properly preserved and where required on ice. The temperature of the cooler at receipt 

was 2.4 C

No issues

GC/MS VOA Method(s) 8260B: One internal standard response was outside of acceptance limits for the 

following sample: FC Composite 5 (500-53342-2). The sample was re-analyzed at a 

dilution for Acetone with all internal standard areas within limits. Both sets of data have 

been provided.

Results are consistent with other filter cake 

samples. No affect on results.

Metals No analytical or quality issues were noted. No issues

General 

Chemistry

No analytical or quality issues were noted. No issues

Receipt The samples were received on 12/22/2012 11:30 am; the samples arrived in good 

condition, properly preserved and where required on ice. The temperature of the cooler at 

receipt was 1.3 C

No issues

Receipt Exception: Cr+6 past hold time. Results are consistent with other filter cake 

samples. No affect on results.

GC/MS VOA No analytical or quality issues were noted. No issues

Metals No analytical or quality issues were noted. No issues

General 

Chemistry

Method(s) 9071B: The oil and grease matrix spike / matrix spike duplicate (MS / MSD) 

recoveries for sample 500-53491-1 in batch 174372 were outside control limits. The 

associated laboratory control sample (LCS) recovery met acceptance criteria.

Results are consistent with other filter cake 

samples. No affect on results.

Filter Cake 5 Sample 53342 December 17, 2012

Filter Cake 6 Sample 53491 December 19, 2012
John Deere

Ankeny IA

Table 10A

Filter Cake Test Data

Mobile Metal Concentration Data

Ankeny Metals Oil Grease Evaluation.xlsx

Charts for Cr Ni OG FC1to6

Designation on Figures 1 2 3 4 5 6 7 8 9 10

Sample ID FC 2 FC 1 FC 6 FC 6 FC 3 FC 5 FC 1 FC 4 FC 4 Initial FC

DUPLICATE Duplicate DUPLICATE pH 10.03

LAB Sample ID 53034-1 52882-1 53491-2 53491-1 53120-1 53342-1 52882-3 53315-1 53315-2 36909-1,2

Date Sampled 12/6/2012 12/3/2012 12/19/2012 12/19/2012 12/10/2012 12/17/2012 12/3/2012 12/14/2012 12/14/2012 7/20/2011

HEM (OIL & GREASE) mg/Kg 21500 19500 17000 16600 13200 13200 12600 11100 8910 6920

Metals: TOTAL (ICP) Units

CHROMIUM mg/Kg 9290 8710 15000 15000 10300 14200 9210 14400 13200 9430

NICKEL mg/Kg 78.7 70.2 86.1 85.5 88.6 77.4 71.6 89.8 86.4 1010

7870 7020 8610 8550 8860 7740 7160 8980 8640 101000

ZINC mg/Kg 381 346 499 501 457 441 359 481 451 3390

Metals: TCLP (ICP) Units

CHROMIUM mg/L 0.0524 <0.0250 <0.0250 0.826 <0.0250 0.166 0.0685 <0.0250 0.0120 0.0121

x10,000 for chart 524 250 250 8260 250 1660 685 250 120 121

NICKEL mg/L 0.646 0.0547 0.0624 0.744 0.0462 0.531 0.59 0.0549 0.0582 0.103

x10,000 for chart 6460 547 624 7440 462 5310 5900 549 582 1030

ZINC mg/L 0.0685 <0.100 <0.100 0.404 <0.100 0.0502 0.148 <0.100 <0.100 <0.100

HEXAVALENT CHROMIUM mg/Kg 4.31 3.89 <3.99 <3.75 7.05 <3.33 13.6 3.97 4.08 6.88

x1,000 for chart 4310 3890 4000 3750 7050 3330 13600 3970 4080 6880

CYANIDE (TOTAL) mg/Kg <1.81 1.92 1.29 1.15 <2.04 0.905 0.816 0.745 0.765 0.613

pH SU 9.02 9.52 9.87 9.79 9.51 9.59 9.61 9.50 9.58 9.35

TOTAL SOLIDS % 27.0 26.4 25.0 26.0 24.0 30.0 25.9 26.0 26.0 27.1

*From Appendix C: Calcuations for Oily Waste Sample Analysis

Observations for the Chrome Chart: Observations for the Nickel Chart:

1 - Chrome (total) is independent of Oil and Grease concentration 1 - Nickel (total) is independent of Oil and Grease concentration

2 - Hex chrome is independent of Chrome-total (peaks not the same) 2 - TCLP Nickel is independent of Total Nickel

3 - TCLP Chrome is independent of Total Chrome

4 - Sample 4 is an outlier for TCLP chrome - no apparent reason
John Deere

Ankeny IA

Table 10B

Filter Cake Testing Data

Oily Waste Test for Mobile Metal Concentration

Ankeny Metals Oil Grease Evaluation.xlsx

FC2 Oily Waste MMC

Analyte THF 

Extract

Toluene 

Extract

TCLP 

Extract MMC

Comparison: Extract 

with Max 

Concentration

Discussion and Observations

EXTRACT VOLUME ml 302 404 936 1,642

BARIUM mg/L <0.040 <0.010 0.048 0.037 TCLP Insignificant mobile metal

CHROMIUM mg/L 0.164 0.013 <0.010 0.039 THF Insignificant mobile metal

COPPER mg/L 1.91 0.068 0.097 0.423 THF Slight affinity for THF (Note 1)

MERCURY mg/L <0.0005 0.0005 <0.0005 <0.0005 No difference Insignificant mobile metal

NICKEL mg/L 0.486 0.042 0.244 0.239 THF Insignificant mobile metal

LEAD mg/L 0.110 <0.010 <0.010 0.028 THF Insignificant mobile metal

VANADIUM mg/L <0.200 <0.050 <0.050 <0.078 No difference Insignificant mobile metal

ZINC mg/L <0.040 0.015 0.026 0.026 TCLP

Note 1: Copper MMC is due to THF extract; this does not have a material affect on the potential hazardous

 properties of the filter cake

CONCLUSION: Metal mobility is not affected by Oil and Grease levels found in the filter cake samples

 *From Appendix C: Calculations for Oily Waste Sample Analysis
FIGURES 

file://\\fnxfiler\Environmental\Share\02.1.6 WWT Operating Manu