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HomeMy WebLinkAboutNC0089087_Permit Modification_20151014North Carolina Department of Environmental Quality Pat McCrory Donald R. van der Vaart Governor Secretary October 14, 2015 Paul Young, VP Regulatory Affairs Ergon Asphalt & Emulsions, Inc. 2520 Wilco Boulevard South Wilson, North Carolina 27893 Subject: Issuance of NPDES Permit Modification NPDES Permit NCO089087 EAE Wilson 2520 Wilco Boulevard South Wilson County Dear Mr. Young: In response to your Change of Ownership notice and updated application to modify the subject permit (received October 10, 2014), the Division of Water Resources (the Division or DWR) hereby issues the subject discharge permit. We issue this permit pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency (EPA) dated October 15, 2007 (or as subsequently amended). Permit Modifications. The Division acknowledges Ergon's request to modify parameters of concern (POCs) and their respective sampling frequencies (received October 10, 2014). We have further considered that bulk storage of asphalt product poses less risk of escaping to the natural environment than less viscus hydrocarbon products such as vehicle fuels. Therefore, we conclude: • EPA Test Methods 624 (volatile organics) and 625 (semi -volatile organics) are no longer required, based on data submitted to date. • Total Suspended Solids (TSS) and Turbidity will remain in the permit, but the monitoring frequencies are hereby relaxed from Monthly to Quarterly, based on data submitted to date. • Whole Effluent Toxicity (WET) testing will continue in the permit but, based on data submitted to date, monitoring is hereby relaxed from Quarterly to Annually. [Should any annual test fail, the Permittee shall immediately conduct follow-up testing [see NOTE, Section A. (2.)] and revert to Quarterly monitoring. Findings - DWR Site Visit/Inspection 16Apr2015: 1. Ergon facilities appear well run and well maintained. 2. The Division notes site -grading issues for stormwater: • The ground -surface surrounding the truck -loading rack appears to drain eastward to the property line. Here, catch -basins connected to sub -surface piping convey stormwater southward, to include offsite drainage from adjacent neighbors east. DWR suspects that this conveyance bypasses Ergon's stormwater-collection pond, thus discharging offsite potentially impacted, untreated stormwater. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet: www.newaterquality.org An Equal Opportunity 1 Affirmative Action Employer • DWR recommends that the Permittee re -grade and/or berm the truck -loading area to confine or otherwise contain runoff onsite for treatment afforded by the pond. 2. Draining from the adjacent property west, DWR observed a storm -drain (?) outlet inappropriately capped with a "trash -can lid" (?); this outlet apparently draining to Ergon's onsite pond. DWR questions what impact this discharge may have on the permittee's final -discharge compliance. 3. Site inspectors noted a temporarily effluent bypass of boiler blowdown installed to facilitate sump -pump maintenance. DWR recommends that Ergon adopt new facilities and/or a pollution prevention plan to prevent future effluent bypasses - a permit violation. Electronic Discharge Monitoring Reports (eDMR). Please be advised that the Division will implement an electronic Discharge Monitoring Report (eDMR) program in accord with pending requirements by the Environmental Protection Agency (EPA). We have included the details required to implement the eDMR program in this permit [see Special Condition A. (4)]. Proposed federal regulations require electronic submittal of all DMRs and specify that, if North Carolina does not establish a program to receive such submittals, Permittees must then submit eDMRs directly to EPA. For information on eDMRs, registering for eDMR submittal, and obtaining an eDMR user account, please visit our webpage: http•//portal ncdenr ore/web/wo/admin/bo ipu/edmr For information on EPA's proposed NPDES Electronic Reporting Rule, please visit EPA's website: If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing upon written request submitted within thirty (30) days following receipt of this letter. This request must take the form of a written petition, conforming to Chapter I SOB of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may modify, revoke, and/or reissue this permit. This permit does not affect your legal obligation to obtain other permits required by the Division of Water Resources, the Division of Land Resources, the Coastal Area Management Act, or any other Federal or Local governmental permit. If you have any questions, please contact Joe R. duect line (919) 807-6394. cer y, C S. Jay Zimmerman, .G., Dir to Division of Water Resources L.G. at jjoe.corporon@ncdenr.gov] or call his Enclosure: NPDES Permit NC0089087 (modification issuance final) he: RRO/SWPS Supervisor, Danny Smith Central Files NPDES Program Files ec: RRO/SWPS Supervisor, Danny Smith Aquatic Toxicity Branch (ATB), Atm. Susan Meadows EAE, Inc., Austin Moody, Environmental Engineer [Austin.moody@ergon.coml Permit NC00089087 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES-) In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Ergon Asphalt & Emulsions, Inc. is hereby authorized to discharge wastewater from outfalls located at the EAE -Wilson 2520 Wilco Boulevard Wilson County to receiving waters designated as an unnamed tributary to Contentnea Creek in the Neuse River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, H, III and IV hereof. This permit shall become effective November 1, 2015. This permit and authorization to discharge shall expire at midnight on June 3 012018. Signed this day October 14, 2015. S. ��immerman, P.G., Director•-' _, Division of Water Resources By Authority of the Environmental Management Commission Page 1 Permit NC00089087 .. SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions described herein. Ergon Asphalt & Emulsions, Inc. is hereby authorized to: 1. continue operating Surface -Water Pollution -Prevention facilities for stormwater and related wastewater runoff(s) servicing distribution of petroleum hydrocarbons contained as surface bulk - storage in excess of one (1) million gallons utilizing; • railroad offloading facilities for liquid asphalt with spill -prevention secondary containment • above -ground storage tanks (ASTs), heated • truck -loading rack with spill -prevention secondary containment • pond (stormwater-.retention); • 8-inch diameter discharge line with discharge valve, manually -operated, lockable - normally closed • effluent surface-spreader/diffuser • sample point, up gradient of vegetative filter located at the EAE - Wilson, 2520 Wilco Boulevard, Wilson, Wilson County, and 2. discharge from said treatment works via Outfall 001, at the location specified on the attached map, into an unnamed tributary (UT) to Contentnea Creek [stream segment 27-86-(7)], a waterbody currently classified C; SW; NSW within Subbasin 03-04-07 [HUC: 03020203] of the Neuse River Basin. Page 2 Permit N000089087 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq.; 02B .0500 et seq.] Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored and reported 1 by the Permittee as specified below: EFFLUENT CHARACTERISTICS [PARAMETER CODE] , LIMITS .: . MONITORING RE UIREMENTS .1 Monthly Average Daily Maximum Measurement Frequency Sample a Sample Location Flow 2 50050 Episodic 2 Effluent Total Suspended Solids 3 C0530 30.0 mg/L 45.0 mg/L Quarterly Grab Effluent Turbidity 3 00076 50 NTU Quarterly Grab Effluent pH (standard units) 3 00400 Not < 6.0 of > 9.0 Quarterly Grab Effluent Oil & Grease 3 EPA 1664 [STG-HEM] 00556 Quarterly Grab Effluent WET Acute Toxicity 4. TAE6C Annually 4 Grab Effluent Footnotes: 1. No later than 270 days from the permit effective date, begin submitting discharge Monitoring Reports electronically using NCDWR's eDMR application system. See. Special Conditions A. (4.) 2. Flow shall be monitored with each discharge event. During periods of no discharge, the Permittee shall submit a monthly Discharge Monitoring Report (DMR) indicating "No flow/No discharge." Flow may be monitored using any one of the following methods: a. measure flow continuously; b. calculate flow based on total rainfall per unit area draining to the outfall [see Rational Equation, Section A. (3)]; c. estimate flow at 20-minute intervals during the entire discharge event; or d. report flow based on discharge pump logs. 3. This sample shall be collected concurrently with WET -test sampling. 4. WET Testing: The Permittee shall perform Annual Whole Effluent Toxicity (WET) testing; Acute Pass/Fail @ 90% (Fathead Minnow, 24-hour static test), January, April, July, and October [see Section A. (2.)]. The Permittee has been granted provisional Annual testing based on compliance. If any annual WET test should "fail" [LG-50 < 100%], the Permittee shall immediately conduct follow-up testing [see NOTE, Section A. (2.)] and revert to Quarterly WET testing. After five (5) consecutive Quarterly WET -test events showing "Pass" [LG-50 = 100%], the Permittee may petition the Division to reevaluate the monitoring frequency, as data may warrant. Conditions: • The Permittee shall discharge no floating solids or foam. • The Permittee shall discharge no tank solids, no tank bottom -water, no tank rag layer • Following hydrostatic tank testing, the Permittee shall discharge no tank (or pipe) contents unless the benzene concentration test less than 1.19µg/L and the toluene concentration test less than 11 µg/L. Page 3 Permit NC00089087 A. (2.) ACUTE TOXICITY MONITORING - LIMITED (Annually) [15A NCAC 02B .0200 et seq.] The Permittee shall conduct acute toxicity tests Annually [Except reverting to Quartedy upon failure to pass provisional Annual WET -testing], using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The monitoring shall be performed using a Fathead Minnow (Pimephales promelas), 24-hour static test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The tests will be performed during the months of January, April, July, and October. The parameter code for Pimephales promelas is TGE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWR Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Environmental Sciences Section 1621 Mail Service Center Raleigh, N.C. 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during any month, the Permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with'the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Form submitted. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Page 4 Permit NC00089087 A. (3.) RATIONAL EQUASION - FOR CALCULATING FLOW [G.S. 143-215.3(a)(2)] The Rational Equation is one method for calculating runoff; find references and information in DWR's Stormwater BMP Manual, Chapter 3, "Stormwater Calculations," by addressing the following website: http://i)ortal.NCDEQ.orp-/web/wo/ws/su/bmp-manual The Rational Equation: Q=KuCIA, where: Q = flow (peak flow rate (cfs or m3/sec) Ku = units conversation factor =1.008 for U.S. standard units (usually ignored because it is so close to 1), or 0.278 for SI units C = dimensionless runoff coefficient for the watershed, loosely defined as the ratio of runoff to rainfall I = intensity of rainfall taken from the intensity -duration -frequency curves for the specified design return period at the time of concentration, tc (in/h or mm/h). tc = time of concentration (time after the beginning of rainfall excess when all portions of the drainage basin are contributing simultaneously to flow at the outlet). A = area of tributary watershed (acres or km2) The rational equation is used to calculate the runoff from a region, given: • runoff coefficient which accounts for infiltration and other potential losses in the region, . • rainfall intensity to the region, • time it takes for runoff to travel from the region's upper reaches to its outlet, and • region's drainage area. A. (4.) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS [G.S. 143-215.3(a)(2)]; [G.S. 143-215.66] Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then Permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division adopted and implement these regulations in 2013. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) • Section D. (6.) • Section E. (5.) Reporting Records Retention Monitoring Reports Page 5 Permit NC00089087 Ir 1. Reporting (Supersedes Part II, Section D. (2.) and Section E. (5.) (a)1 Beginning no later than 270 days from the permit effective date, the Permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring -data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), Permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NCDEQ / DWR / Information Processing Unit ATTENTION: Central Files / eDMR 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a Permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the Permittee re -applies for and is granted a new temporary waiver by the Division. - Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http://portal.NCDEO.org/web/wq/admin/bog/ipu/edmr Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. 2. Signatory Requirements [Supplements Part II, Section B. (11.) (b) and supersedes Section B. (11.) All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11, Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part H, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. Page 6 Permit NC00089087 For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.NCDEO.or web/wq/admin/boa/ipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification E40 CFR 122.221. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " I Records Retention [Supplements Part H, Section D. (Q] The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 7 11 US Hwy 301 7- -IF Approximate Property 6b Boundary X Coon tN NAMOn Wild P • M.4 7 01 C U'r to Contentnea Creek Outfall 001 (flows South) (flows south) \4 09 Contentnea Creek (flows cast) P Ergon Asphalt & Emulsions, Inc. EAE-Wilson, 2520 Wilco Boulevard S., Wilson State Grid/ USGS Quad: E27NW/Wilson, NC BUC:0302020307 Latitude: N35041'19" Drainage Basin: Keuse River Basin Longitude: W77055'02" Receiving Stream: UTtoContentneaCreek (27-86-(7)] Sub -Basin: 03-04-07 Stream Class: C; SW; NSW Facility Location (not to scale) NPDES Permit NCO089087 North Wilson County an Site I tannery reclines • Pool • Fileess Center • Playground Conveniently Located • Z, 2 & 3 Bedrooms Appliances Furnished Washer/DryerHookups NelvlyRenrodeled AparhaenlsAvaiteble 1706•B Vineyard Dr. Wilson, NC py 252-291-2035 or visit us on the web: Q T o w N n o u r s tirsteasternrentals.com IMMEDIATE OPENINGS For Experienced Body Shop Technicians Truck Part Counter Person White's international Trucks WStson, NO Goldsboro, NO New Bern, NC r! ErgonAsphalt y & Emulsions, Inc. a company that works, CERTIFIED MAIL 7008 1830 0000 5250 4144 July 28, 2015 Mr. Joe Corporon North Carolina Department of Environmental and Natural Resources Department of Water Resources NPDES RE: ErgonAsphalt&Emulsions —Wilson, NC (NCO089087) Response to Draft NPDES Permit Dear Mr. Corporon: Ergon, Inc. P.O. Box 1639 Jackson, MS 392154639 USA 601-9333000 ergon.com RECEIVEDIDENROWR AUG 0 2015 Water Quality Permitting Section Ergon Asphalt & Emulsions— Wilson, NC received the NPDES draft permit on July 9, 2C15. We are submitting the following comments: 1. TSS and Turbidity will remain in the permit, but the monitoring frequencies are hereby relaxed from Monthly to Quarterly, based on data submitted to date. While the frequency of monitoring is being relaxed, we noticed that a TSS monthly average limit was added to the permit. Please provide the justification for the addition of tits limit. 2. Based on data submitted to date, WET testing is being relaxed from q er to annually. i Per Part I.A.(1.) Footnote 4. of the current NPDES permit, "After five c i ous quarterly WET - test events showing "Pass", the permittee may petition the division to reevaluate the monitoring frequency". On April 21, 2015, the NCDENR notified Sean Randall of EAE — Wilson that based on the results of the previous five WET -tests, there was no need tc collect additional WET test data. The correspondence is being attached to this letter. Since the facility is currently not subject to WET testing, we feel that requiring annual WET testing would be placing more stringency on the facility rather than relaxing the requirement. 3. The frequency of DMR submittals is not indicated in the draft permit or rationale. Please provide this information, as it is not clear since monitoring frequencies have been relaxed. If you have any questions please contact me at (601) 933-3122. Sincerely, Ergon Asphalt & Emulsions, Inc. / �� Crd�zj Katelan Crain Environmental Engineer Office: 601-933-3122 Fax: 601-933-3369 Mobile: 601-270-2092 Katelan.Crain@ergon.com Enclosures CC: Sean Randall, EAE —Wilson Steve Clark, EAE File (220-E-02-14- ) Katelan Crain From: Sean Randall Sent: Tuesday, April 21, 2015 11:59 AM To: Austin Moody; Katelan Crain Subject: FW: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit fyi From: Corporon, Joe rmailto:ioe.corooron(c ncdenr.aov Sent: Tuesday, April 21, 2015 12:15 PM AUG 1 U &k) To: Sean Randall Cc: Hennessy, John; Zhang, Cheng Water Quality Subject: RE: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit Permitting Sectior Thanks, Sean — received; by the way, I notice all five (5) quarterly tests indicate "pass," with the latest sample collected April 7, 2015. Therefore, no need to collect additional WET test data discussed during our site visit. Respectfully, Joe R Corporon, L.G. Compliance and Expedited Permitting DWR Division of Water Resources NCDENR/ NPDES Program / Water Quality Permitting Section 919-807-6394; FAX 919-807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Sean Randall [mailto:Sean.Randall(cbergon.coml Sent: Tuesday, April 21, 2015 12:04 PM To: Corporon, Joe Cc: Austin Moody; Katelan Crain Subject: RE: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit Files are attached this time. From: Sean Randall Sent: Tuesday, April 21, 2015 12:03 PM To: 'Corporon, Joe' Subject: RE: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit sorry, I will resend. From: Corporon, Joe rmailto:ioe.corporon(ancdenr.00v] Sent: Tuesday, April 21, 2015 12:02 PM To: Sean Randall Subject: RE: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit Sean — I don't find the files. Did you forget to attach? Try again. Respectfully, Joe R. Corporon, L. G. Compliance and Expedited Permitting DWR W.Uhsc4UmetRssa:mt Division of Water Resources NCDENR/ NPDES Program / Water Quality Permitting Section 919-807-6394; FAX 919-807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Sean Randall [mailto:Sean. Randall@ergon.com] Sent: Tuesday, April 21, 2015 11:59 AM To: Corporon, Joe Cc: Austin Moody; Katelan Crain Subject: RE: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit Mr. Corporon, Attached are Ergon A&E Wilson Toxicity Reports for January 2014 thru January 2015. We appreciate your help in this process. Sean Randall 252-991-4692 office 580-583-6618 cell From: Corporon, Joe fmailto:joe.corporonC@ncdenr.gov] Sent: Monday, April 20, 2015 7:48 AM To: Sean Randall Cc: Hennessy, John; Pickle, Ken; Zhang, Cheng; Smith, Danny; Bennett, Bradley; Austin Moodv; Bob Walley Subject: NCO089087 Ergon Asphalt and Emulsions, Inc. - Site Visit Mr. Sean Randall: Sean, thanks again for the tour of your facility last Thursday. I enjoyed meeting with you and your dedicated crew. DWR will soon provide feedback on your existing site conditions, and make its decision on your permit application(s). I look forward to receiving your make-up Whole Effluent Toxicity (WET) test results in accord with your existing permit (and any past results that may not have been submitted). I will copy the home office and you on all future correspondence. Thanks also for your continued patience with our backlogged permit -review process. Respectfully, . 4, Corporon, Joe From: Pickle, Ken Sent: Thursday, April 16, 2015 5:09 PM To: Corporon, Joe Cc: Bennett, Bradley, Georgoulias, Bethany; Hennessy, John; Riddle, Rick L Subject: Ergon Asphalt plant, Wilson Hi Joe, • First, most important: So far, I concur that there is no need here for a stormwater permit; the NPDES wastewater permit can suffice. We are open to re-evaluating this if you think differently, or if we have overlooked any aspect. It might be good to meet briefly to be sure we are all seeing the some thing. Just let me know. This opinion based on 40 CFR 443.11(c) Effluent Limitations Guidelines... Asphalt Emulsion Subcategory provision that, "The term process wastewater pollutants shall mean any pollutants present in the process wastewaters and rainwater runoff." My underlining. So, it looks like we have a basis to conclude that the efficient bureaucratic approach here is to have just the one permit, the wastewater permit As I reported earlier today, in the NPDES stormwater program we are using a narrower FOG test at sites where we think the pollutants are likely to be exclusively derived from petroleum. Our new test is: Non polar oil and grease by EPA Method 1664 (SGT-HEM) with a new stormwater benchmark of 15 mg/L. SGT HEM means'silica gel transfer - hexane extraction method', I believe. As I understand it, it's important to qualify the Method with the 'SGT HEM' to be sure that we are getting the narrower method. The Stormwater Permitting Program went through an evolution over recent years in getting from 'O&G'to'TPH' to 'Non -polar Oil and Grease by EPA Method 1664 (SGT-HEM)'. 'TPH' turned out to be confusing, and we are removing it from all permits as they come up for renewal. As you are editing your own internal guidance on bulk terminal NPDES permitting, we would suggest you learn from our experience, and just skip the confusing step of 'TPH'. On the other hand, at sites where animal and vegetable fats, oils, and greases might also be present we are continuing to use the previous O&G test with a stormwater benchmark of 30 mg/L. Bethany led our thinking on these revisions a few years ago, and can perhaps advise further if you want to discuss. Either she or I would also be a good one to review your revised guidance on Bulk Terminal permitting to be sure we are coordinated. As we also discussed, I'm available for a quick review of your Ergon DRAFT NPDES wastewater permit renewal when it's ready. Thanks for asking me. Now, as to sharine my observations this mornine at Ereon: o On -site staff confirmed the unpermitted discharge of boiler blowdown on an infrequent, or maybe just once, maintenance problem basis within the last couple of days. Usually this flow goes to the city sewer, but apparently not when the line backs up or the pump fails. Not a permitted flow, and so you may consider amending the renewed permit to include this flow. As far as Chang and RRO, this is a permit violation, and it's their call as to an NOV. But to my eye this falls in the "No harm, no foul, please don't do it again' category, presuming that it has indeed been an infrequent occurrence of small magnitude. We identified a previously unrecorded underground pipe entering the drainage piping from the property to the east. Nearest development appeared to be a loading dock at a building —500' east of the site. The connection was a surprise to the new Terminal Manager, Sean Randall. Upstream origin of the pipe is unknown. Sean advised he would be trying to find out about this pipe. o We identified a previously unrecorded underground pipe entering the western -most drainage ditch, apparently from the Cargill dog food factory bordering on the west. By my observation the standing water in the drainage ditch had a brownish color not observed anywhere else on site. Approximately 10" diameter pipe was sealed with duct tape, or similar tape, where it was exposed above the ditch: probably not an effective seal; suspected source of brownish water in the ditch. o Drainage from the eastern —15% (?) of the site bypasses the runoff pond. Thomas Dawson, lead operator, reports taking the permit samples at a location that captures the pond discharge, but does not include this flow. Sampling —60' further downstream would capture this flow, but would also capture any flow from the mystery pipe from the east, previously mentioned above. o Noted that three compressed air aerators were operating in the pond, as evidenced by surface turbulence, and as confirmed by T. Dawson. Stated purpose of the aerators was to keep the grass carp alive in the pond by providing DO to this typically stagnant pond. Light green color observed in the pond, of unknown origin, possibly not indicative of anything special. o One apparently blind sump between the two rail spur lines. If site personnel were familiar with the purpose or function of this sump, I did not hear that explanation. o Very nice level spreader on the discharge from the pond. o Pretty good looking site, over all. Let me know if I can help with confirming other observations on site. 114m, Ken Pickle Stormwater Program Specialist NCDENR I DEMLR I Stormwater Permitting Program 1612 Mail Service Center, Raleigh, NC 27699-1612 512 N. Salisbury St, Raleigh, NC 27604 Phone: (919) 807-6376 Fax: (919) 807-6494 Email: ken. Pickle @ncdenr.00v Website:—i)://oortal.ncdenr.org/web/Irlstormwater ** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulations.** eCFR— Code of Federal Regulations http://www.ecfr.gov/cgi-bin/text-idx?SID=9d79b98d56b2d7ea12d5... ELECTRONIC CODE OF FEDERAL REGULATIONS e-CFR Data is current as of February 2, 2016 Title 40 —. Chapter I , Subchapter N Part 443 , Subpart A Title 40: Protection of Environment PART 443—EFFLUENT LIMITATIONS GUIDELINES FOR EXISTING SOURCES AND STANDARDS OF PERFORMANCE AND PRE-TREAT-MENT STANDARDS FOR NEW SOURCES FOR THE PAVING AND ROOFING MATERIALS (TARS AND ASPHALT) POINT SOURCE CATEGORY Subpart A —Asphalt Emulsion Subcategory Contents §443.10 Applicability; description of the asphalt emulsion subcategory. §443.11 Specialized definitions. §443.12 Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available. §443.13 Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best available technology economically achievable. §443.14 [Reserved] §443.15 Standards of performance for new sources. §443.16 Pretreatment standards for new sources. t Back to Top §443.10 Applicability; description of the asphalt emulsion subcategory. The provisions of this subpart are applicable to discharges resulting from the production of asphalt paving and roofing emulsions. It Back to Top §443.11 Specialized definitions. For the purpose of this subpart: (a) Except as provided below, the general definitions, abbreviations and methods of analysis set forth in part 401 of this chapter shall apply to this subpart. (b) The term "production area size" shall mean that area in which the oxidation towers, loading facilities, and all buildings that house product processes we located. _ (c) The term "process wastewater pollutants" shall mean any pollutants present in the process \ wastewaters and rainwater runoff. %/ 1 t Back to Top §443A2 Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available. Except as provided in §§125.30 through 125.32, any existing point source subject to this subpart shall achieve the following effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available (BPT): Effluent characteristic Effluent limitations Maximum for any 1 day Average of daily values for 30 consecutive days shall not exceed— Metric units (kg/cu m of runoff) Oil and grease 0.020 0.015 pH 0) (1) English units (lb/1,000 gal of runoff) Oil and grease 0.167 0.125 PH 0) (t) 'Within the range 6.0 to 9.0. 1 of 3 2/4/2015 1:54 PM eCFR — Code of Federal Regulations http://www.ecfr.gov/cgi-bin/text-idx?SID=9d79b98d56b2d7ea l2d5... [40 FIR 31191, July 24, 1975, as amended at 60 FIR 33969, June 29, 1995] t Back to Top §443.13 Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best available technology economically achievable. The following limitations establish the quantity or quality of pollutants or pollutant properties, controlled by this section, which may be discharged by a point source subject to the provisions of this subpart after application of the best available technology economically achievable: Effluent characteristic Effluent limitations Maximum for any 1 day Average of daily values for 30 consecutive days shall not exceed— Metric units (kg/cu m of runoff) TSS 0.023 0.015 Oil and grease 0.015 0.010 pH 0) (1) English units (lb/1,000 gal of runoff) TSS 0.188 0.125 Oil and grease 0.125 0.083 PH M (1) lWithin the range 6.0 to 9.0. t Back to Top §443.14 [Reserved] t Back to Top §443.15 Standards of performancefor new sources. The following standards of performance establish the quantity or quality of pollutants or pollutant properties, controlled by this section, which may be discharged by a new source subject to the provisions of this subpart: Effluent characteristic Effluent limitations Maximum for any 1 day Average of daily values for 30 consecutive days shall notexceed— Metric units (kg/cu m of runoff) TSS 0.0231 0.015 Oil and grease 0.0151 0.010 pH (1) 0) English units (lb/1,000 gal of runoff) TSS 0.188 0.125 Oil and grease 1 0.1251 0.083 pH I (1) (1) 'Within the range 6.0 to 9.0. t Back to Top §443.16 Pretreatment standards for new sources. Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40 CFR part 403. In addition, the following pretreatment standard establishes the quantity or quality of pollutants or pollutant properties controlled by this section which may be discharged to a publicly owned treatment works by a new source subject to the provisions of this subpart: Pollutant or pollutant property Pretreatment standard BODs- No limitation. TSS Do. pH Do. Oil and grease 100 mgll. [40 FIR 31191, July 24, 1975, as amended at 60 FIR 33969, June 29, 19951 2 of 3 2/4/2015 1:54 PM 1 Michael F. Easley i Governor r William G. Ross, Jr_ Secretary -i North Carolina Department of Environment and Natural Resources "�11 Alan W. Klimek, Director Division of Water Quality February 27, 2007 Pamela F. Faggert, / Vice President and Chief Environmental Officer 7 Dominion Glen Dominion Boulevard Glen Allen, Virginia 23060 .q-V Subject: Your Request to Rescind NPDES Permit NCO079014 Rosemary Power Station Roanoke Rapids, North Carolina Halifax County Dear Ms. Faggert: The Division of Water Quality (the Division) has received and reviewed your letter dated December 20, 2006. We acknowledge your request to rescind both your permits for the subject site, one for a point source discharge (NC0079014), and one for non -point -source stormwater (NCS000197). The Point Source Branch hereby addresses only your NC0079014 permit. The Division will address your request to rescind Non -Point Source permit NCS000197 under separate letterhead. Your facility stores hydrocarbon fuels in bulk. The Division began its investigations of hydrocarbon bulk - storage in 1986. These and subsequent investigations focused our permitting guidance through the last three, five-year NPDES permit cycles. We investigated tank- and piping -maintenance activities, contaminants of concern (COCs), best management practices (BMPs), and thereby evaluated the potential of facilities like yours to imoact North Carolina surface waters. Your facility requires an individual NPDES permit, and does not qualify for general stormwater General Permit NCG080000 because: 1. onsite petroleum -hydrocarbon bulk storage capacity is equal to, or exceeds, one million gallons, and; 2. secondary containment dikes (for product spills) confine stormwater in close proximity to product tanks and appurtenant piping, potentially creating product -contact wastewater [CWA Sec. 502(6), 33U.S.C. §1362 (6)], and; 3. routine operations require the manual discharge of stormwater (via a pipe through secondary containment) to waterbodies of the state, i.e., the release constitutes a point - source discharge [CWA Sec. 502(14), 33U.S.C. §1362 (14)]. North Carolina therefore concludes that this is a wastewater point source and as such, its discharge to the natural environment must be permitted under the NPDES Program. NCDEMY ®*&V N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1 800 623-7748 Type.... Individual Outlet Curves Page 7.13 Name.... Outl 6 -81, j File.... P:\_PROJECT FILES\Black Rock Resources\BROCK POST DT2.PPW RATING TABLE FOR ONE OUTLET TYPE Structure ID = CV (Culvert -Circular) -------------------------------------- Mannings open channel maximum capacity: 1.31 cfs UPstream ID's= 01, IB DNstream ID = TW (Pond Outfall) Pond WS. Device (into) Converge Next DS HGL 0 SUM DS Chan. TW Elev. 0 HW HGL DS HGL DS HGL Error Error TW Error ft cfs ft ft ft +/-ft +/-cfs ft +/-ft -------------------------------------- ------ -------------------- 117.10 2.56 117.10 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=S3.83ft Vh-.838ft HL=3.681ft 217.20 2.60 117.20 Free Free .000 .000 Free Outfall FULL PLOW ... Lfull=53.85ft Vh=.861ft HL=3.782ft 117.30 2.63 117.30 Free Free .000 .000 Free Outfall FULL FLOW ... Lfu11=S3.86ft Vh=.884ft HL=3.882ft 117.40 2.67 117.40 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.87ft Vh=.906ft HL=3.981ft 117.S0 2.70 117.50 Free Free .000 .000 Free Outfall FULL FLOW...Lfull-53.88ft Vh=.929ft HL=4.063ft 117.60 2.73 117.60 Free Free .000 .000 Free Outfall FULL FLOW...Lfull-53.90ft Vh=.952ft HL=4.182ft 117.70 2.76 117.70 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.91ft Vh=.974ft HL=4.282ft 217.80 2.80 117.80 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.91ft Vh=.997f t HL=4.383ft 117.90 2.83 117.90 Free Free .000 .000 Free Outfall FULL FLOW...Lfull=S3.92ft Vh=1.020ft HL=4.483ft 118.00 2.86 118.00 Free Free .000 .000 Free Outfall FULL FLOW...Lfull=53.92ft Vh=1.043ft HL=4.583ft 118.10 2.89 118.10 Free Free .000 .000 Free Outfall FULL FLOW ... Lfullo53.94ft Vh=1.065ft HL=4.683ft 118.20 2.92 118.20 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.94ft Vh=1.088ft HL=4.782ft 118.30 2.9S 118.30 Free Free .000 .000 Free Outfall FULL FLOW ... Lfullr53.95ft Vh=1.110ft HL=4.882ft 116.40 2.98 118.40 Free Free .000 .000 Free Outfall FULL PLOW ... Lfull=53.95ft Vh=1.133ft HL=4.982ft 118.50 3.01 118.50 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.95ft Vh=1.156ft HL-5.082ft 118.60 3.04 218.60 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.95ft Vh=1.179ft HLoS.184ft 118.70 3.07 118.70 Free Free .000 .000 Free Outfall FULL FLOW...Lfull-53.95ft Vh=1.201ft HL=5.282ft 118.80 3.10 118.80 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.95ft Vh=1.224ft HL-5.383ft SIN: 121EOIC0709D Bartlett Engineering and Surveying, PC PondPack Ver. 9.0041 Time: 10:17 AM Date: 10/29/2010 4.0f Type.... Individual Outlet Curves Page 7.14 Name.... Outl 6 -8" 0 6 File.... P:\_PROJECT FILES\Black Rock Resources\BROCIC POST DT2.PPW RATING TABLE FOR ONE OUTLET TYPE Structure ID = CV (Culvert -Circular) -------------------------------------- Mannings open channel maximum capacity: 1.31 cfs Upstream ID's= 01, IS DNstream ID a TW (Pond Outfall) Pond WS. Device (into) Converge Next DS HGL 0 SUM DS Chan. TW Elev. 0 HW HGL DS HGL DS HGL Error Error TW Error ft cfs ft ft ft +/-ft +/-cfs ft +/-ft 118.90 3.13 118.90 Free Free .000 .000 Free Outfall FULL FLOW ... Lfu11=53.96ft Vh=1.247ft HL=5.483ft 119.00 3.15 119.00 Free Free .000 .000 Free Outfall FULL FLOW ... Lfull=53.96ft Vh=1.269ft HL=5.582ft SIN: 121SOlCO709D Bartlett Engineering and Surveying, PC PondPack Ver. 9.0042 Time: 10:17 AM Date: 10/29/2010 R� Appendix A A-1 Index of Starting Page Numbers for ID Names ---- O ----- Outl 6 -S"... 7.01, 7.04 ----- P ----- POND 10... 6.01 ---- S ----- SUBAREA 10... 3.01, 4.01, 5.01, 5.02, 5.03, 5.04, 5.05 SUBAREA 20... 3.03, 4.02 ----- W ----- Watershed... 1.01 WILSON 2010... 