United States EPA-905-R97-002bi/f
Environmental Protection Agency May 1997
WASTE MANAGEMENT
Risk Assessment for the Waste Technologies Industries (WTI)
Hazardous Waste Incineration Facility (East Liverpool, Ohio)
VOLUME II: Introduction
U.S. Environmental Protection Agency - Region 5
Waste, Pesticides and Toxics Division
77 West Jackson Blvd.
Chicago, IL 60604
Prepared with the assistance of:
AT. Kearney, Inc. (Prime Contractor; Chicago, IL);
with Subcontract support from:
ENVIRON Corp. (Arlington, VA),
Midwest Research Institute (Kansas City, MO)
and EARTH TECH, Inc. (Concord, MA)
under EPA Contract No. 68-W4-0006
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VOLUME II
INTRODUCTION TO THE RISK ASSESSMENT FOR THE
WASTE TECHNOLOGIES INDUSTRIES (WTI)
CONTENTS
Page
List of Acronyms Used in WTI Risk Assessment iii
I. OVERVIEW I-l
A. Introduction I-l
B. Structure of the Report 1-2
H. FACILITY BACKGROUND II-l
A. Facility Location and Setting II-l
B. Description of Facility II-3
C. Description of Incinerator II-5
HI. RISK ASSESSMENT HISTORY AT WTI ffl-1
A. Introduction III-l
B. Previous Risk Assessments for the WTI Facility III-l
IV. PEER REVIEW COMMENTS AND KEY ASSUMPTIONS IV-1
A. Peer Review Comments IV-1
B. Identification of Key Assumptions IV-4
V. REFERENCES V-l
Volume II
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CONTENTS (Continued)
FIGURES
Figure II-l Location of the WTI Facility II-9
Figure II-2 Vicinity of WTI Incinerator 11-10
Figure II-3 Industrial Operations in the Ohio River Valley
Near the WTI Facility 11-11
Figure II-4 WTI Incinerator Site Plan 11-12
Figure II-5 Schematic of Incineration System 11-13
Figure n-6 Process Flow Diagram 11-14
APPENDICES
II-l WTI Permitted Waste Code List
H-2 Chronology of WTI's Regulatory History
Volume II ii
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LIST OF ACRONYMS USED IN WTI RISK ASSESSMENT
ABS ABSORPTION FACTOR (UNITLESS)
ACFM ACTUAL CUBIC FEET PER MINUTE
ADOM ACID DEPOSITION AND OXIDANT MODEL
AEERL AIR AND ENERGY ENGINEERING RESEARCH LAB
AHH ARYL HYDROCARBON HYDROXYLASE
AIHA AMERICAN INDUSTRIAL HEALTH ASSOCIATION
AIHC AMERICAN INDUSTRIAL HEALTH COUNCIL
APC AIR POLLUTION CONTROL
APCE AIR POLLUTION CONTROL EQUIPMENT
AQUIRE AQUATIC INFORMATION AND RETRIEVAL DATABASE
ARCHIE AUTOMATED RESOURCE FOR CHEMICAL HAZARD INCIDENT
EVALUATION
ARIP ACCIDENT RELEASE INVENTORY PROGRAM
ASL ABOVE SEA LEVEL
ASTM AMERICAN SOCIETY FOR TESTING AND MATERIALS
ATSDR AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY
AWFCOs AUTOMATIC WASTE FEED CUT-OFFs
AWQC AMBIENT WATER QUALITY CRITERIA
BAF BIO ACCUMULATION FACTOR
BaP BENZO(A)PYRENE
BCFs BIOCONCENTRATION FACTORS
BEHP BIS(2-ETHYLHEXYL)PHTALATE
BIF BOILERS AND INDUSTRIAL FURNACE
BLEVE BOILING LIQUID EXPANDING VAPOR EXPLOSION
BMP BIOMAGNIFICATION FACTOR
BPIP BUILDING PROFILE INPUT PROGRAM
BSAFs BIOTA-SEDIMENT ACCUMULATION FACTORS
BTFs BIOTRANSFER FACTORS
BVPSMT BEAVER VALLEY POWER STATION METEOROLOGICAL TOWER
CAA CLEAN AIR ACT
CAB CARBON ABSORPTION BED
CALEPA CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
CARB CALIFORNIA AIR RESOURCES BOARD
CAS CHEMICAL ABSTRACTS SERVICE (REGISTRY NUMBER)
CCMS COMMITTEE ON THE CHALLENGES OF MODERN SOCIETY
CDC CENTERS FOR DISEASE CONTROL
CDD CHLORINATED DIBENZO-p-DIOXIN
CDF CHLORINATED DIBENZOFURAN
CEPPO CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION OFFICE
111
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CES COASTAL ENVIRONMENTAL SERVICES
CFR CODE OF FEDERAL REGULATIONS
C12 CHLORINE
CM CHEMICAL CONCENTRATION IN FOOD
CNS CENTRAL NERVOUS SYSTEM
C02 CARBON DIOXIDE
COMPDEP COMPLEX TERRAIN DEPOSITION MODEL
CWQE CARBONIC WATER QUALITY CRITERIA
ODD DICHLORODIPHENYLDICHLOROETHANE
DDE DICHLORODIPHENYLDICHLOROETHYLENE
DERA DETAILED ECOLOGICAL RISK ASSESSMENT
DFP DI-ISOPROPYLFLUOROPHOSPHATE
DNOP DI(n)OCTYL PHTHALATE
ORE DESTRUCTION AND REMOVAL EFFICIENCY
DSSI DIVERSIFIED SCIENTIFIC SERVICES INC.
EBL ELEVATED BLOOD LEAD
ECOCs ENVIRONMENTAL CHEMICALS OF CONCERN
ECIS ENHANCED CARBON INJECTION SYSTEM
ED EXPOSURE DURATION
EF EXPOSURE FREQUENCY
EHS EXTREMELY HAZARDOUS SUBSTANCES
EPCRA EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
ERA ECOLOGICAL RISK ASSESSMENT
ER-L EFFECTS RANGE-LOW
ERNS EMERGENCY RESPONSE NOTIFICATION SYSTEM
ERPG EMERGENCY RESPONSE PLANNING GUIDELINE
ESP ELECTROSTATIC PRECIPITATOR
ETE EXPOSURE TOXICITY EQUIVALENTS
FDA FOOD AND DRUG ADMINISTRATION
FEMA FEDERAL EMERGENCY MANAGEMENT AGENCY
FI FRACTION INGESTED FROM CONTAMINATED SOURCE
FID FLAME IONIZATION DETECTOR
FR FEDERAL REGISTER
FRV FINAL RESIDUE VALUES
GEP GOOD ENGINEERING PRACTICE
GC/MS GAS CHROMATOGRAPHY/MASS SPECTROMETRY
HC1 HYDROGEN CHLORIDE
HEAST HEALTH EFFECTS ASSESSMENTS SUMMARY TABLE
Hg MERCURY
HHRA HUMAN HEALTH RISK ASSESSMENT
His HAZARD INDICES
HPDM HYBRID PLUME DISPERSION MODEL
HSDB HAZARDOUS SUBSTANCE DATA BANK
HMIS HAZARDOUS MATERIALS INFORMATION SYSTEM
IV
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HQ HAZARD QUOTIENT
HWFAB HAZARDOUS WASTE FACILITY APPROVAL BOARD
IARC INTERNATIONAL AGENCY FOR RESEARCH ON CANCER
ICAP INDUCTIVELY COUPLED ARGON PLASMA
IDLH IMMEDIATELY DANGEROUS TO LIFE OR HEALTH
IEUBK INTEGRATED EXPOSURE UPTAKE BIOKINETIC
IRIS INTEGRATED RISK INFORMATION SYSTEM
ISC INDUSTRIAL SOURCE COMPLEX
ISCST2 INDUSTRIAL COMPLEX SHORT TERM 2
IR FOOD INGESTION RATE
JACADs JOHNSTON ATOLL CHEMICAL AGENT DISPOSAL SYSTEM
Kd SOIL-WATER PARTITIONING COEFFICIENTS
KQC ORGANIC CARBON PARTITIONING COEFFICIENT
KQW OCTANOL WATER PARTITIONING COEFFICIENT
kp PLANT SURFACE LOSS COEFFICIENT
LADD LIFETIME AVERAGE DAILY DOSE
LC50 MEDIAN LETHAL CONCENTRATION
LD50 MEDIAN LETHAL DOSE
LEPCs LOCAL EMERGENCY PLANNING COMMITTEES
LEL LOWEST EFFECT LEVEL
LHS LATIN HYPERCUBE SAMPLING
LOAEL LOWEST OBSERVED ADVERSE EFFECT LEVEL
LOEC LOWEST EFFECT CONCENTRATION
LOCs LEVELS OF CONCERN
MDB MUNITIONS DEMILITARIZATION BUILDING
MEI MAXIMUM EXPOSED INDIVIDUAL
MEK METHYL ETHYL KETONE
MOE MINISTRY OF THE ENVIRONMENT, ONTARIO
NAAQS NATIONAL AMBIENT AIR QUALITY STANDARDS
NATO NORTH ATLANTIC TREATY ORGANIZATION
NCDC NATIONAL CLIMATIC DATA CENTER
NHANES NATIONAL HEALTH AND NUTRITION EXAMINATION SURVEY
NFPA NATIONAL FIRE PROTECTION ASSOCIATION
NOAA NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
NOAEL NO OBSERVED ADVERSE EFFECT LEVEL
NOECS NO OBSERVABLE EFFECT CONCENTRATIONS
NOEL NO OBSERVED EFFECT LEVEL
NIOSH NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY AND HEALTH
NOx NITROGEN OXIDES
NPS NATIONAL PARK SERVICES
NPDES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
NRC NATIONAL RESEARCH COUNCIL
NWS NATIONAL WEATHER SERVICE
NYDEC NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION
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ODA OHIO DEPARTMENT OF AGRICULTURE
OAQPS OFFICE OF AIR QUALITY PLANNING & STANDARDS
OCDD OCTACHLORODIBENZODIOXIN
OCDF OCTACHLORODIBENZOFURAN
ODNR OHIO DEPARTMENT OF NATURAL RESOURCES
ODPS OHIO DEPARTMENT OF PUBLIC SAFETY
OEPA OHIO ENVIRONMENTAL PROTECTION AGENCY
OHM/TADS OIL AND HAZARDOUS MATERIALS/TECHNICAL ASSISTANCE DATA
SYSTEM
ORD OFFICE OF RESEARCH AND DEVELOPMENT
ORNL OAK RIDGE NATIONAL LABORATORY
ORSANCO OHIO RIVER SANITATION COMMISSION
OSTP OFFICE OF SCIENCE AND TECHNOLOGY POLICY
OSW OFFICE OF SOLID WASTE
OSWER OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
PAHs POLYCYCUC AROMATIC HYDROCARBONS
PCB POLYCHLORINATED BIPHENYL
PCDD POLYCHLORINATED DIBENZO-p-DIOXIN
PCDF POLYCHLORINATED DffiENZOFURAN
PCE PERCHLOROETHYLENE
PCI PORTER CONSULTANTS, INC.
