RISK­
BASED
CONDITIONS
:
Dow
Elastomers,
Laplace,
LA
FACILITY
V.
D.
1.
Definitions:

V.
D.
1.
a.
Annual
Sampling
Mode:
A
rate
of
sampling
once
per
twelve
months,
but
no
closer
than
200
days
or
longer
than
530
days
since
the
last
sampling.

V.
D.
1.
b.
Quarterly
Sampling
Mode:
A
rate
of
sampling
once
per
every
three
months,
but
no
closer
than
40
days
or
longer
than
140
days
since
the
last
sampling.

V.
D.
1.
c.
Monthly
Sampling
Mode:
A
rate
of
sampling
once
every
month,
but
no
closer
than
10
days
or
longer
than
50
days
since
the
last
sampling.

V.
D.
1.
d.
Analytical
Database:
A
record
of
analytical
results
from
all
hazardous
waste
feed
metal
samples
taken,
voluntarily
or
required.
This
database
contains
all
data
obtained
whether
used
in
calculating
a
five­
year
rolling
total
metals
feed
rate
or
not.

V.
D.
1.
e.
Five­
Year
Rolling
Total
Metals
Feed:
A
time­
weighted
calculation
of
total
mass
of
a
metal
fed
to
the
HCl
Recovery
Unit
based
upon
analysis
results
obtained
during
the
previous
sixty
months.
Invalidated
data
shall
not
be
used
in
calculating
this
total.
The
time
weighting
of
data
will
be
from
the
date
of
sampling
that
generates
valid
data
to
the
next
sampling
date
when
valid
data
is
obtained.
This
value
is
a
monthly
rolling
total.

V.
D.
1.
f.
Five­
Year
Metals
Feed
Guideline:
A
site­
specific,
risk­
based
guideline
based
upon
an
EPA
Risk
Assessment
and
plant
operations
during
the
Risk
Assessment
Burn.
The
guideline
value
is
calculated
using
EPA's
grams
per
second
mass
flow
rate
results
from
the
risk
assessment
and
projecting
that
flow
over
sixty
months,
including
one
leap
day.

V.
D.
2.
For
each
permitted
hazardous
waste
HAF
the
Permittee
shall
conduct
total
metals
sampling
and
analysis
for
antimony,
arsenic,
barium,
beryllium,
cadmium,
chromium,
lead,
mercury,
nickel,
selenium,
silver
and
thallium.

V.
D.
2.
a.
The
Permittee
shall
sample
each
feed
stream
to
the
Hazardous
Waste
Organics
Tanks
(
1
to
5)
four
times
annually
(
referred
to
as
quarterly
sampling
mode),
unless
the
provisions
of
7
or
8
below
apply.

V.
D.
2.
b.
LDEQ/
EPA­
approved
sampling
and
analytical
methods
(
e.
g.,
"
Test
Methods
for
Evaluating
Solid
Waste
 
Physical/
Chemical
Methods",
SW­
846)
shall
be
used
unless
the
Permittee
obtains
approval
from
the
LDEQ
to
use
another
method.

V.
D.
3
The
site­
specific,
risk­
based
guidelines
are
based
upon
the
EPA
Risk
Assessment
conducted
for
this
facility.
EPA
recommended
these
guidelines
as
annual
average
values
since
the
risk
assessment
evaluated
risk
over
a
40­
year
operating
time
period.
In
determining
the
metal
mass
flow
rate
for
each
hazardous
waste
HAF
to
compare
to
the
site­
specific,
risk­
based
guideline
for
that
metal,
the
Permittee
shall
calculate
a
fiveyear
rolling
total
metals
feed
to
the
HAF
from
the
valid
data
in
the
analytical
database.

V.
D.
4
The
Permittee
shall
not
exceed:

V.
D.
4.
a.
The
five­
year
metals
feed
guideline
specified
in
Table
10
when
calculating
the
total
metals
feed
for
any
metal
over
the
previous
twelve
months;

V.
D.
4.
b.
After
five
years
from
the
effective
date
of
this
permit,
the
fiveyear
metals
feed
guideline
in
Table
10
when
calculating
the
five­
year
rolling
total
metals
feed
for
any
metal
over
the
previous
sixty
months.
(
An
exceedance
of
Section
D.
4.
a
above
shall
not
constitute
an
exceedance
of
this
Section.)

V.
D.
5.
During
the
initial
five­
year
period
the
Permittee
may
use
existing
historical
data
to
calculate
the
five­
year
rolling
total
metals
feed,
if
that
data
exists.

V.
D.
5.
a.
Facilities
with
limited
historical
data,
less
than
five
consecutive
years
of
annual
sampling
and
analysis
data,
shall
develop
historical
data
at
an
accelerated
rate
by
either
option
listed
as
follows:

V.
D.
5.
a.(
1)
Sample
at
the
monthly
sampling
mode
for
one
year;
or
V.
D.
5.
a.(
2)
Sample
at
the
quarterly
sampling
mode
for
five
quarters.

