UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

REPLY TO THE ATTENTION OF: Terry Zick Industrial Services Manager CTI and Associated, inc 12482 Emerson Drive Brighton, MI 48116
Dear Ms Zick: DW-8J

We have reviewed your Analytical Plan to support a delisting petition and we have found your plan to be incomplete. When petitioning to delist a hazardous waste, it is necessary to demonstrate that there are no hazardous constituents in the waste above the health based levels. It is not sufficient to analyze only for the constituents for which the waste was originally listed. Your sampling and analysis plan must first address all hazardous constituents in order to determine which hazardous constituents may be in your waste. Material Safety Data Sheets are not adequate for determining the presence of constituents at levels near the allowable health based limits set in the delisting program. At least one sample of your waste must be analyzed for all constituents on Appendix IX of 40 CFR part 264, excluding the pesticides and herbicides. The constituents of concern in your waste will include all metals listed in Appendix IX and all volatile and semivolatile constituents that are detected in the initial sample. For the purpose of delisting, allowable levels are determined by the Delisting Risk Assessment Software or DRAS. This program is available online at http://www.epa.gov/region6/6pd/rcrac/pd-o/dras/dras.htm. Before you prepare a delisting petition, we recommend that you use this program to determine if there are any constituents in your waste which might exceed the limiting values allowed by DRAS. A more extensive analysis of your waste would be helpful for this purpose. When running the DRAS program, Region 5 sets the hazard quotient to one and the cancer risk at 10 -6. Since the allowable levels for a delisted waste are dependent on the volume, it is necessary to enter the volume of waste to be delisted before running the program. If you believe that your waste is a suitable candidate for delisting, we request that before you proceed with any sampling, you prepare and submit a draft sampling and analysis plan setting forth your sampling strategy, sampling protocol, analytical procedures and elements of quality control. At a minimum, your sampling strategy should include six samples of your waste collected and analyzed as described below. A 'sample' generally means a composite of four grabs to be analyzed for metals and semivolatiles, plus one grab sample to be analyzed for volatiles.

Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer)Your sampling strategy should include a single initial sample (composite plus grab) to be

analyzed for all volatile, semivolatile and metal constituents in Appendix IX of 40 CFR part 264, excluding pesticides and herbicides. This initial sample will be a basis for identifying the constituents of concern to be be analyzed for in the subsequent samples. After the constituents of concern have been identified, the initial sample must be analyzed for leachability. Five additional samples must then be collected, one sample per week for five weeks. Each sample must be analyzed for total constituent concentration and for leachability for all constituents of concern. Prior to performing leachability tests, each sample should be tested for oil & grease using SW 846 method 1664. For samples with more than .1% oil and grease, leachability of metals should be performed using the Oily Waste Extraction Procedure (OWEP), SW 846 Method 1330A. As written, the OWEP involves two soxhlet extractions followed by the EP tox test, Method 1310. Since Method 1310 is no longer being used, Method 1311 should be substituted for Method 1310 in step 7.10 of 1330A. Leachability of each sample must be determined using the TCLP procedure with three different extraction fluids representing acidic, neutral and alkaline environments. The leachability will first be determined by the TCLP, Method 1311 using the extraction fluid specified in step 7.1.4 of the method. This fluid will have with a pH of either 4.93 or 2.88. The leachability of each sample must also be determined under neutral and alkaline conditions using the TCLP procedure, but substituting the extraction fluid specified in the method with 1) a neutral fluid of reagent water such as ASTM Type II water or equivalent, and 2) an alkaline fluid such as sodium hydroxide with a pH between 10 and 11. For samples with more than 1% oil & grease, leachability of metals at multiple pHs should be done using the above described extraction fluids in step 7.10 of the OWEP. All samples should also be tested for pH, corrosivity, total sulfide, total cyanide, and leachable cyanide. Analysis for total cyanide and total sulfide can be performed using SW 846 methods 9010 and 9030. Leachable cyanide is measured by the TCLP procedure using distilled water as the extraction fluid. In addition to the requirements specified above, the sampling and analysis plans must include the following information: Sampling Plan ♦ Describe in detail the procedure to be followed for collecting samples.

Grab samples for volatiles Composite samples for metals and semivolatiles Describe all equipment to be used for obtaining samples.

♦ Specify the total volume that must be collected for each sample at each sampling event. The volume collected must be adequate for total analysis and for TCLP analysis at 3 pHs. State if additional sample volume is necessary for matrix spikes and matrix spike duplicates.♦ Describe elements of field quality control, including trip and field blanks and field

duplicates

♦ Specify the type of containers and the number of containers that will be necessary.

♦ Describe chain of custody procedures

♦ Specify allowable holding times before analysis, both before and after extraction.

♦ The system for labeling and numbering samples should not identify which samples are duplicates.
♦ Include health and safety considerations during sample collection 

### Analytical Plan ♦ Specify the analytical methods that will be used for total analysis and leachability for each constituent. Also specify analytical methods for additional parameters, including pH, oil and grease, and corrosivity,

♦ Specify the reporting level that can be achieved by the specified method for an analysis of each constituent in the waste and in the leachate.

♦ Include a brief discussion of applicable elements of laboratory quality control

♦ Give the acceptable range of recovery expected for each sample. (based on the Matrix spike and matrix spike duplicate samples. If you have any questions, please do not hesitate to call me at 312-886-1482. Sincerely yours,

Judy Kleiman Regional Delisting Coordinator