2.01 SIR: 121E01CO709D Bartlett Engineering and Surveying, PC PondPack Ver. 9.0041 Time: 10:17 AM Date: 10/29/2010 ■ � � Ergon Asphalt & Emulsions, Inc. Certified Mail: 7012 3460 0003 4309 5315 Attn: John Hennessey NC DENR / DWR / WQ Permitting Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: Ergon Asphalt & Emulsions, Inc. —Wilson, NC NPDES Permit Change in Ownership NC00089087 Dear Mr. Hennessy: RECEIVED/DENRIDWR OCT 10 2014 Water Quality Permitting Section Enclosed, please find the following forms: • NPDES EPA Form 1 • NPDES EPA Form 2C • NPDES EPA Form 2F • Permit Name / Ownership Change Form for NPDES Permit Number NC00089087 • Sampling Results • Chemical Leaching Studies Also with this submittal, Per Regulatory Citation 15A NCAC 0213.0100, we request the Division to reevaluate the current permit's sampling requirements and frequencies. The table below outlines the current effluent limitations and monitoring requirements. Table 1: Current Effluent Limitations and Monitoring Requirements Effluent Characteristics [Parameter Code] Limits Monitoring Requirements Monthly Average Daily Maximum Measurement Frequency Flow 50050 - - Episodic Total Suspended Solids C0530 - 45.0 mg/L 1/Month Turbidity 00076 - 50 NTU 1/Month Volatiles Organics EPA 624 - - 1/Month Semi -Volatile Organics EPA 625 - - 1/Month WET Acute Toxicity TAE6C Based on our industry knowledge and the attached supporting documentation the above effluent and monitoring requirements are not representative for this facility's processes and products stored. As stated by Joe Corporon during our May 12, 2014 meeting and as reported on the past sampling reports (Attachment 5), the facility has not had any issues with meeting the above requirements. Also included in the attachments are three studies (Attachment 6) conducted to determine the probability of chemical leaching of asphalt. Through our own testing we have found these studies to be accurate in the fact that asphalt has a very low probability of chemical 0)U A F (C-f_LV An Ergon Company I P.O. Box 23028 1 Jackson, MS 39225ZO28 USA 1 601-933-3000 1 http://www.ergon.com RErgon Asphalt & Emulsions, Inc. leaching. Therefore, Volatile Organics, Semi -Volatile Organics, and WET Acute Toxicity testing are not representative testing parameters for this facility. Table 2 outlines our proposed effluent limitations and monitoring requirements that are sufficient to accurately and effectively monitor the facility's stormwater discharges. Table 2: Pronosed Effluent Limitations and Mnnitnrinn RP.n111rerrlentS. Effluent Characteristics Units Limits Measurement Frequency Flow MGD Annual Average and Episodic Daily Maximum Total Suspended Solids mG/L Annual Average and Semi-annual Maximum Oil and Grease mg/L Annual Average and Semi-annual Maximum pH 6.0-9.0 Annual Average and Semi-annual Maximum These proposed effluent limitations and monitoring requirements are consistent with the sampling requirements at our similar asphalt storage and production facilities in Mississippi, Texas, Tennessee, Oklahoma, and Kansas. Should you have and questions or comments please contact me. RECEIVED/DENRIDWR OCT 10 2014 Sincerely, Water Quality Ergon Asphalt & Emulsions, Inc. Permitting Section Austin Moody Environmental Engineer Office: (601) 933-3521 Fax: (601) 933-3369 Austin. moodvna.ergon. com Enclosures: CC: Brad Dixon, EAE-Wilson Chris Eldridge, Ergon Inc. File (220-E-02-14- ) An Ergon Company I P.O. Box 23028 1 Jackson, MS 392253028 USA 1 601-933-3000 1 httpi/�.ergon.com Schematic of Water Flow EAE-Wilson Wilson, Wilson County, North Carolina I Storm Water Runoff 11,600 GIRD Retention Pond 11,800 GPD—y Outtall001 11,800 I r' II `1 .yZ—nsunc;rop.,U h— Unnamed C1 d Tributary E, � C +O+ O = O U Contentnea Creek RECENEDIDENRDWR Pat McCrory Governor A7 OCT 10 2014 ±L141 NNCDEAM Water Q$e� on R Permitting North Carolina Department of Environment and Natural Resources Division of Water Resources WATER QUALITY PERMITTING SECTION John E. Skvarla, III Secretary PERMIT NAME/OWNERSHIP CHANGE REQUEST This form is for ownership changes or name changes of NPDES wastewater hermits. "Permittee" references the existing permit Folder • "Applicant" references the entity applying for the ox nership-'name change. I. NPDES Permit No. (for tivhich the change is requested): N C 0 0 8 9 0 8 7 or Certificate of Coverage #: N C G 5 11. Existing Permittee Information: a. Permit issued to (company name): Black Creek Terminal, LLC b. Person legally responsible for permit: Paul Young First MI Last VP - Regulatory Affairs Title P.O. Box 1639 Permit Holder Mailing Address Jackson MS 39215- City State Zip (601) 933-3000 (601) 933-3369 Phone Fax c. Facility name: Black Creek Terminal d. Facility's physical address: 2520 Wilco BLVD South Address Wilson NC 27893- City State Zip e. Facility contact person: _ Brad Dixon (252) 991-4692 First / MI / Last Phone 111. Applicant Information: a. Request for change is a result of: ® Change in ownership of the facility ❑ Name change of the facility or owner tf other please explain: b. Permit issued to (company name): c. Person legally responsible for permit Ergon Asphalt & Emulsions, Inc. - Wilson Paul Young First MI Last VP -Regulatory Affairs Title P.O. Box 1639 Permit Holder Mailing Address Jackson MS 39215-1639 City State Zip (601) 933-3521 austin.moody@ergon.com Phone E-mail Address Page 1 of 2 Revised 7'01.201.1 IV. d. Facility name: e. Facility's physical address: f. Facility contact person: Ergon Asphalt & Emulsions, Inc. - Wilson 2520 Wilco BLVD South Address Wilson NC 27893- City State Zip Brad Dixon First MI Last Terminal Manager Title (252) 991-4692 bdixon ct,blackereekterminal.com Phone E-mail Address Will the permitted facility continue to conduct the same commercial/industrial activities conducted prior to this ownership or name change? ® Yes ❑ No (please explain) If applicable, the applicant shall submit a major permit modification request to D W R. A major modification shall be defined as one that increases the volume, increases the pollutant load, results in a significant relocation of the discharge point, or results in a change in the characteristics of the waste generated. V. Required Items: THIS .APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE INCOMPLETE OR MISSING: 1. This completed application is required for both name change and/or ownership change requests. 2. Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request. Articles of incorporation are not sufficient for an ownership change. Applicable regulations: 40 CFR 122.41, 40 CFR 122.61 and 15A NCAC 02H .0114 .................................................................................................................... The certifications below must be completed and signed by both the permit holder prior to the change (Permittee), and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PERMITTEE CERTIFICATION (Permit holder prior to ownership change): 1, attest that this application for a namelownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. Signature Date APPLICANT CERTIFICATION 1, Paul Youna, attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. /�/ZOZy Si ure � Date PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Water Resources Water Quality Permitting Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 NPDES PERMIT NAME/OWNERSHIP CHANGE REQUEST Nee 2 of 2 lteriserl7 012014 Attachment 5 Sample Results Lou ISIANA STATE UNIVERSITY A N D A G R I C U L T U R A L A N D M E C if A N 1 C A L C O L L E G E Schocl cf the roast art! �It�'uo;�rr�ent;'r7epart►rtarrt of Fn: irammentai Stvdres Re,pome and f;'lsemkal Assessment Team I28i liner ('oast & 1:nvii-onment 11kh—, Baton Roinu r. LA 7003 V D t?S/RCAT06-01 TO: Steve Lehmann. SSC NOAA-HMRD FROM: Buffi., Ashton Response & Chemical Assessment `Ream Louisiana State University. Dept of Environmental Studies RE: BARGE MM53/54 OIL SPILL 10 February 2006 The Response and Chemical Assessment Team at Louisiana State University analyzed one (1) paving grade asphalt sample collected from Barge MM54 (Barge MM53's sister barge) by GC/MS; and performed a "water temperature" experiment to determine the properties of the sunken asphalt at increasing temperatures. Stemple identifications and descriptions are given in 1`able 1. The GC/MS analvsis results are in Tables 2 and 3. and the results of the water temperature experiment, including photographs, are given on pages 4 and 5. Table 1. Sample Identifications and Descriptions. LSIJ Ill## Field lD# Sample Description Collection Date 2N6040-01 n/a Asphalt from Barge tv M54 28 Jan 06 t'?''Al' has made the following conclusions: • Due to the low concentrations of PA1-ls in the asphalt sample, we feel that there is a ve?y lo►v probability of chemical leaching. The high temperature refining process and the heated transport process for this paving grade asphalt greatly reduces the water soluble PAHs, which is evident in the GC/MS data. The naphthalene compounds that are present in the sample will naturally- degrade, and the other PAI-Is will be encapsulated within the asphalt "pancake". • There is little to no probability of sheening from the Bard, sunken asphalt, even at water temperatures around 80' I'. The hot asphalt hitting the water results in a hardened asphalt matrix that sinks. Once it hits the bottom surface, the hardened asphalt wily slowly biodegrade throughout the rest oi'the winter and spring. DES/RC AT06-01 Barge N. B15-31i4 Oil Spill GUMS Results (Fast-ti(1i method): Fable 2. Normal Alkane Concentrations in Barge NIN153154 :asphalt Sample LSU ID# 2N6040-01 Site Barge MM53/54 Sample Decri tion Asphalt ALKANES Conc n !m nC-10 Decane 2.0 nC-11 Undecane 2.5 nC-12 Dodecane 2.0 nC-13 Tridecane 2.4 nC-14 Tetradecane 2.4 nC-15 Pentadecane 3.1 nC-16 Hexadecane 3.8 nC-17 He tadecane 3.5 Pristane 1.1 nC-18 Octadecane 4.0 Ph tape 1.7 nC-19 Nonadecane 4.2 nC-20 Eicosane 4.7 nC-21 Heneicosane 6.0 nC-22 Docosane 6.8 nC-23 Tricosane 8.6 nC-24 Tetracosane 11 nC-25 Pentacosane 11 nC-26 Hexacosane 12 nC-27 He tacosane 15 nC-28 Octacosane 16 nC-29 Nonacosane 19 nC-30 Triacontane 24 nC-31 Hentriacontane 28 nC-32 Dotriacontane 35 nC-33 Tdtriacontane 39 nC-34 Tetratriacontane 26 nC-35 Pentatriacontane 28 TOTAL ALKANES 323 DFS/ ICAT06-p1 liar-c NIN153/54 Oil spill Fable ;. PAII Concentrations in Barre NFNIS3154 Asphalt Sample (nd=nondetectibellm detection limits) LSU ID# 2N6040-111 Barge WA-53154 Site Sample Decri Lion Asohalt PAHs Conc n tm ) Naphthalene 0.51 C•1 Na h 2.3 C-2 Naph 2.8 C-3 Na h 2.4 C-4 Na h nd Fluorene nd C-1 Fluor nd C-2 Fluor nd C-3 Fluor nd Dibenzothio hene 0.45 C-1 OBT 2.0 C-2 DBT 4.8 C-3 DBT 6.5 Phenanthrene 0.52 C-1 Phen 1.7 C-2 Phen 3.9 C-3 Phen 4.5 C-4 Phen nd Anthracene nd Fluoranthene nd P rene nd C-1 P r 0.75 C-2 P r 1.8 C-3 P r 2.6 C-4 P r 2.6 Na thobenzothio hene 1.1 C-1 NBT 10 C-2 NBT 17 C-3 NBT 21 Benzo a Anthracene 0.71 Chrysene 0.73 C-1 Chry 2.3 C-2 Chry 4.3 C-3 Chry nd C-4 Chry nd Benzo (b) Fluoranthene nd Benzo k) Fluoranthene nd Benzo e P rene nd Benzo (a) P rene nd Per lene nd Indeno (1.2.3 - cd) P rene nd Oibenzo (a.h) anthracene nd Benzo tc.h.il perylene I nd TOTAL PAHs 1 97 DE'ti/lt(A I'06-01 l3aru,c -NI NIU154 Oil Spill Water Fxnerimenl Procedure and Results: I he asphalt sample was heated to approximate 110"F and x%as added to a beaker ofdeionited water at a temperature nl 60"F. The water was then healed to the linal temperature ill' I2Y'F. Observations were made and pittures were taken at the tollo%%ing temperatures: Water temperature o f' 60"F o Asphalt Iloats at first (Figure I ), bill then sinks to the bottom alter swirling thRECEIVED/DENR/DWR beaker (Figure 2). o No visible sheen or oil on the water surface at this water temperature after OCT 10 2014 swirling the beaker with the asphalt on the bottom. Water Quellty Permitting Section Figure I. Figure 2. • Water temperature of 70°F - 90°F o Asphalt still at bottom of beaker and is stuck to the glass. o No visible sheen or oil on the water surface at this water temperature after swirling the beaker. o Asphalt has a glassy appearance. • Water temperature of I00°F — I I OT o Asphalt still at bottom ol'beaker and is still stuck to the glass. o No visible sheen or oil on the water surface at this water temperature after swirling the beaker. o Asphalt appears to be melting, as shown in Figure 3. 1)1; S/RGCI06-01 Barge NINI5364 Oil Spill Figure 3. • Water temperature of 120°F - 125T o Asphalt still at bottom of the beaker, stuck to the glass. When the asphalt glob was moved with a spatula, some of the asphalt Floated to the water surface. o Small oil droplets are visible on the surface of the water; however, not really able to photograph them. o Appearance of the asphalt at 1250F is displayed in Figure 4. Figure 4. DE;S/ItCA 1'04-01 5 Rai ge )I?153/544 Oil Spill ASPHALT INSTITUTE Executive Offices and Research Center Research Park Drive P.Q. Box 14052 Lexington, KY 40512-4052 USA Telephone 859-288-4960 FAX No. 859-288-4999 LEACHABILITY OF ASPHALT AND CONCRETE PAVEMENTS Anthony J. Kriech (Heritage Research Group, 7901 W. Morris St., Indianapolis, Indiana 46231, U.S,A.; e-mail tony.kriech@heritage-enviro.com) CONTENTS INTRODUCTION SITE LOCATIONS SAMPLE PREPARATION METHODS SAMPLE ANALYSES COMMENTS CONCLUSIONS REFERENCES 0. INTRODUCTION The IAPA (Illinois Asphalt Pavement Association) contracted with Heritage Research Group to study the leachability of both Portland Cement Concrete (PCC) and Hot Mix Asphalt Pavements (HMA). Granular materials, including soil from the edge of each pavement type, were also tested to determine leachability. The design of this experiment was through the joint cooperation of the Illinois Environmental Protection Agency, Illinois Department of Transportation and IAPA. The purpose of the study was to determine the suitability of using concrete, asphalt, or soils from the surrounding roadway for use as clean fill. The concern is that the incidental spills onto the road from cars and trucks could contaminate the pavement and surrounding road side, and make these road materials unsuitable for use in clean fill situations below the water table. Specifically, unsubstituted Polynuclear Aromatic Hydrocarbons (PAH's) and heavy metals were studied. These were chosen because volatile and semi -volatile compounds, which may be spilled on the road, evaporate quickly. Previous studies by Heritage Research Group'2 have not found these compounds present. Only the metals and high molecular weight organic compounds tend to remain. 