PDA PENNSYLVANIA DEPARTMENT OF AGRICULTURAL
PDF PROBABILITY DISTRIBUTION FUNCTIONS
PDNR PENNSYLVANIA DEPARTMENT OF NATURAL RESOURCES
PeCDF PENTACHLORODIBENZOFURAN
PEM PALUSTRINE EMERGENT
PERA PRELIMINARY ECOLOGICAL RISK ASSESSMENT
PFO PALUSTRINE FORESTED
pH (A measure of acidity/basicity)
PHYTOTOX COMPUTER DATABASE OF ORGANIC CHEMICALS & EFFECT ON
PLANTS
PIC PRODUCTS OF INCOMPLETE COMBUSTION
POHCs PRINCIPLE ORGANIC HAZARDOUS CONSTITUENTS
POW PALUSTRINE OPEN WATER
ppb PARTS PER BILLION
PSS PALUSTRINE SCRUB-SHRUB
QC QUALITY CONTROL
RAC REFERENCE AIR CONCENTRATION
RfC REFERENCE CONCENTRATION
RfD REFERENCE DOSE
RCRA RESOURCE CONSERVATION AND RECOVERY ACT
RFC RECIRCULATED FLUE GAS
RREL RISK REDUCTION ENGINEERING LABORATORY
RTECS REGISTRY OF TOXIC EFFECTS OF CHEMICAL-SUBSTANCES
VI
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SAB SCIENCE ADVISORY BOARD OF THE U.S. EPA
SARA SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986
SCC SECONDARY COMBUSTION CHAMBER
SCS SOIL CONSERVATION SERVICE
SERA SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT
SETAC SOCIETY OF ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY
SF SLOPE FACTORS
SLC SCREEN LEVEL CONCENTRATION
SOx SULFUR OXIDES
SRE SYSTEM REMOVAL EFFICIENCY
STORET STORAGE AND RETRIEVAL OF WATER-RELATED DATA
TANKS2 U.S. EPA TANK CALCULATION PROGRAM
TCDD TETRACHLORODIBENZO-p-DIOXIN
TEF TOXICITY EQUIVALENCY FACTOR
TEQ TOXICITY EQUIVALENT
TFE TRIFLUOROETHANE
THC TOTAL HYDROCARBON
TOC TOTAL ORGANIC CARBON
TSDF TREATMENT, STORAGE AND DISPOSAL FACILITIES
UBK UPTAKE BIOKINETIC
UCL UPPER CONFIDENCE LIMIT
USDC UNITED STATES DEPARTMENT OF COMMERCE
USDHHS UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES
USDOE UNITED STATES DEPARTMENT OF ENERGY
USDOT UNITED STATES DEPARTMENT OF TRANSPORTATION
USEPA UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
USFWS UNITED STATES FISH AND WILDLIFE SERVICE
USGS UNITED STATES GEOLOGICAL SURVEY
USLE UNIVERSAL SOIL LOSS EQUATION
USPCI UNITED STATES POLLUTION CONTROL, INC.
UST UNDERGROUND STORAGE TANKS
VOC VOLATILE ORGANIC COMPOUNDS
VOST VOLATILE ORGANIC SAMPLING TRAIN
WTI WASTE TECHNOLOGIES INDUSTRIES
WVDNR WEST VIRGINIA DEPARTMENT OF NATURAL RESOURCES
VII
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I. OVERVIEW
A. Introduction
Waste Technologies Industries (WTI) received a Resource Conservation and Recovery
Act (RCRA) hazardous waste permit in 1983 to construct and operate a hazardous waste
incineration facility in East Liverpool, Ohio. The facility uses a rotary kiln incinerator for
thermal destruction and can incinerate approximately 50,000 to 80,000 tons of waste annually.
Commercial operation of the incinerator started in 1993.
In 1991, U.S. EPA initiated a comprehensive study of the potential health risks to the
public associated with the facility. Several preliminary assessments of potential human health
risks due to routine stack emissions have been completed since that time.1 In each of the
preliminary assessments, as additional site-specific information became available, it was used
to refine earlier assumptions. The current assessment involves a comprehensive approach
which makes use of extensive site-specific data and information on local population behavior
that were not available in previous assessments.
In November 1993, U.S. EPA released a project plan for this multipathway assessment of
the WTI facility. The WTI Risk Assessment Project Plan (U.S. EPA 1993a) was reviewed by
an independent panel of experts in the fields of combustion engineering, atmospheric
dispersion modeling, exposure assessment, and toxicology. Consistent with the approach
outlined in the Project Plan and with comments from the peer reviewers, three major
components of the assessment were defined: 1) a detailed analysis of human health impacts
from routine emissions, referred to as the Human Health Risk Assessment (HHRA); 2) a
screening ecological assessment of impacts from routine emissions, referred to as the
Screening Ecological Risk Assessment (SERA); and 3) an analysis of the potential impacts
from accidental release scenarios developed based on operations at WTI, referred to as the
Accident Analysis.
1 The preliminary assessments include an evaluation of potential human health risks
associated with inhalation of contaminants released from the incinerator stack performed in
1992 (Preliminary risk assessment of inhalation exposures to stack emissions from the WTI
incinerator, U.S. EPA 1992) and two screening-level analyses of indirect, multipathway
exposure to stack emissions (i.e., exposure to stack gas constituents deposited on soil and
concentrated in the food chain) performed in 1993 and 1994 (U.S. EPA 1993b; 1994).
Volume II 1-1
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The primary objective of the HHRA is to estimate the potential risks to public health due
to routine atmospheric emissions from the WTI facility, particularly risks posed by indirect
exposures associated with contaminant uptake through the food chain.
The SERA is performed as part of the WTI Risk Assessment to determine the potential
significance of risks to ecological receptors (e.g., plants, fish, wildlife) from exposure to
routine emissions from the facility. The SERA for the WTI facility uses conservative
assumptions and approaches designed to overstate risk. Thus, the SERA serves to identify
particular chemicals, .exposure scenarios, and receptors that may be associated with the
greatest potential risks.
The Accident Analysis is performed as part of the WTI Risk Assessment to evaluate the
likelihood and potential off-site consequences of accidents that may occur during operation of
the facility. Because it is not possible to identify and assess all accidents that could
hypothetically occur at the WTI facility, a subset of accidents reflecting a range of severity of
consequence and likelihood of occurrence are evaluated. The results of the analysis provide a
basis for evaluating the adequacy of existing accident prevention measures and emergency
response procedures.
B. Structure of the Report
As a preface to this assessment, this volume (Volume n) provides a description of the
facility, and its location and setting in the three-state area of Ohio, Pennsylvania, and West
Virginia; an overview of previous risk assessments conducted by U.S. EPA for this site,
including the preliminary assessment of inhalation exposure and the screening-level risk
analyses of indirect exposure; and a summary of comments provided by the Peer Review Panel
on the Project Plan.
To assess the potential for adverse effects of facility emissions on either human health or
the ecosystem, the nature and magnitude of chemical emissions from the facility has to be
characterized and the atmospheric transport of these emissions to downwind receptors has to
be quantitatively described. Volume HI of this assessment presents the results of the emissions
characterization. Volume IV describes the selection of an atmospheric transport model, the
input parameters used in the model, and the results of air dispersion and deposition modeling
of facility emissions. The results presented in Volumes III and IV are subsequently used in
characterizing exposure for routine stack and fugitive emissions to human and ecological
receptors in the site vicinity.
The results of the WTI Risk Assessment are contained in three volumes as follows:
Volume II 1-2
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• Volume V: Human Health Risk Assessment (HHRA)
The HHRA is designed to provide estimates of: (1) individual risks based on central
tendency exposure; (2) individual risks based on maximum environmental
concentrations; (3) risks to highly exposed or susceptible subgroups of the
population (e.g., subsistence fanners and school children); (4) risks associated with
specific activities that may result in elevated exposures (e.g., subsistence fishermen
and deer hunters); and (5) population risk. This is achieved by evaluating the area
that is most affected by facility emissions and identifying subgroups to characterize
the population in the area. This approach allows for the estimation of risks to
specific segments of the population taking into consideration activity patterns,
number of individuals, and actual locations of individuals in these subgroups with
respect to the facility. The fate and transport modeling of emissions from the
facility to estimate exposures to identified subgroups is described in Volume V and
the associated appendices. As part of this process of characterizing human health
risks, uncertainties are described qualitatively and quantitatively.
• Volume VI: Screening Ecological Risk Assessment (SERA)
The SERA includes an evaluation of available biotic information from the site
vicinity to provide a preliminary description of potential ecological receptors (e.g.,
rare, threatened and endangered species; migratory birds; and important game
species), and important ecological habitats (e.g., wetland areas). A conceptual site
model is developed that describes how stressors associated with the WTI facility
might affect the ecological components in the surrounding environment through the
development and evaluation of specific ecological endpoints. Finally, an estimate of
the potential for current and/or future adverse impacts to the biotic component of
the environment is provided, based on the integration of potential exposures of
ecological receptors to WTI emissions and toxicological threshold values.
• Volume VII: Accident Analysis
In this part of the assessment, several accident scenarios are identified that could
result in significant releases of chemicals into the environment. These scenarios
include ruptures of storage tanks, large magnitude on-site spills, mixing of
incompatible wastes, and off-site releases caused by transportation accidents. In
evaluating these scenarios, both probability and consequence are assessed, so that
likelihood of occurrence is coupled with magnitude of effect in characterizing short
term risks.
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H. FACILITY BACKGROUND
A. Facility Location and Setting
The WTI Hazardous Waste Treatment Facility is located approximately 30 miles (50
kilometers) northwest of Pittsburgh on the Ohio River in East Liverpool, Columbiana County,
Ohio, as shown in Figure H-l. The facility is located directly across the Ohio River from
West Virginia and less than a mile and a half west of the Pennsylvania-Ohio border. In the
immediate vicinity of the WTI facility, the area is mixed residential and commercial, with
some light industrial activity present.
The WTI facility is situated on 21.5 acres of land adjacent to the Columbiana Port
Authority Facility property. The WTI facility and the Port Authority tract of land is zoned for
general industrial activity. The site is bordered on the north by Conrail railroad tracks, on the
west by GRH Co., an industrial supply company, and Environmental Computer Systems, and
on the south and east by the Ohio River. The area immediately surrounding these properties is
zoned medium-high-density residential use. Much of the local residential property, which
includes an elementary school (East Elementary School), is located on a terrace approximately
1,000 feet north of the site and at a ground elevation approximately 50 feet higher than that of
the site. Figure H-2 shows the general area and topography in the immediate vicinity of the
WTI facility.
The Ohio River forms the Ohio/West Virginia border immediately south of the site and is
approximately 1,200 to 1,500 feet wide along this stretch. The topography of the area is
gently rolling, except in the immediate vicinity of the site where the Ohio River forms a steep
river valley oriented in the east northeast direction. Considering the local and regional
topographic elevations near the site, it is likely that winds are channeled along the valley, with
predominant wind flow to the east northeast.
The region of Ohio, West Virginia, and Pennsylvania in the general vicinity of the WTI
facility is largely rural with scattered beef, dairy, and agricultural farms. In addition, large
tracts of land in this area are reserved for state parks and game lands. The closest towns to
the WTI facility include East Liverpool, Ohio (located primarily west of the facility); Chester,
West Virginia (approximately one mile southeast of the site across the Ohio River); Wellsville,
Ohio (six miles west of the site); and Midland, Pennsylvania (five njiles east of the site).
According to the 1990 census, the population of East Liverpool is approximately 14,000 and
Volume II II-1
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the population of neighboring Chester, West Virginia, is approximately 3,000. The population
of Columbiana County, in which the facility is located, is 108,000, according to the 1990
census. The total population within one, three, five, and ten miles of the site is estimated to
be approximately 3,800, 23,400, 37,600, and 72,300, respectively, based on the 1990 census.
A variety of industrial operations are located in the Ohio River valley in the vicinity of
WTI, as shown in Figure n-3. In East Liverpool/Chester, there are several industrial
facilities, including storage tank facilities, an asphalt roofing plant, and a china manufacturer
(e.g., Ferro Corporation, Mason Color & Chemical Works, Inc., and Homer Laughlin China
Co.). Upriver from the WTI facility, several steel-related facilities operate in Midland and
Shippingport, Pennsylvania. The Midland/Shippingport area, approximately five miles east of
the site, contains a specialty steel operation, several petroleum storage facilities, and nuclear
and coal-fired power plants (e.g., J&L Specialty Products Corporation, Keywell Corporation,
Beaver Valley Nuclear Power Station, and Bruce Mansfield Coal-Fired Power Plant).
