"
.

s
To:
Jack­
Waggener@
URSCorp.
com
dwin/
DC/
U
S
EP
EPA
Lee­
Bagby@
urscorp.
com,
Maryt
mpel/
DC/
USEPA/
US@
EPA
Jack,

r
confirming
our
meeting
on
Thursday,
July
31,2003
in
our
office
conference
room
6231
F.
As
I
am
providing
the
following
preliminary
list
of
our
concerns
related
to
your
July
3
email
ts.
Hopefully,
this
will
increase
the
efficiency
and
utility
of
our
meeting.

Woody
We
have
several
questions
and
requests
that
are
intended
to
develop
the
necessary
technical
record
for
our
use
in
reviewing
your
issues
related
to
the
molybdenum
limits
in
the
Organics
subcategory
of
the
CWT
rule.
As
you
know,
the
record
must
logically
support
any
proposed
modifications
or
changes
to
the
existing
rule.

Is
the
Clean
Harbors
facility
subject
to
the
CWT
rule?

1
­
Based
on
the
description
of
the
Clean
Harbors,
Deer
Park,
Texas
facility
operations
(
pages
1
&
2
of
the
attachment
to
your
07­
03­
03
email),
the
Deer
Park
operations
are
not
subject
to
the
CWT
rule.
The
Deer
Park
biological
treatment
system
accepts
only
wastewater
generated
on
site:
leachate
from
the
two
landfills,
contaminated
ground
water
"
pump
&
treat"
wastewater,
stom
water
and
landfill
run­
on.
As
described
in
the
2000
final
CWT
rule,
the
landfills
2.
Please
describe
the
off­
site
waste
receipts
other
than
landfill
wastewater,
if
any,
that
are
treated
in
the
biological
system?

Is
there
any
information
that
documents
that
the
Deer
Park
treatment
system
is
well­
designed
and
well­
operated?`

3.
Please
provide
a
detailed
block
diagram
clearly
showing
all
the
unit
operations
of
the
powdered
activated
carbon
biological
treatment
system
including
recycle
loops.
The
discussion
suggests
that
the
Deer
Park
system
is
a
continuous
activated
sludge
biological
system
with
PAC
addition.
Please
show
what
astes
are
sent
to
each
storage
tank,
include
the
sampling
points
for
the
molybdenum
data
c
in
June
2003;
show
the
compliance
monitoring
effluent
sampling
point
as
well
as
the
internal
monitoring
sampling
point
required
by
the
State
of
Texas.

4.
Please
provide
the
design
basis
for
the
existing
treatment
system
{
compliance
targets
by
pollutant
parameter,
flow
rate,
hydraulic
residence
time,
organic
load
(
BOD5),
mixed
liquor
suspended
solids
(
MLSS),
F/
M
xatio,
etc­)
­
Please
provide­
the
individual
flows
for
the
leachate,
groundwater,
storm
water,
and
landfill
run­
on
including
which
holding
tank
receives
each
waste
stream.
Are
the
holding
tanks
agitated
or
mixed
for
equalization?
5.
Please
provide
the
Baseline
Monitoring
Report
and
subsequent
Compliance
Monitoring
Reports.

ters.
The
Mo
data
alone
is
insufficient
to
assess
the
or
each
sample
date,
please
7.
Please
provide
data
for
the
operating
conditions
on
the
dates
the
samples
were
collected.

8.
For
the
North
&
South
landfill
leachate
samples,
please
provide
data
for
other
parmeters,
if
available?

9.
Please
provide
the
operating
conditions
for
the
June
2003
molybdenum
data
points
as
well
as
any
available
data
for
any
other
parameters
collected
on
the
sample
dates
and
other
dates.
I
Regarding
the
March
24,2003
report
for
CIPF,
Williamsport,
Maryland
.
The
report
indicated
that
CIPF
is
equipped
to
treat
metals,
oils,
and
organics
waste
receipts.
But
during
the
sampling
period,
it
only
treated
oils
and
organics
waste
receipts.

According
to
the
block
diagram,
both
oily
wastestreams
and
organics
wastestreams
are
treated
in
for
Mo,
but
no
influent
SBR
Mo
data
for
the
organics
wastestream.

10.
Do
you
have
any
organics
subcategory
SBR
influent
characterization
data
especially
for
Mo?

11
Please
provide
the
relative
influent
flows
to
the
SBR
unit
for
the
oily
wastes
and
for
the
organics
wastes
especially
for
the
sample
dates?
t
m
p
­
.
T
­
w
­

in­*

s­

2
12.
Please
provide
design
and
operating
information
documenting
that
the
SBR
unit
is
well­
designed
and
operated.

Other
than
Clean
Harbors,
Deer
Park,
TX,
do
you
have
any
Mo
influent
concentration
characterization
data
for
organic
waste
receipts?
How
many
CWT
Organics
subcategory
plants
have
Mo
problems?
