EVALUATION OF METALS MIGRATION FROM CEMENT KILN DUST (CKD) PILES USING THE EPACMTP GROUNDWATER MODEL

cement kiln dust (CKD) from regulation under Subtitle C of RCRA, pending completion of a Report to Congress required by §8002(o) and a determination by the EPA Administrator either to promulgate regulations under Subtitle C or that such regulations are unwarranted. EPA completed the Report to Congress in December 1993 and the subsequent regulatory determination in January 1995. Based on potential adverse effects resulting from documented damages to groundwater and modeled releases via the air pathway, EPA is undertaking a proposed rule-making to regulate the management of CKD. In support of the Report to Congress and subsequent regulatory determination, EPA conducted screening-level groundwater modeling to determine whether constituents could leach from the CKD management units to the groundwater and then move to a receptor site. The modeling indicated limited potential for contaminants of concern to migrate downgradient to receptor locations at levels of concern. However, the alkaline conditions associated with CKD leachate suggest that additional modeling with more complex groundwater models may be appropriate. Thus, the Agency chose to conduct additional groundwater analyses using the more complex groundwater model, EPACMTP. This report documents the results from this modeling effort and identifies additional limitations of this modeling effort. This report is separated into four sections: Section 1 discusses the modelin

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY HAZARDOUS WASTE MANAGEMENT PERMIT AET DESTRUCTION FACILITY

(codified and to be codified in Title 40 of the Code of Federal Regulations), a Permit is issued t

iii Table of Contents

on a Site-specific Basi

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As required by the above reference, Condition lI.E.3.a. and Condition II.F.3.a., Nuclear Fuel Services, Inc. (NFS) is enclosing the quarterly RCRA Facilify Investigation (RFI) and Interi

Air Quality

• Requires return flo

U.S. Nuclear Regulatory Commission

Dear Messrs. Farmer and Tiesler: As required by the above reference, Condition II.E.3.a. and Condition II.F.3.a., Nuclear Fuel Services, Inc. (NFS) is enclosing the quarterly RCRA Facility Investigation (RFI) and Interim Measures (IM) Progress Reports as Attachments I and II. The next quarterly RF/IM Progress Reports will be submitted by March 16, 1998

and Conservation

Dear Messrs. Farmer and Tiesler: As required by the above reference, Condition H.E.3.a. and Condition II.F.3.a., Nuclear Fuel Services, Inc. (NFS) is enclosing the quarterly RCRA Facility Investigation (RFW) and Interi

C. Existing State Programs

E. Previous Activities to Address Industrial Facilitie

Dear Messrs. Farmer and Tiesler:

As required by the above reference, Condition II.E.3.a. and Condition II.F.3.a., Nuclear Fuel Services, Inc. (NFS) is enclosing the quarterly RCRA Facility Investigation (RFI) and Interi