Approximately 15 miles upriver from the site in Monaca, Pennsylvania, are located several
more large industrial facilities (e.g., Arco Chemical Company and Zinc Corporation of
America).
Several industrial plants are located downriver from East Liverpool, in the
Wellsville/Stratton area, eight miles southwest of the WTI facility. A large refinery is located
near Wellsville as are several other industrial facilities (e.g., Quaker State Corporation Congo
Refinery, Airco Industrial Gases, and Sterling China Co.). Several miles downriver from
Wellsville is the large W.H. Sammis coal-fired power plant in Stratton, Ohio.
For purposes of assessing the potential impacts of the facility on ecological populations, a
1,250 square mile area around the WTI facility was evaluated. The assessment area is
composed of a mixture of terrestrial, wetland, and aquatic communities. The terrestrial
component consists of (mostly deciduous) forests and woodlots, woody scrub, agricultural
areas, and rural residential or urban areas. Agricultural activities consist mostly of hay
harvesting and livestock farming.
A total of 360 lacustrine and palustrine wetland areas greater than 10 acres have been
identified within the assessment area; numerous wetlands smaller than 10 acres are also
present but were not quantified. In addition, 189 non-intermittent rivers and streams are
present within the assessment area, including the Ohio River. Twenty-five major lakes,
ponds, and reservoirs (more than 20 acres in size) have been identified within the assessment
area. Eight state parks, two state forests, four major wildlife management areas, and
numerous smaller areas (e.g., state game lands) with ecological value are located within, or in
the immediate vicinity of, the assessment area. Due to its large size and the diversity of
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habitat types present, the assessment area supports large and diverse plant and animal
communities, composed of large numbers of plant, mammal, bird, reptile, amphibian, fish,
and other species, some of them rare or endangered.
B. Description of Facility
The WTI hazardous waste incineration system is designed to thermally oxidize hazardous
wastes regulated under Subtitle C of RCRA. The facility contains a single, rotary kiln
incinerator for organic waste destruction, and has a permit for a second hazardous waste
incinerator and an inorganic waste treatment plant. The facility accepts wastes from a broad
range of waste-generating industries located primarily in the Ohio River Valley (WTI 1982).
The WTI facility received construction and operating permits from U.S. EPA, Region 5
in 1983 and from the Hazardous Waste Facility Approval Board (HWFAB)2 in 1984. In
addition, WTI currently holds permits from the Ohio Environmental Protection Agency
(OEPA) divisions of Air Pollution Control and Water Pollution Control. The applications for
these permits contain facility operating information that are applied in this study. The
following information on waste management on-site and incinerator operation was taken from
WTI's application to U.S. EPA for a RCRA operating permit (WTI 1982).
WTI treats liquid, solid, and semisolid RCRA waste in the incinerator. The waste is
shipped to the facility either packaged (in lined boxes, fiber packs, metal cans and drums, or
reusable containers) or in bulk (by dump trucks or truck tank wagons). The facility incinerates
both characteristic hazardous wastes (i.e., wastes classified as hazardous on the basis of
defined hazardous characteristics) and listed hazardous wastes (i.e., wastes identified as
hazardous under RCRA regulations). These hazardous wastes are required to be treated in
accordance with applicable regulations and the facility's operating permits. A more complete
discussion of the types of waste that may be received and treated by WTI is contained in the
facility's RCRA permit application and in the RCRA permit. Appendix II-1 lists WTI's
permitted waste codes. WTI has not been authorized to accept dioxins, asbestos, radioactive
wastes, war gases, or poly chlorinated biphenyls (PCBs) in concentrations exceeding 50 parts
per million. In addition, WTI is not permitted to accept several chlorinated wastes limited
under RCRA as "F" series wastes (F020 through F023, and F026 through F027), nor are "P-
list" (acutely hazardous) wastes currently permitted to be accepted by the facility. Although P-
2 The HWFAB, which was later renamed the Hazardous Waste Facility Board (HWFB), is
a state regulatory body that works in conjunction with the Ohio Environmental Protection
Agency.
Volume II II-3
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list wastes are included in WTI's RCRA permit, incineration of these wastes by WTI has been
prohibited by U.S. EPA until final permit conditions are issued.
Facility operations are conducted in various structures on-site, including a guard house,
administrative and maintenance buildings, truck holding and sampling area, drum processing
facility, organic waste tank farm, incinerator feed building, and the incinerator and its
associated systems. A map of the site that shows these buildings is provided in Figure II-4.
Wastes shipped to the facility are pre-approved and registered on a computerized waste
tracking system. On arrival at the facility, the waste is weighed and the associated paperwork
reviewed to verify compliance with regulatory requirements and consistency with information
previously provided by the generator. The waste is sampled, if appropriate, in accordance
with the facility waste analysis plan and, after approval, directed to the appropriate process
treatment area. The computerized waste tracking system monitors the proper disposition of
the waste by providing handling instructions for waste after it enters the facility until final
disposal.
The general handling and management of wastes received by the facility, prior to
incineration, is described below. Several of these activities have the potential to result in
fugitive emissions.
v
• Containers of bulk materials (solid or liquid) are sampled upon arrival at the
facility.
• Bulk solid wastes are emptied into waste pits, and a clamshell bucket transfers the
waste from the pits into the feed hopper for the kiln.
• Bulk liquid wastes delivered to the facility in tanker trucks are unloaded under a
roof in a diked, concrete area. During unloading, the tankers are purged with a
nitrogen blanket.
• Drummed wastes are unloaded in the drum processing building and the contents are
pumped to tanks in the waste tank farm or to pump-out tanks to the south of the
drum processing building. At least one out of every ten drums of each waste stream
is normally sampled.
• Drums containing non-pumpable liquids (e.g., sludges and^slurries) are extruded,
mixed with pumpable waste, and stored in tanks on the south side of the drum
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processing building. Drums that do not contain free liquid are opened and are fed
directly to the incinerator.
• Waste blending occurs in the indoor tank farm. All waste handling, storage, and
treatment areas are concrete diked and contain collection sumps for the capture of
spilled materials. In addition, all handling areas are serviced by overhead
ventilation hoods that vent to the incinerator or the carbon adsorption bed (CAB)
system.
There are three different waste water systems at the WTI facility: A, B, and C. System
"A" collects uncontaminated storm water from such areas as roofs and the employee parking
lot, and the water is discharged directly to the Ohio river. System "B" collects storm water
from "inactive" process areas such as sumps and plant roadways where contamination is
possible but not normally expected. "B" water is retained in three 200,000-gallon tanks and is
tested prior to discharge to the Ohio River. If required based on the test results, "B" water
would be treated prior to discharge. System "C" collects water from active process areas such
as diked tank areas, washdowns, and other areas where some contact with hazardous waste can
reasonably be expected. "C" water is stored in one 250,000-gallon, open-top tank prior to
treatment and is a potential source of fugitive emissions. Water is treated via sand filtration
and activated carbon, and once properly decontaminated, can be used as process feed water in
the incineration system.
<***
C. Description of Incinerator
WTI, an Ohio partnership, presently owns and operates this facility, with Von Roll
(Ohio), Inc., as managing partner. Von Roll (Ohio), Inc., as well as the other WTI partners,
are each wholly owned by Von Roll America, Inc., which in turn is owned by the Swiss-based
Von Roll AG. Von Roll AG has designed, constructed, and operated hazardous waste
incineration facilities worldwide, including Germany, Austria, Denmark, and Sweden.
The WTI facility is required to comply with all applicable regulations and emissions
requirements governing its operation. Federal and state permits require that hazardous organic
wastes fed to the incinerator be thermally oxidized to meet a destruction and removal
efficiency of at least 99.99 percent. The facility's RCRA permit (U.S. EPA 1983) limits the
heat input rate of the incinerator to less than 97.8 million British thermal units per hour
(BTU/hr lower heat value). On average, WTI expects the incinerator to operate between
7,400 and 7,900 hours per year, with an average yearly mass throughput ranging between
Volume II II-5
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52,000 and 77,000 tons per incinerator. Monitoring of the chlorine and BTU content of the
feed (three-hour operating average) to the incinerator is required to ensure compliance with the
RCRA permit conditions.
The incineration system consists of waste feed mechanisms, a rotary kiln, a secondary'
combustion chamber, a heat recovery boiler, air pollution control devices, a flue gas stack,
slag and fly ash removal equipment, and computerized process control and instrumentation
equipment. Figure II-5 is a drawing of the incinerator system.
The wastes fed to the incinerator are in the form of loose solids, drums and containers,
and liquids. An overhead crane and bucket is used to deliver loose solids to the kiln via a feed
chute that extends into the first zone of the kiln. Drums and containers are pushed by a
hydraulic ram feeder into the kiln feed chute. Finally, the front wall of the kiln is equipped
with five steam-atomized pumpable waste lances, which are used to introduce liquids and other
pumpable slurries into the kiln.
The rotary kiln is a refractory-lined cylindrical shell 15 feet in diameter and 43 feet long
that rotates at approximately 3 revolutions per hour. Wastes enter the rotary kiln and are
oxidized at the internal kiln temperature of approximately 1,800 to 2,200° F. Solids and other
nonburnable wastes generally melt under the intense heat and form a residual viscous slag.
The kiln is slightly tilted to provide a solids residence time of one to two hours. Gases from
the kiln pass to the secondary combustion chamber to provide for greater destruction of
organic compounds.
Residence time in the incinerator, defined as the time required for flue gas to travel from
a point midway down the rotary kiln to the point at which secondary combustion air is injected
into the secondary combustion chamber, is 2.5 seconds. The secondary combustion chamber,
which measures 61 feet high by 21 feet by 22 feet, achieves burnout of residual combustion
material in the combustion gas by providing additional residence time while maintaining the
gas at an elevated temperature. Recirculated flue gas ("RFG") is injected at two different
points within the secondary combustion chamber (referred to as "secondary RFG" and
"tertiary RFG") to increase the destruction efficiency of residual organics in the combustion
gas by increasing mixing. If necessary, fossil fuel may be fired in the secondary combustion
chamber to maintain the temperature. The combustion gases leave the secondary combustion
chamber at a temperature which generally ranges between 1,350 and 1,500° F.
The gas is further cooled as it passes through heat recovery boilers, causing a small
quantity of particles to be removed from the gas stream. The waste heat recovery boiler uses
heat generated from waste incineration to generate steam for plant use. Flue gas exits the
boiler at approximately 700° F (371 ° C).
Volume II II-6
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After leaving the boiler, the combustion gases pass through an air pollution control
system consisting of a spray dryer, an electrostatic precipitator (ESP), flue gas quench, and a
four-stage wet scrubber system, as described below.
• The spray dryer rapidly cools the combustion gases to approximately 385° F
(196° C) using an atomized spray of treated "blowdown" water from the scrubber
system (described below). The scrubber blowdown stream, which at most facilities
would become a waste water requiring discharge, has been eliminated at WTI by
evaporation in the spray dryer. Salts and other residues, which are dissolved or
suspended in the scrubber blowdown stream, become entrained in the combustion
gas stream and are subsequently collected in the ESP (described below). Besides
eliminating the need to dispose of a waste water stream, the evaporation of the
scrubber water quickly cools the combustion gas below the temperature range
believed to be most favorable to the formation of dioxins/furans.
• Dry, powdered, activated carbon is introduced into the combustion gas stream at
two different points in the duct work (the location of these points and the quantity of
carbon injected at each point has been claimed confidential by WTI under 40 CFR
Part 2). Contaminants in the gas stream such as dioxins/furans are adsorbed and
tightly bound onto the surface of the carbon particles, thus reducing the
concentration of these contaminants. Because of the relatively large size of the
carbon particles, they are easily controlled by the particle collection devices
installed at the WTI plant (i.e., ESP and scrubbers). The carbon particles are
captured along with the other dust collected in the ESP, and the fly ash is taken off-
site for further treatment and disposal. The system that introduces the dry activated
carbon into the duct work is referred to as the enhanced carbon injection system
("ECIS").