1.0 SITE LOCATIONS The Illinois Department of Transportation located a section of pavement on Route #4 south of Springfield. The unique feature of the pavement section was that it contained Portland Cement Concrete, which was built in 1976 and a Hot Mix Asphalt pavement, which abuts this section and was also built at the same time. Because these sections are contiguous, the traffic on each are identical. Three sites were randomly selected in each pavement type, as to longitudinal location. Coring occurred on December 17, 1991 by IDOT District personnel. Once a site was selected, three four inch specimens were taken across the pavement. The first is between the wheel paths, the second was in the outer wheel path, and the third was taken outside the outer wheel path. A sample of soil and granular material was also taken from the shoulder of the road. The sample identification and locations are listed in Fi ure A. The "W' proceeding the numbers indicates white (PCC) pavements and "B" indicates black (HMA) pavements. Heritage Research also received some laboratory prepared samples from IDOT laboratories. &.r 1ple W-0 is a Portland Cement Concrete laboratory cylinder and is considered typical of Portland Cement Concrete by I DOT. Sample B-0 is a Hot Mix Asphalt sample prepared by (DOT and the compositional mix design is also considered typical by IDOT. These samples were used as controls and are free of any potential contamination: which the road samples may have received since they were placed in 1976. 2.0 SAMPLE PREPARATION To prepare the sample for Toxic Characteristics Leachability Procedure (TCLP) in accordance with EPA guidelines, the samples were crushed to pass the 9.5 mm. sieve size. An impact crusher was used to reduce the samples to below this size. Representative materials from each sample location were combined with other samples sites to test various hypothesis about pavement contamination. The first was that contamination may be greater between the wheel path, because this is where crankcase drippings tend to fall. To test this theory, all samples from between the wheel path were combined for each pavement type to make one sample. A second hypothesis was that the samples taken from the wheel path would be cleaner, because the tires are constantly wearing this pavement away. This idea was tested by combining all samples in the wheel path for each pavement. Samples outside the wheel path were also combined to make a sample to determine if there was a similar trend in the data. The soil samples from the shoulder were also combined to determine if the soil was higher or lower than the pavement in leachability. Finally, one transverse sample was taken from one location of each pavement type and compared to longitudinal samples to test for site specific contamination. All of these combined samples were compared to the laboratory samples of each pavement type, which had been prepared in the laboratory as a control. Table A lists the combination of sites used to make each sample for TCLP testing. 3.0 METHODS After the combined samples were prepared by Heritage Research, they were submitted to EMS Heritage Laboratories for TCLP testing. EMS Heritage is an EPA certified laboratory. The test methods used are listed below. Contents Test` TCLP Procedure PAH`s I MethodlProcedure - -----_ SW-846-1311 SW 846-8310 Metals _ - Barium_ SW-846-7080 Cadmium Chromium SW-846-7130 SE-846-7190 Lead ! SW-846-7420 Silver Arsenic PKV-846-7760 Selenium SW-846-7740 Mercury ; SW-846-7470 4.0 SAMPLE ANALYSES A summary of the test results from the TCLP are listed in Table B for the Portland Cement Concrete Pavement and soil located next to this pavement type. Table C lists the leachability of Hot Mix Asphalt samples and soil corresponding to this pavement. Please note that PAH's are measured in ?g/L, which is parts per billion. The metal leachability is in mg/L or parts per million. The detection limit of the barium analyses varied with the sample. Because of high calcium in the leachate of some samples, the detection levels varied from 0.2 to 2.0. Matrix effects do impact on the detection level achievable in these samples. 5.0 COMMENTS 5.1 Both the PCC and HMA laboratory prepared samples from IDOT had measurable amounts of metals leaching, but no measurable PAH's. The PCC sample indicated a small amount of leachable chrome. The HMA had measurable barium in the leachate. 5.2 Samples taken in the PCC section, whether taken longitudinally or transversely, showed trace amounts of naphthalene and phenanthrene in two samples. Both samples contained material from site W-3, so it could be the same contaminant. Four samples contained a small amount of Naphthalene. These values were, in all cases, less than one part per billion. One sample from the wheel path had measurable barium on the leachate. 5.3 The soil samples taken from the PCC shoulder produced no leachable PAH's. However, a measurable (3.5 ppm.) level of barium was found. Contents 5.4 The HMA pavement appeared quite similar to the PCC pavement in leachate results. Only naphthalene and phenanthrene were found in the pavement leachate. In all cases, the level was under one part per billion. Metal leachate was confined to barium, which was present in both the laboratory and field samples. This would indicate that barium is not coming from contamination, but rather is most likely coming from the aggregate in the mixture. These values would probably be lower if the sample was not crushed, which exposes the uncoated aggregate surfaces and increasing the exposed surface area greatly. 5.5 The soil from the HMA shoulder also contained a measurable level (0.76 parts per billion) of naphthalene. Since the laboratory samples did not have measurable levels, it is possible that this came from surface contamination. Used crankcase oils and tire composition contains measurable quantities of both naphthalene and phenanthrene, and could be potential sources for these very low, but measurable values. 5.6 The hypothesis that contamination would be greater between the wheel paths than at other location was not supported by these results. Overall, the level of leachable PAH materials was too low to determine trends in the data. 6.0 CONCLUSIONS This study found that both PCC and HMA pavements each have very low levels of leachable metals and PAH materials. The relative low levels of leachable materials from both pavement types are quite similar. Soils from the shoulder of the road are quite similar in characteristics to the PCC and HMA pavements. 7.0 REFERENCES 1. Kriech, Anthony J. Evaluation of Hot Mix Asphalt for Leachability. HRG #3959AOM3. October 15, 1990. 2. Kriech, Anthony J. Evaluation of RAP for Use as a Clean Fill. HRG #4122EM02. January 30. 1991. TABLE A Sample Identification Sample # Sample Identification :Description 1 `W-0 PCC Uncontaminated, Laboratory Specimen 2 W-1, 2, 3 PCC Transverse Across the Pavement 3___...... W--1,_5,._9 :PCC Between Wheel Path, Longitudinal _Sample -- 4 W 2, 6, 10 PCC In Wheel Path, Longitudinal Sample 5! _ W 3, 7, 11 ° PCC Outside Wheel Path, Longitudinal Sample _ 6 `W 4, 8, 12 PCC Soil from Shoulder, Longitudinal Sample _ 7 IHMA Uncontaminated, Laboratory Specimen ; 8 B-1, 2, 3 1 B-1, 5, 9 HMA Transverse Across the Pavement ' 9 ; HMA Between Wheel Path, Longitudinal Sample 10 1 B-2, 6, 10 HMA In Wheel Path, Longitudinal Sample 1 1B_3, _ _ 7, 11^ HMA Outside Wheel Path, Longitudinal Sample 12 B-4 8, 12 IHMA Soil from Shoulder, Longitudinal Sample _ Contents TABLE B Illinois TCLP Test Results for Portland Cement Concrete Cores [Sample Number (Control) 2 3 4 5 ;fi (Soil) -- Site Number PAH's, N/L W-0 W-1,2,3 W-1,3,9 W-2,6,10 W _ 3,7,11 _ Heritage W Det. 4,8.12 Limit [Naphthaiene BDL 0.44 0.21 0.23 0.26 BDL 0:16 Acena hth lene BDL BDL BDL ; _ BDL ^: _BDL BDL! J BDL BDL —r0.25 F�cenaphthene ` BDL_ BDL f BDL 0.16 __— Fluorene ..__-_-------.____.............._.__.__ _..___ _ � Phenanthrene Anthracene I Ffuoranthene _ -J _BDL BDL i BDL € _ _. BDL 0.44 BDL BDL , BDL BDL BDL _ _.. BDL _ BDL BDL BDL i __ _. _. ___.. BDL '•, BDL BDL BDL ..j 0.26 BDL ' BDL _ , BDL BDL _ 0.019 0.16 0.021 - BDL BDL 0.021 Pyrene _. __-- - _-.. _. _ _.— _, BDL BDL ^BDL BDL BDL BDL f 0`075 ��tjzo(A)Anthracene BDL BDL BDL BDL BDL BDL -+ BDL BDL - -! 0.013 0.041 --- Chrysene BDL BDL BDL BDL Benzo(B)Fluoranthene BDL BDL _ _ _ ._ BDL BDL BDL ........ BDL ;I BDL ..........� BDL __ 0.029 -- --- -.. Benzo K Fluoranthene BDL BDL BDL-- BDL 0.013 Benzo(A)Pyrene Dibenzo A,H Anthracenel ( ) Benzo(G, H, 1) Pery Iene _ BDL ? BDL BDL BDL BDL BDL BDL BDL I BDL BDL BDL 't BDL 0.023 BDL BDL L _ 0.085 - BDL BDL B—DL--�-� BDL I 0.14 indeno(1,2,3-cd)Pyrene BDL BDL BDL BDLII BDL BDL 0.028 Metals,_mg_/L_ Barium_ BDL BDL ': _BDL 1.2* BDL 3.5 _ 2.000 Cadmium Chromium JI-ead _ _ _ _ BDL _�-_ 0.072 BDL BDL BDL -J _ BE BDL BDL - BDL BDL BDL BDL _ BDL 0.020 0.050� _BDL i BDL BDL B_DL _ BDL 0200� Silver _ _ _ Arsenic_ _BDL BDL BDL s BDL BDL BDL _BDL BDL s BDLi� BDL BD_L BDL_I _0.040 0.005� Selenium ^ BDL BDL j BDL BDL BDL BDL -BDL _ _1 BDL __ BDL 0.010 ]mercuryBDL BDL BDL • This sample had a detection limit for barium of 0.2. Contents TABLE C Illinois TCLP Test Results for Portland Cement Concrete Cores Sam le Number ;F7 (C�o--n-trot 8 9 -F-10 11 Fi Soil i Site Number i._-_...__...__._._......----.._.. B-0 B-1,2,3 - B 1,3,9 _ _ .. B-2,6,10 : .. B-3,7,11 � B-4,8-12 .. ___--.._ Heritage' Det. _...._.emit- _...--._..._......._:.. .: .............. . Naphthalene ._ BDL.-... ._ 26 ._.__.0.31 _.._.. 0.28......... . Acenaphthylene BDL ...026...- ..:....0 BDL BDL BDL -BDL BDL _ _ 0.25 _ Acenaphthene _._._°...BDL , -.BDL BDL....._ ._...BDL , _ BDL__.i--_0.16._. Fluorene __--BDL BDL.....-_.._._ - BDL . _.. .__._BDL-- I BDL - ..BDL....: BDL } - -0.019 Phenanthrene BDL -BDL BDL _ J. BDL_ ��—�0.3-0 ; BDL _ _BDL IF 0 Anthracene BDL BDL -- ` BDL - -BDL - BDLW� --BDL___ BDL _BDL: BDL __ 0.021 FluorantheneDL------ BDL _� 0021- Pyrene Benzo(A) i nthracene Chrysene IE BDL BDL BDL BDL BDL i j BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL ' BDL BDL 0.075 0.013 0.041 t Fluoranthene BDL BDL BDL { BDL BDL it BDL 0.029 Benzo(K) t Fluoranthene BDL BDL BDL i BDL BDL BDL 0.013 Benzo(A)Pyrene - BDL _ BDL i� BDL BDL BDL-ir DL i -0.023 Dibenzo(A,H) j Anthracene_ BDL BDL BDL BDL [:iD:L:.*..,BDL 0.085 Benzo(G,H,I)Peryle BDL `•: BDL BDL BDL BDL BDL_ Indeno(1,2,3-cd) Pyren_e BDL ' BDL _ 4� BDL _ BDL I BDL - BDL 0.028 Metals, mgA- -' - Barium 2.9 3.7 BDL 3.1 2.6 3.5 2.000 .Cadmium BDL BDL , BDL BDL 0.020 IChromium BDL BDL BDL i BDL BDL ��� �_ BDL 0.050 Lead BDL �w- _-BDL; _BDL_ - _ -BDL iBDL _ . _BDL _ �0.200 _ Silver !� BDL BDL BDL BDL BDL BDL 0.040 Arsenic E BDL_.... BDL E�... 005 ..._........ Selenium --- Mercury_ . BDL BDL _.._ BDL BDL -BDL BDL BDL BDL F BDL BDL BDL .BDL.... _BD_ L f BDL ..0 .. 0.010 0.005 Contents ASPHALT INSTITUTE Executive Offices and Research Center Research Park Drive P.O. Box 14052 Lexington, KY 40512-4052 USA Telephone 859-288-4960 FAX No. 859-288-4999 Oregon And Washington Fish Hatcheries Lined With Asphalt by Ed D. Schlect, District Engineer, Asphalt Institute More than 30 fish hatchery ponds are operated by Oregon and Washington and many of them are lined with hot -mix asphalt (HMA). The states' fish and wildlife officials say the ponds are durable and produce good -quality fish. HMA is one of the most commonly used liners for hatchery ponds, according to Ray Sheldon, hatchery operations coordinator for the Oregon Department of Fish and Wildlife. 