V.
D.
5.
b.
After
completion
of
the
accelerated
sampling
frequency
to
develop
a
historical
record,
the
Permittee
may
initiate
the
quarterly
or
annual
sampling
mode,
as
determined
by
the
Permittee's
projected
five­
year
compliance
with
the
risk­
based
guidelines
in
Table
10
and
as
described
in
numbers
7
and
9
below.

V.
D.
6.
When
the
five­
year
rolling
total
metals
feed
rate
for
a
metal
being
sampled
under
the
annual
sampling
mode
exceeds
the
five­
year
metals
feed
guideline
listed
in
Table
10
for
that
metal
during
a
sampling
and
analysis
event,
the
Permittee
shall
increase
the
sampling
frequency
for
that
metal
to
the
quarterly
sampling
mode.

V.
D.
7.
When
the
five­
year
rolling
total
metals
feed
rate
for
a
metal
being
sampled
under
the
quarterly
sampling
mode
does
not
exceed
the
five­
year
metals
feed
guideline
listed
in
Table
10
for
the
last
five
sampling
events
for
that
metal,
the
Permittee
may
reduce
the
sampling
frequency
for
that
metal
to
the
annual
sampling
mode.

V.
D.
8.
When
the
five­
year
rolling
total
metals
feed
rate
for
a
metal
being
sampled
under
the
quarterly
sampling
mode
exceeds
the
five­
year
metals
feed
guideline
listed
in
Table
10
for
that
metal
during
any
two
of
five
consecutive
sampling
and
analysis
events,
the
Permittee
shall:

V.
D.
8.
a.
increase
the
sampling
frequency
for
that
metal
in
the
hazardous
waste
stream
to
the
monthly
sampling
mode;

V.
D.
8.
b.
investigate
the
cause
of
the
high
metal
mass
flow
rate;

V.
D.
8.
c.
determine
probable
causes
for
exceeding
the
site­
specific,
risk­
based
guideline
for
that
metal;

V.
D.
8.
d.
take
corrective
measures
to
demonstrate
compliance
with
the
risk­
based
guidelines
for
that
metal;
and
V.
D.
8.
e.
notify
LDEQ
in
the
annual
report
of
the
exceedance,
probable
causes
of
the
exceedance
and
corrective
measures
taken.

V.
D.
9.
When
the
five­
year
rolling
total
metals
feed
rate
for
a
metal
being
sampled
under
the
monthly
sampling
mode
does
not
exceed
the
five­
year
metals
feed
guideline
listed
in
Table
10
for
the
last
five
sampling
events
for
that
metal,
the
Permittee
may
reduce
the
sampling
frequency
for
that
metal
to
the
quarterly
sampling
mode.

V.
D.
10.
Data
Handling
V.
D.
10.
a.
At
any
time
the
Permittee
may
voluntarily
increase
the
sampling
frequency
of
a
metal
in
a
hazardous
waste
stream.
V.
D.
10.
a.(
1)
When
sampling
under
a
voluntarily­
increased
frequency,
the
Permittee
may
return
at
any
time
to
the
sampling
mode
for
which
the
metal
in
the
hazardous
waste
stream
was
qualified.

V.
D.
10.
a.(
2)
Sampling
and
analysis
results
obtained
during
the
voluntarily­
increased
sampling
frequency
shall
not
be
used
to
increase
or
reduce
the
sampling
mode.

V.
D.
10.
a.(
3)
Data
obtained
during
the
voluntarily­
increased
frequency
shall
be
included
in
the
analytical
database
and
used
in
calculating
the
five­
year
rolling
total
metals
feed.

V.
D.
10.
b.
The
Permittee
may
request
that
the
laboratory
immediately
reanalyze
the
sample
(
replicate
analysis)
for
a
metal
when
data
is
suspect.

V.
D.
10.
b.(
1)
All
analysis
data
obtained
shall
be
included
in
the
analytical
database.

V.
D.
10.
b.(
2)
Any
data
that
is
considered
invalid
shall
have
an
explanation
defining
what
basis
was
used
to
invalidate
the
data.

V.
D.
10.
b.(
3)
Data
that
is
proven
to
be
invalid
shall
not
be
used
in
calculating
the
five­
year
rolling
total
metals
feed.

V.
D.
10.
b.(
4)
Replicate
sample
results
may
be
used
as
the
sampling
frequency
results
when
the
original
sample
results
have
been
invalidated.

V.
D.
10.
c.
The
Permittee
may
resample
the
hazardous
waste
stream
and
have
the
sample
analyzed
for
the
subject
metal
when
data
is
suspect.