Because the dioxin/furan collection efficiency of the ECIS is assumed to be directly
dependent on the concentration of activated carbon in the duct work, the RCRA
permit requires that the carbon feed rate be equal to or greater than the rate
recorded during the initial ECIS compliance stack test.
• The ESP removes particles from the flue gas stream bypassing the gas between
electrically charged rods and plates. The electric field attracts particles in the gas
Volume II II-7
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stream and captures them, removing over 99% of the particles. At the WTI facility,
the ESP utilizes a rigid electrode design with each of the three fields (in series)
operating at secondary voltages between 40 and 55 kilovolts. After the ESP, the
flue gas passes through a quench unit, which saturates the gas with water and lowers
the temperature of the gas stream to approximately 170° F. The gas is then drawn
into the scrubber unit.
• The wet. scrubber system is designed to remove acid gases, such as HC1, SO2, and
C12, and residual fine particles from the gas stream. The system is comprised of
two packed-bed scrubbers followed by a venturi scrubber stage. Each of the three
stages is followed by a mist eliminator. The venturi stage is comprised of a
multitude of venturi-type "Ring Jets" for the removal of submicron-sized particles
and aerosols from the flue gases. Sumps for each stage in the scrubber vessel serve
as reservoirs for the scrubber liquor, which is recirculated to the various scrubber
stages and fed to the quench unit. The pH of the liquor being fed to the second
packed bed is adjusted to aid in the control of acidic contaminants such as SO2. In
order to remove contaminants which collect in the scrubber liquor, a continuous
bleed or "blowdown" of scrubber liquor from the first stage scrubber sump is
pumped to a neutralization tank for conditioning (pH adjustment with lime and
treatment with activated carbon) prior to being evaporated in the spray dryer for
evaporation.
Finally, hi addition to the operating parameters and control devices described above, the
waste feed rate and exit gas flow conditions greatly influence the emission rate and dispersion
of flue gas constituents. These process parameters are shown in Figure H-6, and reflect the
facility operating continuously at the permit maximum of 97.8 million BTU per hour at the
design feed rate of 17,780 Ib/hour as provided in the RCRA permit application for the facility.
The flue gas is discharged into the atmosphere at the stack height of 150 feet.
TT TT-8
-------
/ Ohio
/ Pennsylvania
-------
l Ml ! I 1 i il ii .', I h
f <->...' ' . • "'"~ fr~ / I T -.
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VOLUME II
VICINITY OP Wll INCINkRAIOR
FIGURE
-------
o
V
MIDLAND, PA
- J&L SPECIALITY PRODUCTS
- KEYWELL CORPORATION
MONACO. PA
- ARCO CHEMICAL COMPANY
- ZINC CORPORATION OF AMERICA
WTI
Facility
EAST LIVERPOOL, OH
- FERRO CORPORATION
- MASON COLOR & CHEMICAL WORKS, INC.
- WTI
WELLSVILLE, OH
- STERLING CHINA COMPANY
NEWELL, WV "
- AIRCO INDUSTRIAL GASES
- HOMER LAUGHLIN CHINA COMPANY
- QUAKER STATE CORPORATION CONGO REFINERY
E?
SHIPPINGPORT, PA
- BEAVER VALLEY NUCLEAR POWER STATION
- BRUCE MANSFIELD COAL-FIRED POWER STATION
ale in V \\<>n\'Af:t'<
INDUSTRIAL OPERATIONS IN THE OHIO RIVER VALLEY NEAR THE WTI FACILITY
FIGURE
II-3 _
-------
-------
I
•n
M
-------
- too* ftut ctrtcm (MM COM
- MN-KACCIHC RMM emutKM
FIGURE H-6 PROCESS FLOW DIAGRAM OF WTI INCINERATOR
VOLUME II
11-14
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V
ffl. RISK ASSESSMENT HISTORY AT WTI
A. Introduction
Several preliminary screening risk assessments have been conducted by U.S. EPA that
relate to the WTI incinerator. The "preliminary risk assessment" of inhalation exposure (U.S.
EPA 1992), which Region 5 completed in 1992, was conducted prior to the commencement of
commercial operations at WTI and before on-site meteorological data were available.
Successive "screening risk assessments" were conducted which supplemented the initial study
by including refinements as more information became available. These refinements focused on
the chemicals and pathways believed to present the greatest risk and the population subgroups
expected to be associated with the highest levels of risk. Accordingly, in February 1993, U.S.
EPA's Office of Research and Development (ORD) completed a multipathway, screening-level
analysis (U.S. EPA 1993b) of cancer risks from exposures to dioxins and furans emitted from
the facility stack. ORD updated the screening-level assessment (U.S. EPA 1994) in October
1994 based upon data from actual operation of the incinerator and other, limited site-specific
data.
In November 1993, Region 5 prepared a draft Project Plan (U.S. EPA 1993a) for the
conduct of a comprehensive, site-specific, multipathway risk assessment of the WTI facility,
which was peer reviewed by a panel of independent experts hi December 1993. The WTI
Risk Assessment is based upon that Project Plan and the recommendations submitted by the
Peer Review Panel.
This chapter summarizes the results of U.S. EPA's preliminary risk assessments. A
chronology of significant events pertaining to WiTs regulatory history, including WTI's
application for a RCRA permit hi September 1981, the release of the preliminary inhalation
risk assessment in July 1992, and the peer review of the Project Plan for this risk assessment
in December 1993 is presented in Appendix TL-2.
B. Previous Risk Assessments for the WTI Facility
There have been several screening risk assessments that have preceded this analysis, as
described below. The preliminary risk assessment of inhalation exposure (U.S. EPA 1992)
consisted of an evaluation of potential inhalation exposures resulting from stack emissions
associated with normal operation of the WTI facility. Conservative estimates of cancer risks
Volume II ffl-l
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and the potential for noncancer health effects were estimated using the limited site-specific data
available along with generic exposure assumptions.
Operations at the WTI facility had not yet begun when the preliminary risk assessment
was performed. Thus, a conservative approach was adopted in estimating incinerator stack
emissions based primarily on data from operating hazardous waste incinerators. Given the less
sophisticated air pollution control equipment at many of these facilities compared to WTI, it
was assumed that emission estimates derived from these data were a conservative
representation of expected WTI facility emissions. After the preliminary risk assessment was
completed, WTI performed several trial burns and performance tests that provide site-specific
emissions data for use in the WTI Risk Assessment.
Atmospheric dispersion and transport of stack gas emissions were modeled in the
preliminary risk assessment using the COMPLEX-1 and ISCLT air dispersion models and a
combination of meteorological data from Shippingport, Pennsylvania, approximately 5 miles
east of the site, and Pittsburgh, Pennsylvania, approximately 30 miles southeast of the site.
Site-specific meteorological data has since become available from a monitoring location at the
WTI facility and is used in the WTI Risk Assessment.
Exposure in the preliminary risk assessment was conservatively estimated for a
hypothetical Maximally Exposed Individual (MEI) residing at the point of maximum predicted
annual average ground-level air concentration continuously for a lifetime. Specific populations
in the vicinity of the facility and the deposition of constituents onto the ground surface and
subsequent indirect exposure pathways were not considered in the preliminary risk assessment.
"" The results of the preliminary risk assessment are summarized below:
• The maximum estimated inhalation cancer risk for any single organic stack gas
constituent was approximately 1 x ICr6, for dioxins and furans. The risks for the
next most significant organic compound, benzene, was 7 x 10"7. Cancer risks
associated with inhalation of metals were found to be lower than for dioxins and
benzene.
• Adverse noncancer health effects from exposure to organic compounds emitted from
the facility were not anticipated to occur. A similar result applied to the metals,
although the potential for exceedances of the threshold level for lead was identified,
as discussed below.
Volume II ffl-2
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• The threshold level established for lead, based on the National Ambient Air Quality
Standard (NAAQS), was estimated to be exceeded if lead emissions were to occur
continuously at the hourly emission limit specified in the facility air permit3. At
emission rates predicted based on data from operating incinerators, however, the
NAAQS for lead would not be exceeded.
It should be noted that the HHRA presented in this report includes a number of
improvements over the preliminary risk assessment performed for the WTI facility as follows:
• A more sophisticated air dispersion model is used, which incorporates
meteorological data from multiple stations, with data collected at different elevations
above ground surface;
• The assessment uses recently collected site-specific data. In order to provide a site-
specific evaluation, on-site meteorological data were collected, and measurements of
emissions from the stack were made on numerous occasions;
• Several additional subgroups of the potentially exposed population in the vicinity of
the WTI facility are evaluated (e.g., children of farmers and adult residents,
subsistence fishermen, etc.); and
• All potentially significant pathways of exposure are considered, including both
direct and indirect exposure pathways. Direct exposure is defined as exposure
through inhalation; whereas indirect pathways include human exposure to substances
emitted from the facility through consumption of locally grown or raised food
products (e.g., beef, milk, vegetables, fish); contact with surface water and soil
(ingestion or dermal); and ingestion of breast milk by infants.
In January 1993, ORD conducted a screening-level analysis of risks associated with
indirect, multipathway exposure to emissions of dioxin and furan compounds only (U.S. EPA
1993b). Metals and non-dioxin and non-furan organic compounds were not evaluated. The
screening-level analysis used trial burn data to estimate risks from a single year of facility
3 To ensure protection of human health, U.S. EPA subsequently established interim
allowable limits for lead and other metals under the RCRA permit, based partly on the results
of the preliminary risk assessment.
Volume II m-3
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operation. Thus, the analysis was not intended to be an in-depth exposure assessment of site-
specific data regarding locations of potentially sensitive subpopulations and other relevant
information. Similar to the preliminary risk assessment, the screening analysis used a
maximally exposed individual approach based on the highest predicted ground-level air
concentration. Furthermore, various aspects of the fate, transport, and food chain modeling
were performed using conservative approaches and assumptions with the likely result that
actual risks from dioxins and furans were overstated.
The screening-level analysis of indirect exposure was based on air concentrations of
dioxin compounds estimated in the preliminary risk assessment. All other transport and food
chain modeling, and exposure modeling were uniquely generated for the analysis. Four
scenarios were developed: 1) a subsistence farm, where all beef consumed came from home
stock; 2) a "high-end" farm, where a portion of the beef consumed came from home stock; 3)
a residence with a home garden; and 4) a schoolyard. Pathways of exposure included: beef
consumption for the farm scenarios only; vegetable ingestion for the residence and farm
scenarios; and soil ingestion, dermal contact, and inhalation for all scenarios.
Lifetime cancer risk estimates resulting from the limited period of operation were
estimated for each of these scenarios. For the schoolyard and residence scenarios, predicted
cancer risks were found to be less than 10~7. For both farm scenarios, risks were estimated to
be less than 10'7, except for consumption of beef, which was estimated to be in the 10~5 range
for both farm scenarios.
In October 1994, U.S. EPA updated the screening-level analysis of risks conducted in
1993 (U.S. EPA 1994) because additional time was required to complete the current WTI Risk
Assessment based on recommendations of the Peer Review Panel. The update included
additional site-specific information regarding: climatic data, emission rates, and period of
operation. In addition, the analysis was conducted assuming a 2.1-year period of limited
commercial operation (instead of the one year assumed in the initial screening analysis) and
involved a more rigorous evaluation of the fate and transport of dioxin/furan compounds.4
The exposure assumptions and scenarios used in the initial screening analysis remained
unchanged.
These changes to the screening-level risk analysis resulted in an estimated reduction in
predicted risks by more than a factor of ten. Estimated dioxin cancer risks due to consumption
of beef by a subsistence farmer (i.e., assuming 100 percent of beef diet is derived from
4 The dioxin/furan fate and transport modeling used in the screening level analysis is the
same as that used hi the dioxin exposure assessment (U.S. EPA 1994k) and this WTI Risk
Assessment.