'We've had good results rearing quality fish" in the ponds, says Sheldon. One of Oregon's ponds, the Clackamas fish hatchery at McCiver State Park, releases more than 1.5 million chinook each spring into the Clackamas River. The hatchery houses the fish about 18 months before releasing them into the river. In Washington, the State Department of Fisheries and the Department of Wildlife operate more than 25 hatcheries. At least two Indian tribes in the state also maintain hatchery ponds lined with HMA. A typical Washington state fish hatchery pond is 5 to 7 feet deep and covers a one-half acre surface area. The liner is 2 or 3 inches of HMA on 8 inches of granular base. Liners consist of 3/8-inch nominal maximum -size aggregate with 6.5 percent asphalt cement. The higher volume of asphalt cement ensures a low -void, impermeable mix. When the ponds are empty, pressure relief valves in the pond bottom relieve hydrostatic pressure under the liner. Some ponds are designed with pressure relief valves throughout the pond floor while others use valves only in the drain channel. All joints between the HMA liner and the headwalls and outlet gates are sealed with rubberized asphalt liners. Many of the HMA ponds are sealed with an asphalt emulsion because a bacteria detrimental to r:>' r an find a habitat in the surface voids of the HMA. Current specifications require either a proprietary asphalt emulsion sealer, a CSS-1 or a CS-1 h. Both Washington and Oregon state agencies are pleased with the effectiveness of the HMA liners and plan to use them for additional fish hatcheries in the future. This article appeared in the Winter 1990-91, Volume 4, No. 3, ASPHALT magazine. ;tI1tI•hhi\{}? fit. 1!tI WI 0011 J$ It}ll+ DE TERNIINATION OF POLYCYCLIC AROMATIC COMPOUNDS IN ASPHAI:I- AND IN CORRESPONDING LEACHATE WATER A. J. Kriech J. T. Kurek L. V. Osborn H. L. Wissel B. J. Sweeney heritage Research Group, Indianapolis, Indiana, USA The environmental impact of polveYclic aromatic compounds (PACs) in asphalt (bitumen) materials is related to their availability for environmental transport and biouptake, rather than their total concentrations. This study examines six Stratetg c Highway Research P►ogrant (SARI') paving asphalts and four commercial roofing asphalts. Three cleanup procedures fir the neat asphalt samples are evaluated. This study reports on anal),ses fur 29 PACs, including the EPA 16 prioritypollutant P.411.s and additional Persistent Bioaccumulative Toxins. These require reporting by the U.S. EPA under the Emergency Planning and Community Right -to -Knott, Act (EPCRA) section 313. Tire analytical prvtocol,for analysis of the higher molecular weight PACs by GC/MS it reported, with inclusion of GCIUS/MS verification of sone of the detectahle compounds. Additionally, each asphalt uws taken through a toxicity characteristic leaching proceclure firllowi» g U.S. EPA method SW846-1311. Results oj'the paving and rzrofing asphalts and their con-v�sponding leachate waters are presented in this study. Kevwords EPCRA section 313, GC/MS. leachate, PACs, paving asphalt, rofin asphalt USA. The atrthors thank Caralyn K. Clark for her diligent efforts to finalize and re%ie«v this article. Address correspondence to A. J. Kriech, i leritage Research Group, Indianapolis. IN 46231. 517 i I 1 A. kricch rl al. .Asphalt cement is (lie nondistillable fraction obtained in the distil- lation of crude oil. It is a c01111))eX mixture of high-n)olecular-weight aliphatic and aromatic hydrocarbons and organosulfur compounds with smaller amounts of nitrogen and oxygen COMI)011nds. While there are many similar components in different asphalt samples, the exact compo- sition and properties are a function of both the source of the crude oil and its processing (1). Asphalt is used widely for highways, parking lots, air- port runways, and has also been used in many hydraulic applications for waterproofing reservoirs used for drinking water, fish hatcheries, boat ramps, and canals (2). A significant number of roofing systems also use asphalt in their formulation including asphalt -shingled roofs and flat or sloped built-up roofs (BUR). Some standard differences between asphalt paving and roofing in- clude application temperatures, hardness of the asphalt, and the presence of aggregates. BUR roofing asphalt is typically harder than paving as- phalt cement. Penetration values for BUR roofing asphalt range from 12 to 35; paving asphalt typically has 50 orhigher. Roofing application tem- peratures can be as high as 337"C, but are typically in the range of 232` to 274"C. Application temperatures for paving are generally less than 160°C. Hot mix asphalt composition generally consists of 95% mineral aggregate (rock) and 5% asphalt cement for paving applications. Because of their widespread use in environmental applications, asphalt paving and roofing materials are subject to storm water runoff from rainfall events. This study examines the presence of PACs in the neat asphalt cement as well as the leachate from asphalt. This study reports on analyses for 29 PACs, including the U.S. EPA 16 priority pollutant PAHs and additional Persistent BioaccumuIative Toxins (PBT). These require reporting by the U.S. EPA under the Emer- gency Planning and Community Right -to -Know Act (EPCRA) section 313 (3) if certain conditions are met. Benzo[g,h, i]perylene is a separately listed PAC which requires reporting at a much lower threshold. The act also requires reporting if these PACs are released to the environment through air, water, or the land. As such, a thorough understanding of their partitioning in the environment is required. Previously reported studies show very low content of PAHs in the leachate fraction of asphalt (4). Even in reclaimed asphalt pavement from old roads, which could contain PAHs from crankcase drippings and tire abrasion, studies have found that recycled asphalt pavement (RAP) is nonleachable for the EPA's 16 standard PAI-Is (5). Other in- vestigations (6-8) concerning leachability of road materials indicate that the PAFf concentrations were near or below detectable limits. This study reports the 16 standard PACs, but fOCLISeS on the analysis of an OCILTMilWfirur P4Cc in : t.VVILrlt ? 19 extended list of PAC's (13 additional compounds not listed before and required by E:PCRA), for both the raw asphalt material and its coire- sponding leachate. The significance of these compounds and their envi- ronmental fate are related to their properties, some of which commonly require metabolic activation to produce reactive intermediates before they can express their toxicity, mutagenicity, and carcinogenicity (9). A few compounds on the list are not considered carcinogenic (phenan- threne) or the status is unknown (chrysene has mixed reviews). Others, such as benzo[u]pyrene, have been extensively studied and are classified as known carcinogens. Since these studies were performed on virgin asphalt materials, it does not address spills from traffic and equipment that can lead to leach- ing of these compounds from other sources which could be released from pavement during storm water runoff. The presence of some of these compounds like 3-methylcholanthrene and 1-nitropyrene would not be expected in neat asphalt, but are on the EPCRA list for other RECEIVEDIDENRIDWR materials. EXPERIMENT Specimens Six paving asphalts were obtained tiom the Strategic fligbway Re- search Program (SHRP) library. SHRP was a $150 million research study of asphalt sponsored by individual State Departments of Transpot•tation across the United States. The SHRP library stored samples of asphalt ce- ments from petroleum refineries throughout the United States. These six paving asphalts are produced from single -source crudes rather than mix- tures and represent a significant portion of the composition variability in asphalt cement produced commercially in the United States. Four roofing asphalts were obtained from different regions of the United States from commercial sources of roofing asphalt for built-up roofs. Precipitation of Asphaltenes for Extraction of PACs from Asphalt Asphaltenes are a component of asphalt, defined by ASTM as solu- ble in carbon disulfide but insoluble in paraffin naphthas. This compo- nent is comprised of polynuclear hydrocarbons of molecular weight up to 20,000..joined by alkyl chains (10). It is precipitated and removed to minimize extraction and analytical complications. Asphalt samples OCT 10 2014 Water Quality Permitting Seeccttion 20 A..1. Kric'c-11 c t a/. (--0.4 g) were weighed into a 50 nil- beaker. then dissolved in 10 ml_ of methylene chloride. This was quantitatively transferred to a 100-mL volumetric flask and brou(,ht to the mark with hexane. lifter mixing, samples were allowed to settle overnight prior to aliquot removal for centrifugation and subsequent cleanup. 'this procedure is similar to the one outlined in ASTM D 4124-97 (10). CN/Si Cleanup Procedure (Extraction Method A) This cleanup procedure was initially used since the combination of a cyanopropyl and silica gel chromatographic separation scheme has been shown to be successful for the EPA list of 16 PAHs in asphalt fumes (11). Twenty milliliters of the above hexane solution were concentrated to 2 mL, then passed through a cyanopropyl cartridge and eluted with hexane to 25 mL. This fraction was concentrated to 2 mL, then taken through a silica gel cleanup using'' g of silica baked at 270'C for 2 hr. Twenty milliliters of hexane was used to elute the aliphatic portion of the samples (this fraction discarded), and 20 mL of methylene chloride was used to elute the PAC fraction. Acetonitrile/Methylene Chloride Liquid/Liquid Extraction (Extraction Method B) This extraction procedure was designed to replace Extraction Method A, since dibenz[u j jacridine did not survive the silica gel cleanup and to attempt to minimize the aliphatic background prevalent even after Method A's cleanup. After centrifugation, 20 mL of the hexane/methy- lene chloride solution (90/ I 0) was transferred into a 40-m L via]. Ten milliliters of 20% methylene chloride in acetonitrile (ACN) was added, then the vial was manually shaken for 2 min. After centrifuging, the bottom layer was transferred to a new 40-mL vial. Using 5 mL of the 20% methylene chloride in ACN solvent, this step was repeated twice. The combined extracts were concentrated to slightly under 1 mL using a nitrogen evaporation system at 54'-59°C. For all asphalt samples, two phases formed after settling overnight. The exact composition of the bottom phase was not investigated, although it is believed to contain high -molecular -weight non -"GC able" material. The top ACN phase was removed and brought to a final volume of 1.0 nil- in ACN. For simplicity, this method will subsequently be referred to as the ACN Method B. DMSO Method (Extraction Method C) This method is a modification of a method previously developed (IP346/80) (12) for extraction of Polycyclic Aromatics in Petroleum Fractions by Dimethylsulfoxide (DMSO). T%N.-enty milliliters of the orig- inal hexane solution after asphalt precipitation was concentrated to 5 mL and extracted in triplicate with 2.5 mL of DMSO. Ten milliliters ofwa- ter was added to the DMSO extracts, which was then back extracted twice with isooctane, 5 mL first, and then 2 mL. The combined isooc- tane layers were extracted in triplicate into 2.5 mL of DMSO as before. The DMSO was diluted with water and back extracted three times into isooctane. This isooctane extract was concentrated to 1.0 mL, then an aliquot combined with internal standards (chrysene-d12 and perylene- d>>) for GC/MS analysis. Surrogates could be added prior to extraction but were not added in this study. Leachate Procedure Samples of 10 asphalts were frozen to facilitate breaking the asphalt into small enough pieces to pass through a 9.5-mm sieve. Samples were leached according to SW846 1311. Toxicity Characteristic Leaching Procedure (13), which is designed to emulate what goes on in the envi- ronment. This TCLP test is a batch leaching prescribed by the EPA to determine whether a solid waste is hazardous by toxicity characteristic. One hundred grams of the sieved asphalt material were tumbled for 18 h in 21 of p1l 4.93 buffered solution (acetic acidisodium hydroxide mix). Extraction of Leachate Water for PAC Analysis Method SW-846 3510C (14) (Separatory Funnel Liquid -Liquid Ex- traction) was used for the extraction of the Leachate waters. This method involves three triplicate extractions of the water with methylene chlo- ride under neutral, basic, and acidic conditions. The base/neutral and acid extracts were combined prior to concentration to 1.0 mL in methy- lene chloride. Analytical Method for EPA's 16 PAHs EPA SW846-8270 B (15) was used for the analysis of the leachate water extracts and the total asphalt extracts for 8 of the 29 PAC's reported (those not on the EPCRA list, but on the EPA's list of 16). Program Modifications for GC'/.N— iS Analysis of 22 EPCRA Section 313 Compounds Using a Varian Saturn 4 GCINJIS/MS, the column (a 25 m x 0.25 mm ID BPX5 0.25 micron film SGE Cat # 0541 13) was held at 150 C for 3 min and then increased to 300 ' C at 10'/min and held for 15 min, then increased to 320 -C at 2'`/min kept for 2 min. With a CT 8200 autosam- pier, the solvent plug 0.2 M L with upper and lower air gap and sample volume of 2.0 pl- was programmed with air-dry after wash at an in- jection rate of 5.0 IA/sec and hot -needle time of 0.04 min. The mass range was 100 to 410 m/z and the scan time 0.600 sec, segment length 30 min, filament delay 2.70 min, mass defect 40 mp/100 14, and back- ground mass 98 miz. Most importantly, the injector was at 320°C (de- activated 1078 glass insert with glass wool -Varian Cat no. 392611953), transfer line at 325°C, and the trap temperature at 285' C. An internal standard quantification procedure was used. A total of seven calibration standards (dilutions of a custom mix prepared by AccuStandard, USA) were analyzed to provide a concentration range of 0.1 to 10 pg//tL. Figure I shows a chromatogram of the 22 compounds on the EPCRA l::aw.tt..urtu+ :•lot r.Ca: 0 ^tttntiun: 3EI.HH PIC* 1419 nns3cs IW-105 Plat td+' 1,ififl t.;, ZGt,N W%nyr:' 1 -n .:fdilt S"HJ.. - '471729 i 13.14115.10 1 910 A i1 �17 2122 13 ? 