V.
D.
10.
c.(
1)
All
analysis
data
obtained
shall
be
included
in
the
analytical
database.

V.
D.
10.
c.(
2)
Any
data
that
is
considered
invalid
shall
have
an
explanation
defining
what
basis
was
used
to
prove
the
invalid
nature
of
that
data.
V.
D.
10.
c.(
3)
Data
that
is
proven
to
be
invalid
shall
not
be
used
in
calculating
the
five­
year
rolling
total
metals
feed.

V.
D.
10.
c.(
4)
Resampled
analytical
results
are
normally
considered
a
voluntary
sample
and
do
not
impact
shifts
in
sampling
frequency.
These
results
are
used
for
calculating
the
five­
year
rolling
total
metals
feed
rate.

V.
D.
10.
c.(
5)
Resampled
analytical
results
can
impact
sampling
frequency
when
the
results
from
the
original
samples
have
been
proven
to
be
invalid.

V.
D.
10.
d.
DEQ
reserves
the
right
to
review
the
analytical
database,
to
modify,
as
appropriate,
the
classification
of
valid
or
invalid
data,
and
to
recalculate
mass
feed
rates
and
the
five­
year
rolling
total
metals
feed.

V.
D.
11.
For
the
metals;
antimony,
beryllium,
cadmium,
mercury,
silver,
thallium
and
selenium,
the
Permittee
must
demonstrate
a
good­
faith
effort
to
monitor
and
control
the
metals'
feed
rates.
V.
D.
11.
a.
Demonstrate
that
the
detection
limit
using
the
best
available
analytical
technology
is
at
or
below
the
following:

V.
D.
11.
a.(
1)
1.40
ppm
for
antimony
V.
D.
11.
a.(
2)
0.20
ppm
for
beryllium
V.
D.
11.
a.(
3)
0.20
ppm
for
cadmium
V.
D.
11.
a.(
4)
6.76
ppm
for
thallium
V.
D.
11.
a.(
5)
0.04
ppm
for
mercury
V.
D.
11.
a.(
6)
0.80
ppm
for
silver
V.
D.
11.
a.(
7)
2.77
ppm
for
selenium
V.
D.
11.
b.
If
the
Permittee
fails
to
demonstrate
the
detection
limit
is
at
or
below
the
specified
values
in
a),
demonstrate
what
the
method
detection
limit
is
for
the
sample
matrix
with
the
analytical
laboratory
contracted
to
perform
the
analyses
in
accordance
with
40
CFR
136,
Appendix
B.

V.
D.
11.
c.
Should
an
analysis
result
indicate
the
presence
of
a
metal
at
a
concentration
greater
than
the
method
detection
limit,
the
Permittee
shall
either
reduce
the
hazardous
waste
feed
rate
so
that
the
five­
year
rolling
total
metals
feed
does
not
exceed
the
five­
year
metals
feed
guideline
or
demonstrate
that
the
reported
analysis
result
is
invalid.
V.
D.
12.
The
Permittee
may
request
that
EPA
reevaluate
changes
in
risk
assessment
methodology
or
information
and/
or
waste
feed
characterization
and/
or
facility
operations
in
order
to
revise
the
site­
specific,
risk­
based
guideline
levels.
The
Permittee
shall
identify
specifically
the
basis
for
requesting
reevaluation
and
within
30
days
of
the
request,
the
EPA
will
respond
in
writing
to
indicate
if
and
when
the
reanalysis
will
be
conducted.
TABLE
10
FEED
RATE
GUIDELINES1
Constituent
Average
Annual
Metals
Feed
Rate
(
kg/
yr)
Metals
Feed
Rate
(
g/
s)
Five­
Year
Maximum
Waste
Feed
(
kg)

Antimony
27.2
8.61
E­
4
136
Arsenic
39.1
1.24
E­
3
196
Barium
527
1.67
E­
2
2636
Beryllium
3.9
1.24
E­
4
19.6
Cadmium
3.9
1.24
E­
4
19.6
Total
Chromium23
31.64
1.00
E­
3
158
Lead
814
2.58
E­
2
4072
Mercury
0.89
2.80
E­
5
4.45
Nickel
26205
8.31
E­
2
13110
Selenium
53.6
1.70
E­
3
268
Silver
13.8
4.37
E­
4
70
Thallium
131
4.15
E­
3
655
1
Feed
rates
are
based
upon
a
Risk
Assessment
conducted
by
the
Environmental
Protection
Agency.
3Chromium
VI
is
established
by
stack
measurement
at
an
emission
level
of
4.80
E­
5
g/
s
at
this
total
chromium
feed
rate.
4
Total
Chromium
established
by
stack
measurement
accounting
for
air
pollution
control
equipment
removal
efficiency
and
Chromium
VI
partition
factor.
5
Nickel
feed
rates
established
by
stack
measurements
accounting
for
air
pollution
control
equipment
removal
efficiency.