Volume II m-4
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livestock raised on a farm at the point of maximum impact) decreased from 4 x 10"5 to 1 x
lO"6 in the updated analysis. Estimated excess cancer risks for other pathways also decreased:
residential and school-yard scenarios were not estimated to exceed 4 x 10'9 and 4 x 1010.
respectively. The farm scenarios did not exceed 2 x 10"8 for any pathway, with the exception
of subsistence farmer beef ingestion, as noted above.
Volume H m-5
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IV. PEER REVIEW COMMENTS AND
KEY ASSUMPTIONS
A. Peer Review Comments
In preparation for conducting the WTI Risk Assessment, a Project Plan was developed
describing the approach and procedures to be applied in estimating exposures and risks and
submitted for peer review (U.S. EPA 1993a). Prospective peer reviewers were nominated by
representatives of government, environmental groups, and industry. U.S. EPA's Council of
Science Advisors, which developed U.S. EPA's peer review policy, selected a group of
scientists with expertise in toxicology, combustion engineering, atmospheric dispersion, and
exposure assessment from the pool of nominees. The peer review was conducted by a panel of
13 independent scientists, who met in open session on December 8-9, 1993. The Peer Review
Panel was specifically charged with evaluating the scientific basis for the risk assessment
procedures described in the Project Plan, to ensure that the resulting assessment reflects sound
scientific principles and methods.
The panel evaluated the technical merits of the Project Plan and prepared comments in
four principal subject areas: combustion engineering, atmospheric dispersion modeling,
exposure assessment and toxicology. Detailed comments and recommendations of the Peer
Review Panel are contained in the report, "Report on the Technical Workshop on WTI
Incinerator Risk Issues" (U.S. EPA 1993c). In conducting the WTI Risk Assessment, a
concerted attempt has been made to incorporate the recommendations provided by the Peer
Review Panel. Major modifications to the proposed risk assessment process that followed
from the peer review recommendations included: (1) additional performance tests to develop
more reliable estimates of emissions from the incinerator stack, particularly for dioxin
emissions; (2) refined dispersion modeling talcing into consideration the complex nature of the
local terrain to obtain better predictions of chemical concentrations hi ah* and particle
deposition onto the ground; (3) an ecological risk assessment; and (4) a comprehensive
evaluation of accidental release scenarios.
In addition to these major modifications, a number of other significant changes were
incorporated to address specific recommendations of the Peer Review Panel. Summary
recommendations extracted from Section 3 of the peer review comments document (U.S. EPA
1993c) are listed below. "
Volume II IV-1
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Combustion Engineering
• Additional incinerator stack testing was suggested to reduce the uncertainty
associated with the organic emission estimation procedure. Alternatively, a waste
feed chemical composition profile could be developed, which can be used to
estimate organic emission rates from an understanding of the combustion chemistry
of the incineration process.
• Several recommendations focused on attempting to resolve the differences in dioxin
emissions measured in the March 1993 trial burn and the August 1993 performance
test and to determine the most appropriate test to use in the risk assessment.
Additional testing of stack emissions for dioxins was also encouraged.
• The existing trial burn data, which provided system removal efficiencies for some
metals, was recommended to be used to develop emissions data for metals that were
not tested (taking into consideration the sources and behavior of different metals
within the incinerator train). In addition, it was suggested that thermodynamic
predictions be used to predict the physical/chemical form of metal emissions.
• In addition to routine incinerator stack emissions, it was suggested that fugitive
emissions, and emissions during upset conditions and accidents, be evaluated.
Modeling/Atmospheric Dispersion
• In developing an appropriate meteorological data set for the air dispersion modeling,
it was suggested that site-specific meteorological observations be combined with
Beaver Valley Nuclear Power Station data collected at multiple elevations.
• Wet deposition estimates were recommended to be refined using local precipitation
data.
• Fumigation conditions and terrain-induced downwash were identified as having the
potential to cause locally elevated concentrations. Further, evaluation of such
conditions by modeling or by conducting wind tunnel studies was suggested.
Volume H IV-2
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• Sensitivity and uncertainty analyses were recommended to estimate the uncertainty
of the model's concentration and deposition outputs.
Exposure Assessment (Human Health)
• Food consumption data could be updated using the most recent survey data on
ingestion rates, supplemented with information from local slaughterhouse, home
garden and fish surveys, to identify the fraction of locally derived food. In
addition, several population groups were identified for possible inclusion as high-
end subgroups.
• Although the high-end approach was deemed adequate for addressing variability, a
tiered approach to uncertainty analysis was suggested to address sensitivity and
uncertainty.
• An evaluation of upset conditions, fugitive emissions, and accidents was
recommended.
• The physical (vapor versus particle) 2nd chemical form of several of the metals was
identified as important in influencing transport.
Toxicology
• In addition to the HHRA, it was recommended that an ecological risk assessment be
conducted.
• Several additional compounds were identified for inclusion in the HHRA, including
benzo(a)pyrene, benzo(b)fluoranthene, chrysene, dibenzo(a,h)anthracene,
fluoranthene, anthracene, heterocyclics, nickel, copper and aluminum.
• A consideration of additive and synergistic effects was recommended when
appropriate data are available.
As discussed above, these comments and recommendations have resulted in additional
testing and analyses being conducted, where possible, as part of the^WTI Risk Assessment.
Volume n IV-3
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Subsequent sections of this report cite specific steps that were taken in addressing the
recommendations.
B. Identification of Key Assumptions
Throughout the WTI Risk Assessment, site-specific data are used to reduce uncertainties
associated with the assessment of risks (human and ecological) and the analysis of potential
accidents. In many cases, however, data are not available and assumptions are required to fill
the resulting data gaps. In addition, there are many assumptions used in this assessment that
are inherent to the risk assessment process or the models or methodologies applied. The
assumptions used in this assessment are identified, and those assumptions potentially affecting
the risk estimates (referred to as "key assumptions") are evaluated. Within each volume of
this assessment, the key assumptions are tabulated as part of the discussion of uncertainties. In
addition, the basis for each key assumption is identified to provide the purpose or reasoning
behind the assumption. Finally, the tables of key assumptions provide an indication of the
potential effect of the assumptions on the risk estimates. A relative estimate of the magnitude
of the effect (low, medium, or high) is indicated, as well as the expected direction of the effect
(overestimate, underestimate, or unknown). In this manner, the tables of key assumptions
indicate the importance of each assumption in terms of the effect on the risk estimates if
alternate assumptions within the plausible range were adopted. It is anticipated that these
tables of key assumptions will assist the reader in evaluating the results of the HHRA, SERA,
and Accident Analysis by identifying the sources of greatest uncertainty.
Volume II
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V. REFERENCES
U.S. Environmental Protection Agency (U.S. EPA). 1983. Hazardous waste management
permit, Waste Technologies Industries. EPA Identification # OHD980613541. U.S.
Environmental Protection Agency, Region 5.
U.S. Environmental Protection Agency (U.S. EPA). 1992. Preliminary risk assessment of
inhalation exposures to stack emissions from the WTI incinerator. Prepared by A.T.
Kearney, Inc., July 1992.
U.S. Environmental Protection Agency (U.S. EPA). 1993a. W77phase II risk assessment
project plan, EPA ID number OHD980613541. Region 5, Chicago, Illinois. Prepared
by A.T. Kearney, Inc., EPA Contract No. 68-W9-0040, Work Assignment No. R05-06-
15. November.
U.S. Environmental Protection Agency (U.S. EPA). 1993b. Memorandum from W. Farland,
Director, Office of Health and Environmental Assessment to B. Grant, Attorney, Office
of General Counsel, U.S. EPA, and G. Goldman, Trial Attorney, U.S. Department of
Justice. Office of Research and Development. Februarys.
U.S. Environmental Protection Agency (U.S. EPA). 1993c. Report on the technical
workshop on WTI incinerator risk issues. EPA/630/R-94/001. December.
U.S. Environmental Protection Agency (U.S. EPA). 1994. Memorandum from W. Farland,
Director, Office of Health and Environmental Assessment to WTI Workgroup entitled:
Update of WTI screening level analysis. October 26.
Waste Technologies Industries (WTI). 1982. Application to the United States Environmental
Protection Agency, Volumes 1, 2, and 3. As revised November 11.
Volume H V-l
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APPENDIX H-l
WTI Permitted Waste Code List
Volume n
Appendix n-1
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EPA Hazardous
Waste Number Description of the Waste
Characteristic Waste:
O001 Waste which exhibits characteristics of ignitabiiity in
accordance with the description in 40 CFR Section 261.21, but
is not listed as a hazardous waste in 40 CFR Section 261
Subparts D
D002 Waste which exhibits characteristics of corrosivity in accor-
dance with the description of 40 CFR Section 261.22 but is not
listed as a hazardous waste in 40 CFR Section 261 Subpart D
D003 Waste which exhibits characteristics of reactivity in accordance
with the description in 40 CFR Section 261.23 but is not listed
as a hazardous waste in 40 CFR Section 261 Subpart D
D004 - 17 Waste which exhibits characteristics of EP toxicity in accor-
dance with the description in 40 CFR Section 261.24 and is not
listed as a hazardous waste in 40 CFR Section 261 Subpart D.
These wastes include the following:
EPA Hazardous
Waste Number Contaminant
D004 Arsenic in excess of 5.0 milligrams per liter
D005 Barium in excess of 100.0 milligrams per liter
O006 Cadmium in excess of 1.0 milligrams per liter
D007 Chromium in excess of 5.0 milligrams per liter
OOOS Lead in excess of 5.0 milligrams per liter
D009 Mercury in excess of 0.2 milligrams per liter
D010 Selenium in excess of 1.0 milligrams per liter
D011 Silver in excess of 5.0 milligrams per liter
VOLUME II
APPENDIX H-l
-------
EPA Hazardous
Waste Number Contaminant
D012 Endrin (1,2,3,4,10,10-hexachloro-l, 7-epoxy-
l,4,4a,5,6,7,S,Sa-octahydro-l, 4-endo, endo-5,
8- dimethano naphthalene) in excess of 0.02
milligrams per liter
D013 Lindane (1,2,3,4,5,6- hexachlorocyclohexane,
gamma isomer) in excess of 0.4 milligrams per
liter
D014 Methoxychlor (l,l,l-Trichloro-2, 2-bis p-
ethoxyphenyl ethane) in excess of 10.0
milligrams per liter
D015 Toxaphene (CioHioClg, Technical chlorinated
camphene, 67-69 percent chlorine) in excess of
0.5 milligrams per liter
DO 16 2,4-D, (2,4-Dichlorophenoxyacetic acid) in
excess of 10.0 milligrams per liter
D017 2,4,5-TP Silvex (2,4,5-
Trichlorophenoxypropionic acid) in excess of
1.0 milligrams per liter
Treatment: Wastes D001 and D012 - D017 will be
incinerated. Wastes D002, O003 and D004 - DO 11 will be
treated by the Organic or Inorganic Waste Treatment
Operations or by the General Wastewater Treatment
System depending upon the nature and extent of the
contamination. In general, any waste which contains a
toxic organic component will be treated by the Incineration
Systems. The process by which a specific waste will be
treated will be determined after analysis of a sample of the
waste.