192o 2324 12 } 1 27 28 29 i ilkUl 1iS3P 2,k�N ?.-ti+i� t 1 .9y 1 � _ �y ' y •':fit g? . cq :\ = C'hrt•sene d-12 H = Perylene d-12 FIGURE 1. A chrotnato�,rani of it 10 pgipL calibration standard of the 22 EPCRA compounds. The orcler of elution is outlined in Table 5 for compounds 7 to 29. Oetc•rnnituti ,n ()j P.1 .V in . Js/)holt 521 section 313 list. The linear ranee for most of these compounds was between 0.1 and 10 pg/11 L. _Rvo compounds, I -nitropyrene and 7.12- din»thylbe0zz[ct]antliraccile. prodUced nonlinear curves. The instrument limit of detection is approximately 0.10 pg/pl. for these 29 analytes. Values between 0.05 and 1.0 pgip 1.. are semiquantitative and reported as estimated. GC/MS/MS Analytical Method for Verification of Selected Compounds Using the same system as above, a MS/MS program was developed for selected compounds with mass 228, 252, and 276. The same GC program described above was used. The mass data collection was broken into separate segments by inserting a unique ion preparation method for each molecular ion class. The ion preparation methods are generated by the Saturn software and a unique waveform is applied to the ion trap afterelectron ionization. This waveform ejects all nontarget ions from the trap allowing increased sensitivity. Collisionally induced dissociation by applying a secondary voltage is then used to obtain the fragmentation pattern of the trapped ions. RESULCS AND DISCUSSION Separation and analytical procedures far asphalt materials pose ex- traction and analytical challenges when attempting to find trace quanti- ties of PACs in a primarily aliphatic high -molecular -weight media. It is one of the most complex, difficult materials to chemically analyze, even after cleanup steps and separation techniques are employed (Figure 2). Analytically, the heating zones of the instrumentation were elevated to accommodate the higher -molecular -weight compounds on the EPCRA 313 list. To retain the ion trap at 285` C, glass wool was placed over the trap exterior, taking care to place all cables above the glass wool so the protective coatings would not melt. Initially, a CN/Si cleanup procedure (Method A) was employed and recoveries of these 29 compounds were Similar to the other two extraction methods discussed. Two disadvantages, however, caused the abandon- nient of this approach. First, the dibenz[a,j]acridine did not recover frorn the silica gel cleanup. Second, the injection port liner required frequent chanOng to retain calibration of the instrument. In an attempt to obtain a "cleaner" extract for injection, the ACN (Method B) was developed and analyze recovery for the Laboratory Control Standard (LCS) and a A. 1 Kilc•ch et al. .n .. _..5: +.:� � i�,! .•:ti-/:7t�1-1!\i4.'. !i+:..d:; _iit.. t: .r. . _ 't': -t�: tf;• !.. •- - il.t•.• II�`�I..i 1�. z. �'`•LZ:1 :C:- 1 '►��:1• rtc#Y* ir-i 14.ilij ji1"' -1111 t' t::1 �.•Irl 1/�Gt4i .:. i,:iir"1 T:.+i:tra' 1 :.r. ;.u:i, ;t:_. S It+te;.•, :Nn:• i i i f r:: � f �� .;tiff � �• � l��i, r'� _ .41M • �.`. FIGURE 2. A chromatogram of paving sample 2. The complexity of asphalt analysis is evident. This injection is of the DMSO extract, which is even cleaner than the corresponding ACN extract. Duplicate Control Standard (DLCS) are listed in Table 1. These control standards are spiked with a solution of standard reference compounds. This was performed in duplicate to obtain replicability data. Sample ma- trix and duplicate matrix spikes are also provided in Table 2 and show the difficulties of recovering the mass 302 compounds. This method elimi- nated the need to run two separate fractions, since the benz[aj]acridine survived this extraction procedure. The injection port liner, however, still required frequent changing to retain calibration. Third, the DMSO Method C was evaluated and tuned out to yield the best extraction ap- proach for this matrix and these analytes. The advantages of the DMSO extraction over the first two methods attempted are twofold, but related. First, the injection port liner did not require as frequent a change as when the CN/Si (Method A) or ACN (Method B) were used. Second, the aliphatic background of the asphalt matrix was greatly reduced and apparent in the chromatogram, allowing better detection of the com- pounds in the samples. Recoveries comparing the DMSO (Method C) and ACN (Method B) PAC fortified sample results are similar and shown in Tables I and 2. The mean of the relative percent difference is 23.3 for the DMSO preparation and 9.9 for the ACN preparation for the lab- oratory control standards and 10.4 (DMSO) versus 15.8 (ACN) for the asphalt sample spikes. 1 'f':ABLE I. Comparison ut'"-b Reco%eries from LabaratOl-V C'untrul Stctndards Taken throuch Txvo Diftcrent Extraction Procedures t Method C) I Niethktd I31 REC REC % REC REC EPC'RA section 313 compounds l-CS DI -CS RPD LC'S Dl_C S RPD Fluoranthene 59.7 68.5 13.7 76.3 06.8 13.3 Benzo[a]anthracene 76.4 87.1 13.1 75.1 71.9 4.4 Chrysene 78.6 93.4 17.2 73.9 71.7 3.0 5-Mcthylchrysenc 83.0 92.7 11.0 74.1 69.6 6.3 1-Nitropyrene 90.8 124.5 31.3 85.7 75.3 12.9 Benzo[h]rluoranthene91.8 101.1 2 1. 1 79.1 78.3 1.0 7,12-Dimethylbenzlalanthracene" 204.0 297.9 37.4 32.6 44.3 30.4 Benzo[a]pyrene 89.2 93.1 4.3 78.3 76.7 2.1 3-Niethyleholanthrcnc 63.2 39.1 25.1 71.0 63.8 10.7 Dibenz[a.h]acridine 87.9 94.3 7.0 82.1 82.1 0.0 Dibenz[a j]acridine 82.6 94.3 2.0 83.1 87. 3 4.9 Indeno[ 1,2,3-calpyrene 80.0 94.9 17.0 79.6 77.3 2.9 Dibcnz[a.h]anthracenc 85.9 92.6 7.5 82.2 79.1 3.8 7H-Dibenzule,glcarbazole 19.3 2.4 156 131.1 89.0 38.3 Benzo[g,h.i]perylene 83.6 91.5 9.0 77-4 80.7 4.2 Dibenzo[a,I pyrene 99.8 86.6 3.6 66.9 61.1 9.1 Dibenzo[a,elfluoranthene 86.3 83.2 3.7 80.3 79.0 2.9 Dibcnzo[u.e]pyrcne 83.8 73.9 12.6 93.2 76.6 8.3 Benzo[l;s.11pentaphene 80.2 48.0 49.1 90.8 73.0 21.7 Dibenzo[a,h]pyrenc 65.4 51.1 24.5 86.0 71.9 17.9 Average 83.6 90.5 23.3 79.4 73.7 9.9 Average excluding compounds in bold 77.2 79.6 22.6 81.9 75.3 8.9 Abbreviation: RPD, relative percent difference. "The h. j. and k isomers are not resolved and reported as a mix of Benzo[h]fluoranthcne. "Chromatographic coelution problems with 3 isomers of 252 mass affect precision and accuracy. Three of the mass 252 compounds are not resolved and the 7,12- dimethylbenz[a]anthracene elutes among them, which sometimes causes quantization problems. A different chromatographic column should help to alleviate these complications. Sample results for the raw asphalt (DMSO extraction) are listed in Table 3. Roofing asphalts show the sum of all 29 PACs to be between 4.0 and 23 mg/kg (ppm), with a range of 2.4 to 19 mgr'kg for the EPCRA listed compounds. This includes benzo[g,,h,i]perylene which must be reported separately. Neat paving asphalts show the sum 01- all 29 compounds to be between 1.9 and 66 mg/kg and a range of' TABLE 2. Comparison of Recoveries from Matrix Spikes and Matrix Spike Duplicates Using DMSO and ACN Extracti011s Roofing C Roofing 13 % REC ?,,, REC % REC % REC Average "t-I REC ';(, REC RI:C I', REC Average DNiSO MS D!%'ISO %,ISD DN1SO MS DMSO MSD DMSO recovery ACN MS ACN MSD ACN ?v1S ACN !vISD ACN reemcry Fluoranthcne 71.7 65.8 76.9 76.7 72.8 68.8 70.9 62.7 64.9 66.8 Belmlcrjantlu-acene 79.8 81.4 91.4 87.9 85.1 74.7 82.3 74.9 76.", 77.2 C-'hrysenc 81.8 79.6 92.8 93.8 87.0 73.4 78.4 73.6 69.0 7:.6 5-Methylchryscne 78.5 83.3 87.1 94.4 95.8 73.7 96.7 74.0 7 ".1 76.9 1-Nitr•onyrene 71.3 99.9 45.3 42.8 64.8 30.0 39.2 79.5 65.4 53.5 Benzolhllluoranthcnc" 80.7 S3.1 89.9 91.3 80.3 69.1 77.9 70.4 b7.9 71. 7,12-DinicthylbenzialanIbracene'' 201.2 225.6 192.7 205.9 206 19.3 18.3 17.1 2(l.1 18.7 Benzo(ulpyrene 85.8 82.0 90.6 82.7 85.3 62.8 80.4 56.3 5 7.4 64.2 3-Mel hylcholmillirenc 32.0 52.3 82.3 76.2 60.7 44.7 46.8 47,0 49.5 47.0 Dibenzla,hjacridine 82.2 82.9 68.4 60.4 73.5 40.1 55.1 50.6 46.5 48.1 D'sben z(a,/'jacriditic 71.5 69.7 53.7 45.8 60.2 44.8 51.2 51.3 45.3 4.9,2 lndeno(1,2,3-ctjpyrcnc 76.7 76.4 37.7 57.8 62.2 43.5 50.6 44.1 37.6 44.0 DibenzIu,hjanIIiracctie 84.3 78.1 75.2 68.5 76.5 54.1 52.3 53.9 48.3 53.? 71-f-Dibenzole,gIcarbazole`- 3.S 3.0 11.5 9.0 6.7 57.8 58.7 97.8 78.2 73.1 Bcnzo[,U,h.j]perylcnc 79.4 71.1 50.3 67.5 67.1 34.2 42.5 35.9 32.5 36 l�ibcnzct(n.j]pyrenc G2.4 ?C.9 6G.0 59.(i 61.2 25.1 29.2 27.2 ?3.; 2o.2 Dibenzo(u.e]fluoranthene 42.9 42.1 47.1 41.5 43.4 18.2 21.7 25.7 18.5 21.i1 Dibenzo[melpyrenc 36.2 33.9 45.1 40.4 38.9 17.1 22.3 21.9 1 i.5 19.2 13ct170[1:.c./]pesltapltcne 25.4 24.6 26.8 24.0 25.2 15.3 26.9 14.1 10.5 16.7 Dihcnzo[rr.h]pyrene 21.6 23.8 25.9 28.2 24.9 12.6 18.3 15.7 10.9 14.4 Average 68.7 47.4 Average excluding compounds in bold 61.4 48.9 Abbreviations: NIS, matt -ix spike; MSD, nuilrix pike duplicate. "The h..j, and k isomers arc not resoived and arc reported as a tnix of Bcnzo(h]fiuuranthcnc. "Chromatographic coclution hrohicnss with 3 isomers ol'252 mas% afTed precision and accuracy. Low recoveries fix this compound are more apparent in the DMSO cxtruction compared to the AC N extractiun. i2ti 1..I. Kric-c h (,I ell (ABLE 3. Raw Asphalt Results (mg;I:g}- Four Etoufin��,:lici Six Paving PAC's Not tin LPC'RA .,cction 313 list A Roc 1liOIL, !3 i • 1) - � Ri ine 3 1 0 Naphthalene < 1 < 1 <-1 < 1 .-I I t1.6A - ! I < t list. Acenaphthylenc <! : I < I - I _ 1 I ; I i : I - I Acenaphthalene < I <: I : l < I : l :1 < 1 ; 1 < 1 <r I Fluorene 1.2 0.56 < 1 < 1 1.1 -.:1 -. 1 1.8 < 1 0.79 Est. E.S1. Phenanthrene 1.9 1.1 0.74 1.0 9.9 1.7 1.2 30 < 1 9.3 Anthracene r I < 1 < I < 1 1.1 ; I < 1 1.5 -: 1 < I Pyrenc 0.86 < I < I •< 1 3.1 0.64 < 1 9.1 < 1 1.9 Est. Est. EPCRA section 313 list rluoranthen< < I < I < 1 r 1 0.75 <:1 < I < l < I < I Est. Benz[a]anthracenc 0.76 1 < I <.1 1.3 < I •: l 2.0 -. t 0.96 Est. Est. C'hrysene 9.5 2.2 1.8 2.4 6.5 3.2 < 1 12 2.9 4.3 5-Methylchrysene 3.5 0.72 0.82 0.94 2.8 1.1 < 1 9.2 <-1 0.75 Est. Est. Est. Est. -Nitropyrene < 1 < I < I < I .: I < I < I : I < I < I Benzo[b]flauranthene 1.0 < 1 0.62 < 1 1.5 < t < 1 0.74 •< I <. I Est. Est. Benzo[ j)fluoranthene < I < I < 1 < I < I < I < I < 1 <: I < I Benzo(k)fluoranthene < 1 < I < I < 1 < 1 < I < I < l < I -, I 7.12-Dimethylbenz[ul.tnthracene < I < I I < 1 -. ; •: I < 1 -: I -: I < I Bcnzo[u)pyrcne < I < I <. I < 1 3.7 < I < I < 1 :. I 0.34 Est. 3-Methylcholanthrene <: l < I < 1 < 1 7.8 < I < ! ,:1 < 1 < ! Dibenz(u.h)acridine < l < I < 1 < 1 < 1 : ! < I I <. I <. I Dibenz[a j]ucridine < I < 1 < 1 < I < 1 < I < I < I -- I < I Indeno[ l ,2,3-rd1pyrene < I < 1 < 1 < ! < I < 1 < I < 1 < I < I Dibenz[a,h)anthracene 0.59 < I < 1 < 1 < 1 < I < I : l < I < I Est. 711-Dibenzu[c g)carbazole < I <. I < I < I <- I : i < 1 : I < I :- I BenzoLg.hj]perylene 1.4 0.65 < 1 0.89 2.4 < 1 < 1 < 1 1.0 < 1 Est. Est. Dibenzo[a,npyrene < I < l < l < I < 1 < I < I < I .-1 < I Dibenzo(a,e]Huorunthene < I < I < 1 < I < 1 < i < I : I < I < I Dibenzo(u.elpyrene < l < 1 < I < I - 1 < 1 < I : I I < I Bcnzo[r.mjl-wmaphene < I < I <. I < I ; I : I - I - I ; I < I Dibenzo[o.lt]pyrene < I - I <. I < I -: I < I < I =: I < I < 1 Total of 29 PAC's . 