VOLUME H
APPENDIX II-l
-------
EPA Hazardous
Waste Number
Description of the Waste
Generic Waste:
F001
F002
F003
F004
F005
F006
The following spent halogenated solvents used in degreasing:
tetrachloroethylene, trichloroethylene, methyiene chloride,
1,1,1-trichloroethane, carbon tetrachioride, and chlorinated
fluorocarbons; and sludges from the recovery of these solvents
in degreasing operations
The following spent halogenated solvents: tetrachloroethylene,
methyiene chloride, trichloroethylene, 1,1,1-trichloroethane,
chlorobenzene, l,l,2-trichloro-l,2,2-trifluoroethane, ortho-
dichlorobenzene, and trichlorofluoromethane; and the still
bottoms from the recovery of these solvents
The following spent non-halogenated solvents: xylene, acetone,
ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl
ketone, n-butyl alcohol, cyclohexanone, and methanol; and the
still bottoms from the recovery of these solvents
The following spent non-halogenated solvents: cresois and
cresylic acid, and nitrobenzene; and the still bottoms from the
recovery of these solvents
The following spent non-halogenated solvents: toluene, methyl
ethyl ketone, carbon disulfide, isobutanol, and pyridine; and the
still bottoms from the recovery of these solvents
Wastewater treatment sludges from electroplating operations
except from the lollowing processes: (1) sulfuric acid anodizing
of aluminum; (2) tin plating on carbon steel; (3) zinc plating
(segregated basis) on carbon steel; (4) aluminum or zinc-
aluminum plating on carbon steel; (5) cleaning/stripping
:iated with tin, zinc and aluminum plating on carbon steel;
and (6) chemical etching and milling of aluminum
VOLUME H
APPENDIX H-l
-------
EPA Hazardous
Waste Number
Description of the Waste
F007
FOOS '
F009
F010
F011
F012
F019
Spent cyanide plating bath solutions from electroplating
operations (except for precious metals electroplating spent
cyanide plating bath solutions)
Plating bath sludges from the bottom of plating baths from
electroplating operations where cyanides are used in the process
(except lor precious metals electroplating plating bath sludges)
Spent stripping and cleaning bath solutions from electroplating
operations where cyanides are used in the process (except for
precious metals electroplating spent stripping and cleaning bath
solutions)
Quenching bath sludge from oil baths from metal heat treating
operations where cyanides are used in the process (except for
precious metals heat-treating quenching bath sludges)
Spent cyanide solutions from salt bath pot cleaning from metal
heat treating operations (except lor precious metals heat
treating spent cyanide solutions from salt bath pot cleaning)
Quenching wastewater treatment sludges from metal heat
treating operations where cyanides are used in the process
(except lor precious metals heat treating quenching wastewater
treatment sludges)
Wastewater treatment sludges from the chemical conversion
coating ol aluminum
Treatment: Wastes F001 - F005 will be incinerated. Wastes
F006 - F012 and F019 will be treated by the Organic or
Inorganic Waste Treatment Operations or by the General
Wastewater Treatment System depending upon the nature and
extent ol the contamination. In general, any waste which
contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined alter analysis of a sample of
the waste.
VOLUME II
APPENDIX H-l
-------
EPA Hazardous
Waste Number
Description of the Waste
Wood Preservation:
K001
Inorganic Pigments:
K002
K003
K004
K005
K006
K007
K008
Bottom sediment sludge from the treatment of waste waters
from wood preserving processes that use creosote and/or
pentachiorophenol
Treatment: Waste K001 .will be incinerated.
Wastewater treatment sludge from the production of chrome
yellow and orange pigments
Wastewater treatment sludge from the production of molybdate
orange pigments
Wastewater treatment sludge from the production of zinc
yellow pigments
Wastewater treatment sludge from the production of chrome
green pigments
Wastewater treatment sludge from the production of chrome
oxide green pigments (anhydrous and hydrated)
Wastewater treatment sludge from the production of iron blue
pigments
Oven residue from the production of chrome oxide green
pigments
Treatment: Wastes K002 - KOOS will be treated by the Organic
or Inorganic Waste Treatment Operations or by the General
Wastewater Treatment System depending upon the nature and
extent of the contamination. In general, any waste which
contains a toxic organic component will be treated by the
VOLUME H
APPENDIX H-l
-------
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
EPA Hazardous
Waste Number
Organic Chemicals:
K009
K010
K011
K013
K014
K015
K016
K017
K01S
KOI 9
K020
K021
Description of the Waste
Distillation bottoms from the production of acetaldehyde from
ethylene
Distillation side cuts from the production of acetaldehyde from
ethylene
Bottom stream from the wastewater stripper in the production
of acrylonjtriie
Bottom stream from the acetonitriie column in the production
of acrylonitrile
Bottoms from the acetonitriie purification column in the
production of acrylonitrile
Still bottoms from the distillation of benzyl chloride
Heavy ends or distillation residues from the production of
carbon tetrachloride
Heavy ends (still bottoms) from the purification column in the
production of epichiorohydrin
Heavy ends from the fractionation column in ethyl chloride
production
Heavy ends from the distillation of ethylene dichloride in
ethyiene dichloride production
Heavy ends from the distillation of vinyl chloride in vinyl
chloride monomer production
Aqueous spent antimony catalyst waste from fluorometnanes
production
VOLUME H
APPENDIX H-l
-------
EPA Hazardous
Waste Number
Description of the Waste
K022
K023
K020
K025
K026
K027
K02S
K029
K030
K083
KOS5
K093
K094
K093
K096
K103
Distillation bottom tars from the production of phenol/acetone
from cumene
Distillation light ends from the production of phthaiic anhydride
from naphthalene
Distillation bottoms from the production of phthaiic anhydride
from naphthalene
Distillation bottoms from the production of nitrobenzene by the
nitration of benzene
Stripping still tails from the production of methyl ethyl
pyridines
Centrifuge and distillation residues from toluene diisocyanate
production
Spent catalyst from the hydrochlorinator reactor in the
production of 1,1,1-trichloroethane
Waste from the product steam stripper in the production of
1,1,1 -tr ichloroethane
Column bottoms or heavy ends from the combined production of
trichloroethylene and perchloroethylene
Distillation bottoms from aniline production
Distillation or fractionation column bottoms from the
production of chlorobenzenes
Distillation light ends from the production of phthaiic anhydride
from ortho-xylene
Distillation bottoms from the production of phthaiic anhydride
from ortho-xylene
Distillation bottoms from the production of 1,1,1-
trichloroethane
Heavy ends from the heavy ends column from the production of
1,1,1 -trichloroethane
Process residues from aniline extraction from the production of
aniline
VOLUME H
APPENDIX H-l
-------
EPA Hazardous
Waste Number
Descriotion of the Waste
KlOf
K105
Combined wastewater streams generated from
nitrobenzene/aniline production
Separated aqueous stream from the reactor product washing
step in the production of chlorobenzenes
Treatment: Waste K009-K011, K013-K030, K083, KOS5, K093-
K096 and K.103-K105 will be incinerated.
Inorganic Chemicals:
K071
K073
K106
Brine purification muds from the mercury cell process in
chlorine production, where separately prepurified brine is not
used
Chlorinated hydrocarbon waste from the purification step of the
diaphragm cell process using graphite anodes in chlorine
production
Wastewater treatment sludge from the mercury cell process in
chlorine production
Treatment: K071, K073 and K106 will be treated by the
Organic or Inorganic Waste Treatment Operations or by the
General Wastewater Treatment System depending upon the
nature and extent of the contamination. In general, any waste
which contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste. Permit conditions such as those which restrict the
concentration of mercury in the flue gas eminating from the
stack and in the wastewater discharged to the East Liverpool
Sanitary Sewer may impose limitations on the quantity and
concentration of mercury in these wastes.
VOLUME H
APPENDIX H-l
-------
EPA Hazardous
Waste Number
Description of the Waste
Pesticides:
K031 By-product salts generated in the production of MSMA and
cacodylic acid
K032 Wastewater treatment sludge from the production of chlordane
K033 Wastewater and scrub water from the chlorination of
cyciopentadiene in the production of chlordane
K034 Filter solids from the filtration of hexachlorocyclopentadiene in
the production of chlordane
K035 Wastewater treatment sludges generated in the production of
creosote
K036 Still bottoms from toluene reclamation distillation in the
production of disulf oton
K037 Wastewater treatment sludges from the production of disulf oton
K038 Wastewater from the washing and stripping of phorate
production
K039 Filter cake from the filtration of diethylphosphorodithioic acid
in the production of phorate
K0*0 Wastewater treatment sludge from the production of phorate
K041 Wastewater treatment sludge from the production of toxaphene
K042 Heavy ends or distillation residues from the distillation of
tetrachlorobenzene in the production of 2,4,5-T
K043 2,0-Dicnloropnenol waste from the production of 2,4-D
K097 Vacuum stripper discharge from the chlordane chlorinator in the
production of chlordane
K09S Untreated process wastewater from the production of
toxaphene
K099 Untreated wastewater from the production of 2,4-D
Treatment:
Waste K031-K043 and K097-K099 will be
VOLUME D
APPENDIX H-l
-------
EPA Hazardous
Waste Number
incinerated.
Description of the Waste
Explosives:
K044
K045
K046
K0*7
Wastewater treatment sludges from the manufacturing and
processing of explosives
Spent carbon from the treatment of wastewater containing
explosives
Wastewater treatment sludges from the manufacturing,
formulation and loading of lead-based initiating compounds
Pink/red water from TNT operations
Treatment: Waste K044-K047 will be treated by the Organic or
Inorganic Waste Treatment Operations or by the General
Wastewater Treatment System depending upon the nature and
extent of the contamination. In general, any waste which
contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
Petroleum Refining:
K04S
K049
K030
K051
K052
Dissolved air flotation (DAF) float from the petroleum refining
industry
Slop oil emulsion solids from the petroleum refining industry
Heat exchanger bundle cleaning sludge from the petroleum
refining industry
API separator sludge from the petroleum refining industry
Tank bottoms (leaded) from the petroleum refining industry
Treatment: Waste K048-K052 will be treated by the Organic or
VOLUME II
APPENDIX H-l
10
-------
Inorganic Waste Treatment Operations or by the General
Wastewater Treatment System depending upon the nature and
extent of the contamination. In general, any waste which
includes a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis ot a sample of
the waste.
EPA Hazardous
Waste Number
Description of the Waste
Iron and Steel:
K061
K062
Emission control dust/sludge from the primary production of
steel in electric furnaces
Spent pickle liquor from steel finishing operations
Treatment: Waste K061 and K062 will be treated by the
Organic or Inorganic Waste Treatment Operations or by the
General Wastewater Treatment System depending upon the
nature and extent of the contamination. In general, any waste
which contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
Secondary Lead:
K069
K100
Emission control dust/sludge from secondary lead smelting
Waste leaching solution from acid leaching of emission control
dust/sludge from secondary lead smelting
Treatment: Waste K069 and K100 will be treated by the
Organic or Inorganic Waste Treatment Operations or by the
VOLUME H
APPENDIX H-l
11
-------
General Wastewater Treatment System depending upon the
nature and extent of the contamination. In general, any waste
which contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
EPA Hazardous
Waste Number
Description of the Waste
Veterinary
Pharmaceuticals:
K084
K101
K102
Wastewater treatment sludges generated during the production
of veterinary Pharmaceuticals from arsenic or organo-arsenic
compounds
Distillation tar residues from the distillation of aniline-based
compounds in the production of veterinary Pharmaceuticals
from arsenic or organo-arsenic compounds
Residue from the use of activated carbon for decolonization in
the production of veterinary Pharmaceuticals from arsenic or
organo-arsenic compounds
Treatment: Waste K084, K101 and K102 will be treated by the
Organic or Inorganic Waste Treatment Operations or by the
General Wastewater Treatment System depending upon the
nature and extent of the contamination. In general, any waste
which contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
VOLUME H
APPENDIX n-1
12
-------
EPA Hazardous
Waste Number
Description of the Waste
Ink Formulation:
KOS6
Solvent washes and sludges, caustic washes and sludges, or
water washes and sludges from cleaning tubs and equipment
used in the formulation of ink from pigments, driers, soaps, and
stabilizers containing chromium and lead
Treatment: Waste K046 will be treated by the Organic or
Inorganic Waste Treatment Operations or by the General
Wastewater Treatment System depending upon the nature and
extent of the contamination. In general, any waste which
contains a toxic organic component will be treated by the
Incineration Systems. The process by which a specific waste
will be treated will be determined after analysis of a sample of
the waste.
Coking:
K060
KOS7
Ammonia still lime sludge from coking operations
Decanter tank tar sludge from coking operations
Treatment: Waste K060 and K087 will be incinerated.
Other Waste:
P001
P002
Malpha-acetonylbenzylM-hydroxycoumarin and salts,
(Warfarin)
Acetamide, N-(aminothioxomethyl)-, (l-Acetyl-2-thiourea)
VOLUME H
APPENDIX H-l
13
-------
EPA Hazardous
Waste Number
Description of the Waste
P003
P004
P005
POOfiW
P007
POOS
P009<2>
poioU)
pond)
2-Propenal, (Acrolein)
P013V
P016
P017
P01S
P020
P021
P022
P023
P024
P026
P027
P028
exo-dimethanonaphthalene, (Aldrin)
2-Propen-l-ol, (Allyl alcohol)
Aluminum phosphide
3(2H)-Isoxazolone, Maminomethyl)-,
(5-(Aminomethyl)-3- isoxazolol)
4-aAminopyridine, (4-Pyridinamine)
Phenol, 2,(>,6-trinitro-t ammonium salt, (Ammonium picrate)
Arsenic acid
Arsenic (V) oxide, (Arsenic pentoxide)
Arsenic (ID) oxide, (Arsenic trioxide)
Barium cyanide
Benzenethioi, (Thiophenoi)
Beryllium dust
Methane, oxybis (chloro-, (Bis(chloromethyl)ether)
2-Propanone, 1-bromo-, (Bromoacetone)
Strychnidin-10-one, 2,3-dimethoxy-, (Brucine)
Phenol, 2,(l-methylpropyl)-, (Dinoseb)
Calcium cyanide
Carbon disuli ide, (Carbon bisulfide)
Acetaldehyde, chloro-, (Chloroacetaldehyde)
Benzenamine, 4-chloro-, (p-Chloroaniline)
Mo-Chlorophenylhhiourea, (Thiourea, (2-chlorophenyl)-)
Propanenitrile, 3-chloro-, (3-Chloropropionitrile)
Benzene, (chloromethyl)-, (Benzyl chloride)
Copper cyanides
Cyanides (soluble cyanide salts), not elsewhere specified
VOLUME H
APPENDIX IM
14
-------
EPA Hazardous
Waste Number
Description of the Waste
P036
P037
P038
P039
P0*0
P041
P042
P045
P0*6
P047
P04S
P049
P050
P051
Phenol, 2-cyciohexyl-«,6-dinitro-,
«S6-Dinitro-o- cyclohexylphenol)
Phenyl dichloroarsine, (Dichlorophenylarsine)
l,2f3,4,10,10-Hexachloro-6,7-eDoxy-l,^,4a,5,6,7,8tSa-octahydro-
endo,exo-l,4:3,8-dimethanonaphthalene, (Dieldrin)
Arsine, diethyl-, (Oiethylarsine)
O,O-Diethyl S- [2-{ethylthio)ethyQ phosphorodithioate,
(Oisulfoton)
Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester,
(O,O>Oiethyi O-pyrazinyl phosphorothioate)
Phosphoric acid, diethyl p-nitrophenyl ester,
(Diethyl-p-nitrophenyl phosphate)
1,2-Benzenediol, 4. [l-hydroxy-2-(methyl-amino)ethyl] -,
(Epinephrine)
Phosphorofluoric acid, bis(l-methyiethyl)-ester,
(Oiisopropyl fluorophosphate)
Phosphorodithioic acid, O,O-dimethyl S- [2-(methylamino)-
2-oxoethyl] ester, (Dimethoate)
3,3-Dimethyl-l-(methylthio)-2-butanone, O- [(methyiamino)
carbonyij oxime, (Thiofanox)
Ethanamine, l,l-dimethyl-2-phenyi>,
(alpha^lpha- Dimethylphenethylamine)
Phenol, 2,*-dinitro-6-methyl-, C*f6-Dinitro-o-cresol and saits)
Phenol, 2,, (2,4-Oinitrophenol)
2,<»-Dithiobiuret, (Thioimidodicarbonic diamide)
5-Nk>rbornene-2t3-dimethanol, 1,^,5,6,7,7-hexachloro,
cyclic sulfite, (Endosulfan)
l,2,3,«,10,10-Hexachloro-6,7-epoxy-l,*,*a,5,6,7,8,8a-octahydro-
endo, endo-l,4:5,&-dimethanonaphthalene, (Endrin)
VOLUME n
APPENDIX II-1
15
-------
EPA Hazardous
Waste Number
Description of the Waste
P057
P058
P059
P060
P062
P064
TO**
P066
P067
P06S
P069
P070
P071
P072
P075
P077
POS1<2>
Ethylenimine, (Aziridine)
Acetamide, 2-fluoro-, (Fluoroacetamide)
Acetic acid, fluoro-, sodium salt,
(Fluoroacetic acid, sodium salt)
4,7-Methano-l H-indene, 1,4,5,6, 7,S,S-heptachloro-
3a,*,7,7a-tetrahydro-, (Heptachlor)
1,2,3,4,10,10- Hexachloro-if4,4a,5,8,Sa-hcxahydrc>-l^:
endo-dimethanonaphthaiene,
(Hexachlorohexahydro-exo, exo-dimethanonaphthalene)
Tetraphosphoric acid, hexaethyl ester,
(Hexaethyl tetraphosphate)
Isocyanic acid, methyl ester, (Methyl isocyanate)
Fulminic acid, mercuryUl) salt, (Mercury fulminate)
Acetimidic acid, N-[(methylcarDamoyi)oxy]thio-, methyl
ester, (Methomyl)
2-Methylaziridine, (1,2,-Propylenimine)
Hydrazine, methyl-, (Methyl hydrazine)
Propanenitrile, 2-hydroxy-2-methyl-, (2-Methyllactonitriie)
Propanal, 2-methyl-2-(methylthio)-, O-[(methyiamino)
car bony 1 j oxime, (Aldicarb)
O,O-Dimethyl O-p-nitrophenyl phosphorothioate,
(Methyl parathion)
Thiourea, 1-naphthalenyl-, (alpha-Naphthylthiourea)
Pyridine, (S)-3-(l-methyl-2-pyrroUdinyl)-, and salts,
(Nicotine and salts)
Benzenamine, *-nitro-, (p-Nitroanitine)
1,2,3-Propanetriol, trinitrate-, (Nitroglycerine)
VOLUME H
APPENDIX H-l
16
-------
EPA Hazardous
Waste Number
Description of the Waste
P082
P084
P085
POS8
POS9
P092
P093
P09*
P097
P09S{1)
P099(1)
P101
P102
P103
P107<1)
P108
PI 09
P110
N-Nitrosodimethylamine, (Dimethylnitrosamine)
Ethenamine, N-methyl-N-nitroso-, (N-Nitrosomethylvinylamine)
Diphosphoramide, octamethyl-, (Octamethylpyrophosphoramide)
Osmium oxide, (Osmium tetroxide)
7-Oxabicycio [2.2.1] heptane-2y3-dicarboxylic acid, (Endothall)
Phosphorothioic acid, O,O-diethyl O-(p-nitrophenyl) ester,
(Parathion)
Mercury, (acetato-O)phenyl-, (Phenylmercuric acetate)
Thiourea, phenyl-, (N-Phenylthiourea)
Phosphorothioic acid, O-O-diethyl S-(ethylthio)methyl ester,
(Phorate)
Phosphorothioic acid, O,O-dimethyl O- [p-
((dimethylamino)-sulfonyl)phenyl] ester, (Famphur)
Potassium cyanide
Potassium silver cyanide
Propanenitrile, (Ethyl cyanide)
2-Propyn-l-ol, (Propargyl alcohol)
Carbamimidoseienoic acid, (Selenourea)
Silver cyanide
Sodium azide
Sodium cyanide
Strontium suifide
Strychnidin-10-one, and salts, (Strychnine and salts)
Dithiopyrophosphoric acid, tetraethyl ester,
(Tetraethyldithiopyrophosphate)
Plumbane, tetraethyl-, (Tetraethyl lead)
VOLUME H
APPENDIX H-l
17
-------
EPA Hazardous
Waste Number
Description of the Waste
Pill
P113")
PI 16(D
PUS
P122
PI 23
UOOl
U002
U003
U004
U005
U006
U007
U002
U009
U010
U011
U012
UOH
(1X2)
Pyrophosphoric acid, tetraethyl ester,
(Tetraethylpyrophosphate)
Thallium (HI) oxide, (Thallic oxide)
Thallium (I) selenite
Sulf uric acid, thallium(I) salt, (Thallium(l) sulfate)
Hydrazinecarbothioamide, (Thiosemicarbazide)
Methanethiol, trichloro-, (Trichloromethanethiol)
Vanadic acid, ammonium salt, (Ammonium vanadate)
Vanadium (V) oxide, (Vanadium pentoxide)
Zone cyanide
Zinc phosphide
Camphene, octachloro-, (Toxaphene)
Acetaldehyde, (Ethanal)
2-Propanone, (Acetone)
Ethanenitriie, (Acetonitrile)
Ethanone, 1-phenyl-, (Acetophenone)
Acetamide, N-9H-fluoren-2-yl-, (2-AcetyJaminofluorene)
Ethanoyl chloride, (Acetyi chloride)
2-Propenamide, (Acrylamide)
2-Propenoic acid, (Acrylic acid)
2-Propenenitrile, (Acrylonitrile)
Azirino (2',3':3,4)pyrTolo(l,2-a)indole-*,7-dione,6-amino-&- £
((aminocarbonyl)oxy)methyl]-l,iat2t8,8a,8b-hexahydro-8a-
methoxy-5-methyl-, (Mitomycin C)
lH-l,2,
-------
EPA Hazardous
Waste Number
Description of the Waste
U015
U016
U01S
U020
U021
U022
U02»
U025
U026
U027
U02S
U029
U030
U031
U032<1>
U034
U035
U036
U037
U038
L-Serine, diazoacstate (ester), (Azaserine)
Benz[c]acridine, (3,*-Benzacridine)
Benzene
Benz[a]anthracene, (1,2-Benzanthracene)
Benzene (less than ten percent concentration)
Benzenesulionic acid chloride, (Benzenesulfonyi chloride)
a,l'-Biphenyl)-Mf-diamine, (Benzidine)
Benzofajpyrene, (3,4-Benzopyrene)
Benzene, (trichioromethyl)-, (Benzotrichlbride)
Ethane, I,i'-{methylenebis(oxy3bis[2-chloro-,
(Bis(2-chloroethoxy) methane)
Ethane, l,l'-oxybis [5-chloro-, (Oichloroethyl ether)
2-Naphthyiamine, N,N'-bis(2-chloro-methyl)-, (Chlornaphazine)
Propane, 2,2Vjxybis(2-chloro-, (Bis(2-chloroisopropyl) ether)
1,2-Benzenedicarboxylic acid, 0>is(2-ethyl-hexyl)3 ester,
(Bis(2-ethylnexyi) phtnalate)
Methane, bromo-, (Methyl bromide)
Benzene, l-bromo-4-phenoxy-, («-Bromophenyl phenyl ether)
1-Butanol, (n-Butyl alcohol)
Chromic acid, calcium salt, (Calcium chromate)
Acetaldehyde, trichioro-, (Chloral)
Butanoic acid, 4-[Bis(2-chloroethyl)amino] benzene-,
(Chlorambucil)
4,7-Methanoindan, l,2,4,5,6,7,8,8-octachloro-3a,4,7,7a-
tetrahydro-, (Chlordane, technical)
Benzene, chloro-, (Chiorobenzene)