23 4.1 4.0 5.2 43 6.6 1.9 (,6 .j.9 19 detectables only Total of FPC•RA list only 19 2.4 3.3 4.2 2K 4 Z NI) 24 39 6.5 Abbreviation: Est., estir rates. detectablc but bcl,)%v calibration. nondetectable to 28 Ing/kg for the FPC RA list. Since the samples had been taken through two different extractions, these results were com- pared and show (food agreement. The primary detectable compounds of benz[a]anthracene, chrysene, and 5-methylchrysene are listed in Table 4 showing these comparisons. The 3-tnethy1cholanthrene «vas detectable in only one sample, but its mass spectrum was a good match. The M- I ion at 267 was 34% for the standard and 37"Xi f'or the sample. Also, the 253 ion was 53% and 49% respectively. Quantitation of this com- pound may be skewed high, as there were shoulders on both sides of the peak. The presence of 3-methy[cholanthrene is not understood, since 3-methylcholanthrene is a synthetic compound and therefore not likely to be in the neat asphalt. Structures for these 29 PACs are readily available in the literature (16). Their presence in the neat asphalt and leachability appear to be varied with different types of asphalt. Three of the 252 mass com- pounds are not baseline resolved and are integrated as one peak re- ported as benzo[h]fluoranthene (j and !, isomers included). The 7,12- dimethylbenz[a]anthracene (mass 256) elutes at a similar retention time and chromatographic problems are evidenced in the recovery data. The 7H-dibenzo[c,g]carbazole was also problematic. Recovery of the mass 302 compounds dropped off with all three: methods of extraction and seemed to vary depending on which sample was spiked. The sample extracts ranged in color from light yellow to pink and varied in intensity as well as PAC concentration. Little data on these PACs in asphalt are found in the literature to compare with the data in this study. Malaiyandi et al. showed results for only a subset of this list detennined by HPLC (17). Even though HPLC with fluorescence detection is a sensitive analytical technique, HPLC suffers from two problems. One is that matrix problems with complex mixtures such as asphalt may lead to high reported values. Second, it is difficult to verify the identity without a spectroscopic technique. Analysis of the leachate samples by HPLC would be suitable, since the chromatograms are relatively clean. For asphalt, however, the complex background inhibits the identification and quantification, which could easily be in error using HPLC. . Leachate results are presented in Table 5 for the 10 asphalt samples tested. Results for all 29 compounds are below the regulatory limit, with only two results above the detection limits of 0.1 ppb. A few samples contain results reported as estimated data (detectable but below the cal- ibration). One sample (Paving 3) had a result of 0.18 �tg/L (ppb) of naphthalene. Another sample (Paving 1) had 0.1 pg/L of phenanthrene, which is right at the detection limit. All four roofing samples and three P TABLE 4. Sample Results (mgAg) Comparing Both the DMSO and ACN Extraction Procedures C'umpound DMSO ACN DMSO ACN DMSO ACN DNISO ACM DMSO AUN PO 64-22 Roofing A Rooling 13 Roaring C: Rooting D Bun/jaj.uitluacenc 0.96 < 1 0.76 0.88 --- C:hrysene 3.6 2.6 9.5 7.9 2.2 2.2 1.8 1.6 2.4 1.7 5-7.v1cthy1c1uryscnc 1.2 1.0 3.5 2.5 0.72 < 1 0.82 1.3 0.94 ,• I Paving I Paving 2 Pavino 4 Paving 5 Paving 6 Bcnz(a janthcaCelle 1.3 2.9 - - _ 0.96 < I C hivscnc 0.5 7.0 3.2 3 12 16 2.9 3.5 4.3 3.2 5-Mcilivlchrysene 2.8 5.5 1.1 1.7 9.2 11 -•- 0.75 1.9 11 1���lNr;l►%milioil uJ /'.1 CS lt► _ J yllf;h TABLE 5. Quantification lots, Retention Times. and Leachatc itesult: f01- Docctable Samples Relative PAC riot an order of 1:PCRAsection Quant. Retention elution 1131 list ion lime (min) Paving Pavia;;, Paving 1 ? 4 (mg4iter) I Naphthalene 128 0.67 <0.1 0.18 <0.1 ? Acenaphthylene 152 12.11 <0.1 <0.1 <0.1 3 Acenaphthalene 154 12.69 <0.1 <0.1 <0.1 4 Fluorene 165 14.15 <0.1 <0.1 <0.1 Phenanthrene 178 16.66 0.1 <0.1 0.06 Est. 6 Anthracene 178 16.76 <0.1 <0.1 <0.1 9 Pyrene 202 20.20 <0.I <0.1 <0.1 EPCRA section 313 list" 7 Fluoranthene 202 11.02 <0.1 <0.1 <0.1 9 Benz[u]anthracene 778 14.39 <0.1 <0.1 <0.1 10 Chrysene 228 14.50 <0.1 <0.I <0.1 II 5-tilethylehrysene 242 15.54 <0.1 <0.I <0.1 12 I-Nitropyrene 247 15.65 <0.1 <0.I <0.1 I3 Benvo[h]fluoranthene 252 16.81 <0.1 <:0.1 <0.1 14 Benzo[ j]fluoranthetic 252 16.81 <0. I <0.1 <0.1 I Benzo[k]fluoranthenc 252 16.81 <0.I <0.I <0.I 16 7.12-131tnethylbenz[c;]- 256 16.89 <0.1 <0.I <0.1 anthracene 17 Bcnzo[ajpyrene 252 17.47 <0.1 <0.I <0.I 18 3-Methylcnolanthrene 268 18.26 <0. I <0.1 <0.1 19 Dibcnz[u.h]acridine 279 19.39 <0.1 <0.1 <0.1 20 Dibcnz[u.j]acridinc 279 19.48 <0.1 <0.1 <0.1 21 Indeno[1.2,3-cxdlpyrene 276 19.87 <0.1 <0.1 <0.1 22 Dibenz[a,h]anthraccnc 278 19.92 <0.1 <0.1 <0.1 23 7H-Dibcn7o[c,glcarba7ole 267 20.39 <0.1 <0.1 <0.1 24 Benzo[ .h.rlperylene 276 20.45 <0.1 <0.1 <0.1 25 Dibenzo[u.l]pyrcnc 302 23.53 <0.1 <0.1 <0.1 26 Dibcnzo[a,e]fiuoranthene 302 24.57 <0.I <0.I <0.1 27 Dibenzo[a.elpyrene 302 24.64 <0.i <0.1 <0.1 28 Bettzo[,:s,i]pentaphene 302 24.96 <0.1 <0.1 <0.1 29 Dibenzo[a.hlpyrene 302 25.20 <0.1 <0.1 <0. I \'n;c,. All four roofing asphalts were nondetectable (ND) for all 29 compounds. 'rhree or six pay Zug asphalt samples were also ND. " \ separate analytical limeram was designed for thla list. 5 32 : 1-1 kt'1 t'd h c/ (it'. TABLE 6. Learhate Recovery Data ltlr FPC'RA Section 313 C'ompoutids EPCRA section 3 13 compounds LCS DLCS "4, RPD Huoranthene 95.4 86.7 9.5 Ben7(0]anthracene 96.9 101.7 4.8 Chzysene 96.6 94.3 2.4 5-Methylchtysene 101.5 103.1 13 1-vitropyrcne 101.8 141.3 32.5 Benzo[b]fluoranthcnc - other isontiers 98.8 95.8 0.3 7,12-Dimethylbenz[u]anthracene 83.5 88.4 5.7 Benzo[u]pyrene 101.6 103.2 1.6 3-Mcthyleholanthrene 100.1 110.0 9.4 Dibenz(a.h]acridine 94.1 98.9 5.0 Dibcnz[a j]acridine 93.9 102.2 83 Indeno[ 1.2,3-calpyrene 95.0 99.1 4.2 Dibenz[a,h]anthracenc 93.1 100.7 7.9 7H-Dibenzo[c•,gjcarba7o1e 111.2 121.E 8.9 Benzo1g.0]petylen: 93.1 93.9 0.7 Dibcnzo[a.1]pyrene 86.9 102.8 16.8 Dibenzo(ax]fiuoranthene 90.1 107.8 17.9 Dibento(o.elpyrene 88.2 102.9 15.4 Benzo[rs.t]pentaphene 88.1 103.7 16.2 Dibenzola.h]pyrene 84.4 108.5 25.0 Average 94.7 103.3 9.7 The LCS was spiked at 2.0 u.L,,'L and the DLCS spiked at 4.0 of six paving samples showed no trace of any of these PACs. None of the EPCRA 22 PACs were found in the leachate of any asphalt. Recoveries within a leachate matrix laboratory control standard (LCS) are shown in 'Fable 6. Excellent recoveries and repeatability for most compounds are demon- strated, with the relative percent difference (%RPD) being under 20%, for all compounds except I-nitropyrene, which showed 141.3% recov- ery for the Duplicate Laboratory Control Standard (DLCS) and a 32.5% RPD. Eight of the traditional 16 PAH compounds not within the EPCRA section 313 list were also tested for recoveries and repeatability with all results between 101.211'0 and 124.6% recovery and RPDs all below 501(,. Results for the leachate samples are consistent with previous data (5-8), although data for the bulk of the EPCRA section 313 list has not been previously studied in asphalt or their leachates. Finally, the ttse of GC/MS/MS to validate the presence of these low levels was pursued. The GUMS mass spectra were sometimes not 19 TABLE 7. GC/MS/MS Results on Selected Masses (m,rikg) Mass Compound Roofing A GC/M5 h1S GOIMS Paving 1 GC'/MS-Y1S GUMS Paving 4 Oc"MS/MS GCNIIS ?28 Benz[a)anthsaccne 0.94 0.76 3.9 1.3 2.8 2.0 228 ChrYscnc 4.9 9.5 8.5 6.5 12.0 12.0 252 Benzo[b]tiuroallthene 0.92 1.0 1.9 1.5 + 0.74 252 Berszo[k]fiuorantilcnc - < 1.0 1.5 < 1.0 + < 1.0 232 Benzo[a)pyreslc <0.5 < 1.0 3.4 3.7 + < 1.0 276 Indeno[ 1,2,3-ccl] pyre nc 0.40 < 1.0 2.5 < 1.0 _ < 1.0 278 Dibenz[u,hjatlthracene 0.75 0.59 - < 1.0 - < 1.0 276 Benzo(g.lU)pctvlcnc 1.9 1.4 3.2 2.4 0.38 1.0 4-, Detectable but not quantifiublc; -. Nondclecttd. C- ;4 A. I Knt' h (�t u/. definitive when concentrations were too low relative to the background. The GCi`MS.:MS teclmicltte improx ed the sensitivity by a factor of about 10 for the masses investigated, providing more definitive confin-nation for the presence or absence of some of these PACs. Using this technique, Roofing Sample A and Paving Samples I and were further investigated. Results show good agreement with the MS data both qualitatively and quantitatively and are shown in Table 7. CONCLUSIONS Recovery of 29 environmentally relevant polvcyclic aromatic com- pounds from leachate waters is excellent using traditional liquid/liquid extraction (Method SW 846-3510C), with trace levels of naphthalene and phenanthrene in 3 of 10 samples. None of the compounds on the EPCRA section 313 list showed evidence of leachability from the as- phalts tested. None of the roofing asphalts tested leached any of the 29 compounds. The two paving asphalts that do contain detectable levels of naphthalene and phenanthrene are well below drinking water limits. Determination of these compounds in the raw asphalt is, as expected, much more challenging. All three extraction procedures yielded simi- lar recoveries, however the DMSO extraction (Method Q provides the least interferences in the analysis of these 29 PAC compounds. The an- alytical method described here for the nontraditional list of these PACs works well to provide quantitative recoveries of these higher -molecular - weight compounds. GC/MS/MS analyses provided verification of some compounds that were too low to obtain a confirmatory mass spectrum. FUTURE RESEARCH Although none of the EPCRA section 313 compounds appear to be leached from asphalt, literature findings show release of some of these PACs at extremely low levels during the application of hot mix asphalt (18). Collection of data for these same compounds within asphalt fumes from field applications is a key component to their environmental release requiring additional study. REFERENCES 1. U.S. Department ofHealth and Human Services, National Institute fo l-Oecupation,al Salcty and Health, Hazard Review: Health l (%i,cis of Occuptnional EA-p[osure to Asphull (September 2001). 2. lhe.-isphult lnslitwe Alcu7uul Series No. 12 (h2S-12) (November 1976). 27 38. 1�- 1. U.S. [:11% i ronmen 1:11 Protection Agency, Qjfice of InfOrniolimi Anah-sis 1D.C'.. March 1001 f. 1TA "1143-B-01 -OOX 1,Washinglon. D.C. - 4. L.. 'I'liorsenius, (*Tf[Geohgi Pithl. B 434 (1996). T G.'rownscrid. Lea-ching, Charat terisficsof+phah Road 11iiviv. 9S-_1 (Gaines% ille, I. -la.: University offlovida. 1998). h. R. W. Sadecki, G. P. Busackei, K. L. Momiess, K. C. Faru/. and L. G. Allen, An hnpe-v�gation offf-iiier 0itathl- in Runoff from Siockj)ile.s q/'Sc//rqqed Concrille andBilunthrous (Oakdale, Minn.: Nlinnesora Department orri-an-sportitti011. 1996). 7. A. J. Kriech. "Evaluation of RAP as a Clean Fill;' Asphalt 5 (199 1):S. 8. A. J. Kriech, Leachability ql*Asphalt and Concrete Pavements (Indianapolis, Ind.: Heritage Research Group Report, March 1992). 9. R. S. Bliatnagar, Molecular Basis of Envii-onniental ToxicitY (Mich.-. Ann Arbor Science, 1980), ch. 13. 10. American Society for Testing and Materials. ASTM Standard Method D2S87-97. vol. 4.03. ASTM, West Conshohocken, Pa. (2000). 11, A, J. Kriech, J. T. Kurek, L. V. Osborn, G. R. Blackburn. and F. M. l7chsenfeld. -Bio-Directed Fractionation of Laboratory --Generated.: Asphalt Funks: Relation- ship between Composition and Carcinogenicity; Po/%-c.1-c-/l*c- Aromatic Compoundy 14 -15 (1996):189 199. 12. Poh.-c-rclic Aromatics in Pelroleum Fr -actions by DitncthvlSuffiuvide Rqfi-active Index .-Ilethod. ille/hods.ftirAnalv'sis and Riving, vol. 2. IP 3401180 (1985046.1-346.6. 13. EPA Test Methods.fin- Evaluating Solid Mave, SW 846-1311 (Washington, D.C.: Office of Solid Waste and Emergency Response, July 1992). 14, L-P.4 Rm Alethodsjor Evalitating Solid Waste. SW 846-301 OC (XVashington. D.C.: Office of Solid Waste and Emergency Response, December 1996). 1 i. IT-P.4 Test.Wethody.for Eveduabitgo Solid 1+4vie, SW 846-8270B (Washington. D.C.: Office of Solid (Waste and Emergency Response, September 199-1). 16. R. G. Harvey, Po/vcy-clic Aromatic Hvdnocarbons (New York: Wilev-VCH, 1991). 17. M. Malaiyandi, A. Bcnedik, A. P. Holko, and J. J. Bancsi, "Measurement of Potentially Hazardous PolynticlearAromatic Hydrocarbons from Occupational Ex- posure During Roofing and Paving Operations," in Polynticlear A1191nalic Hvdl-0- cai-boRK Physical v-sical and Biological Chemistry Strilt Internaliol tell $yInposillin, ed. M. Cooke, A. J. Dennis, and G. L. Fisher (Columbus, Ohio: Battelle Press. 1992). 471-489. 18. J. Wang, K. M. Lewis, V. Castranova, D. G. Frazer. T. Goldsinnh, S. Torriblyn, J. Simpson, S. Stone, A. Afshari, and P. D. Siegel, "Characterization of Asphalt Fume Composition under Simulated Read Paving Conditions by GC -MS and Microflow LC-Q-TOF MS;' Anal. Chem. 73 (2001).3691--3700. S. Copyright of Polycyclic Aromatic Compounds is the property of Taylor & Francis Ltd and its content may not be copied or emailed to multiple sites or posted to a listsery without the copyright holder's express written permission. However, users may print, download, or email articles for individual use.