Benzeneacetic acid,
-------
EPA Hazardous
Waste Number
Description of the Waste
U039
U041
U042
U043
ucm
U045
U0*7
U049
U050
U051
U052
U053
U055
U056
U057
U058
U059
U060
U061
U062
U063
U064
U066
U067
U068
U069
U070
VOLUME H
APPENDIX H-l
Phenol, *-chloro-3-methyl-, (*-Chioro-m-cresol)
Oxirane, 2-(chloromethyl)-, (l-Chloro-2,3-epoxypropane)
Ethene, 2-diloroethoxy-, (2-Chioroethyl vinyl ether)
Ethene, chloro-, (Vinyl chloride)
Methane, trichloro-, (Chloroform)
Methane, chloro-, (Methyl chloride)
Methane, chloromethoxy-, (Chloromethyl methyl ether)
Naphthalene, 2-cnloro-, (beta-Chloronaphthalene)
Phenol, 2-chloro-, (o-Chlorophenol)
Benzenamine, 4-chloro-2-methyl-,
(4-Chloro-o-toluidine, hydrochloride)
1,2-Benzphenanthrene, (Chrysene)
Creosote
Cresylic acid, (Cresols)
2-Butenal, (Crotonaldehyde)
Benzene, (1-methylethyl)-, (Cumene)
Benzene, hexahydro-, (Cyclohexane)
Cyclone xanone
2H-l,3,2-Oxazaphosphorine, 2-[bis(2-chloro-ethyl)aminq]
tetrahydro-.oxide 2>, (Cyclophosphamide)
5,12-Naphthacenedione, (8S-cis)-8-acetyl-10-[(3-amino-
2,3,6-trideoxy-alpha-L-lyxo-hexopyranosyl)oxyl]-7,8,9,10-
tetrahydro-6,8,11-trihydroxy-1 -methoxy-, (Daunomycin)
Dichloro dtphenyl dichloroethane, (ODD)
Dichloro diphenyl trichloroethane, (DDT)
S-(2,3-Dichloroallyl) diisopropylthiocarbamate, (Diallate)
Dibenz(a,h]anthracene, (l,2:5,6-Dibenzanthracene)
Dibenz{a,0pyrene, (l,2;7,8-Dibenzopyrene)
Propane, l,2-dibromo-3-chloro-, (l,2-Dibromo-3-chloropropane)
Ethane, 1,2-dibromo-, (Ethylene dibromide)
Methane, dibromo-, (Methylene bromide)
1,2-Benzenedicar boxy lie acid, dibutyl ester, (Dioutyl phthalate)
Benzene, 1,2-dichloro-, (o-Dichlorobenzene)
20
-------
EPA Hazardous
Waste Number
Description of the Waste
U071
U072
U073
U07*
U076
U077
U078
U079
U080
U081
UOS2
U083
U084
U085
UOS6
U087
U088
U089
U090
U091
U092
U093
U094
U095
Benzene, 1,3-dichloro-, (m-Dichlorobenzene)
Benzene, l,*-dichioro-f (p-Dichiorobenzene)
(1,1 '-Biphenyl)-M'-diamine, 3,3'-dichloro-,
(3,3'-Dichlorobenzidine)
2-Butene, 1,0-dichloro-, (l,4-Dichloro-2-butene)
Ethane, 1,1-dichloro-, (Ethylidene dichloride)
Ethane, 1,2-dichloro-, (Ethylene dichloride)
Ethene, 1,1-dichloro*, (1,1-Dichloroethylene)
Ethene, trans-l,2-dichloro-, (1,2-Dichloroethylene)
Methane, dichloro-, (Methylene chloride)
Phenol, 2,(»-dichloro-, (2,4-Dichloropnenol)
Phenol, 2,6-dichloro-, (2,6-Dichlorophenol)
1,2-Dicnloropropane, (Propylene dichloride)
Propene, 1,3-dichloro-, (1,3-Dichloropropene)
l,2:3,4-Diepoxybutane, (2,2'-Bioxirane)
Hydrazine, 1,2-diethyl-, (N,N-Diethylhydrazine)
Phosphorodithioic acid, O,O-diethyl-, S-methylester,
(O,O-Diethyl-S-methyl-dithiophosphate)
1,2-Benzenedicar boxy lie acid, diethyl ester, (Diethyl phthalate)
<*,*'-Stilbenediol, alpha^lpha'-diethyl-, (Diethylstilbestrol)
Benzene, l,2-methylenedioxy-4-propyi-, (Dihydrosafrole)
(l,r-BiphenylM,4'-diamine, 3,3'-dimethoxy-,
(3,3'-Dimethoxybenzidine)
Methanamine, N-methyl-, (Oimethyiamine)
Benzenamine, N,N'-diniethyl-4-phenylazo-,
(Dimethyiaminoazobenzene)
7,12-Dimethylbenze[a)anthracene,
(1,2-Benzanthracene, 7,12-dimethyl-)
(l,l'-BiphenylM,4'xiiamine, 3,3'-dimethyl-,
(3,3'-Dimethylbenzidine)
VOLUME H
APPENDIX II-l
21
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EPA Hazardous
Waste Number
Description of the Waste
U097
U098
U099
U101
U102
U105
U106
U107
U10S
U109
U110
Ulll
U112
U113
U114
UH5
U116
U1L7
U11S
U119
U120
U121
Hydroperoxide, 1-methyl-l-phenylethyl-,
(alpha,alpha-DimethylbenzylhydroDeroxide)
Carbamoyl chloride, dimethyl-, (Dimethylcarbamoyl chloride)
Hydrazine, 1,1-dimethyl-, (1,1-Dimethylhydrazine)
Hydrazine, 1,2-dimethyl-, (1,2-Dimethylhydrazine)
Phenol, 2,»-dimethyl-, (2,^-Dimethylphenol)
1,2-Benzenedicarboxylic acid, dimethyl ester, (Dimethyl
phthalate)
Sulf uric acid, dimethyl ester, (Dimethyl suliate)
Benzene, l-methyl-U2,
-------
EPA Hazardous
Waste Number
Description of the Waste
U122
U123
U125
U126
U127
U128
U129
U130
U131
U132
U133
U13*
U136
U137
,(2)
(1)
UlOO
U141
UU8
Methyiene oxide, (Formaldehyde)
Methanoic acid, (Formic acid)
Furiuran, (Furan)
2-Furancarboxaldehyde, (Furfural)
1-Propanol, 2,3-epoxy-, (Glycidylaidehyde)
benzene, hexachloro-, (Hexachlorobenzene)
1,3-Butadiene, 1,1,2,3,4,4-hexachloro-, (Hexachlorobutadlene)
Hexachlorocyclohexane (gamma isomer), (Lindane)
1,3-Cyclopentadiene, 1,2,3,4,5,5-hexa-chloro-,
(Hexachlorocyciopentadiene)
Ethane, 1,1,1,2,2^2-hexachloro-, (Hexachloroethane)
2,2'-Methylenebis(3,4,6-trichlorophenol), (Hexachlorophene)
Diamine, (Hydrazine)
Hydrogen fluoride, (Hydrofluoric acid)
Hydroxydimethylarsine oxide, (Cacodylic acid)
l,10>(l,2-phenylene)pyrene, (Indeno [l,2,3-cd]pyrene)
Methane, iodo-, (Methyl iodide)
Ferric dextran, (Iron dextran)
1-Propanol, 2-methyl-, (Isobutyl alcohol)
Benzene, l,2-methylenedioxy-<*-propenyl-, (Isosafrole)
Decachlorooctahydro-l,3,*-metheno-2H-cyclobuta[c, d]-
pentalen-2-one, (Kepone)
Lasiocarpine
Acetic acid, lead salt, (Lead acetate)
Phosphoric acid, Lead salt, (Lead phosphate)
Lead subacetate
2,5-Furandione, (Maleic anhydride)
l,2-Dihydro-3,6-pyradizinedione, (Maleic hydrazide)
VOLUME H
APPENDIX H-l
23
-------
EPA Hazardous
Waste Number
Description of the Waste
U149
U150
U152
U153
U154
U155
U156
U157
U15«
U159
U160(2)
U161
U162
U163
U164
U165
U166
U167
U16S
U169
U170
U171
U172
Propanedinitrile, (Malononitrile)
Alanine, 3-fp-bis(2-chloroethyl)aminoJphenyl-, L-, (Melphaian)
Mercury
2-Propenenitrile, 2-methyl-, (Methacryionitrile)
Methanethiol, (Thiomethanol)
Methanol, (Methyl alcohol)
Pyridine, 2-[{2-
-------
EPA Hazardous
Waste Number
Description of the Waste
U173
U17*
UI76
U177
U178
U179
U180
U1S1
U1S2
U183
U1S*
U185
U186
U187
U1S8
U189
U190
U191
U192
U193
U19*
U 196(D
U197
U200
U201
U202
U203
Ethanol, 2,2'-(nitrosoimino)bis-, (N-Nitrosodiethanolamine)
Ethanamine, N-ethyl-N-nitroso-, (N-Nitrosodiethylamine)
Carbamide, N-ethyl-N-nitroso-, (N-Nitroso-N-ethylurea)
Carbamide, N-methyl-N-nitroso-, (N-Nitroso-N-methylurea)
Carbamic acid, methylnitroso-, ethyl ester,
(N-Nitroso-N-methylure thane)
Pyridine, hexahydro-N-nitroso-, (N-Nitrosopiperidine)
Pyrrole, tetrahydro-N-nitroso-, (N-Nitrosopyrrolidine)
Benzenamine, 2-methyl-5-oitro, (5-Nitro-o-toluidine)
1,3,5-Trioxane, 2,^,5-trimethyl-, (Paraldehyde)
Benzene, pentachloro-, (Pentachlorobenzene)
Ethane, pentachloro-, (Pentachloroethane)
Benzene, pentachloro-oitro-, (Pentachloronitrobenzene)
1,3-Pentadiene, (1-Methylbutadiene)
Acetamide, N-(4-ethoxyphenyl)-, (Phenacetin)
Benzene, hydroxy-, (Phenol)
Sulfur phosphide, (Phosphorous suifide)
1,2-Benzenedicarboxylic acid anhydride, (Phthalic anhydride)
Pyridine, 2-methyl-, (2-Picoline)
3,5-DicnJoro-N-(I,l-dimethyl-2-propynyl) benzamide,
(Pronamide)
1,2-Oxathiolane, 2,2-dioxide, (1,3-Propane sultone)
1-Propanamine, (n-Propylamine)
Pyridine
1,^-Cyclohexadienedione, (p-Benzoquinone)
Yohimban-16-carboxylic acid, ll,17-dimethoxy-18-03,*,5-
trimethoxy- benzoyl)oxy]-, methyl ester, (Reserpine)
1,3-Benzenediol, (Resorcinol)
l,2-Benzisothiazolin-3-one, 1,1-dioxide, (Saccharin and salts)
Benzene, l,2-methylenedioxy-4-allyl-, (Safrole)
VOLUME H
APPENDIX n-1
25
-------
EPA Hazardous
Waste Number
Description of the Waste
U232
U233
U235
U236
U23S
U239
U240
U242
U246
U247
2,*,5-Trichlorophenoxyacetic acid, (2,4,5-T)
Propionic acid, 2-(2,4,5-trichlorophenoxy)-, (Silvex)
Benzene, 1,3,5-trinitro-, (sym-Trinitrobenzene)
1-Propanol, 2,3-dibromo-, phosphate (3:1),
(Tris(2,3-dibromopropyl) phosphate)
2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-dimethyl-(l,r-
biphenyD-*,*yiyll[J-bis(azo)bis(5-amino-4-hydroxy)-,
tetrasodium salt, (Trypan blue)
Carbamic acid, ethyl ester, (Ethyl carbamate (urethan))
Benzene, dimethyl-, (Xylene)
2,4-Dichlorophenoxyacetic acid, salts and esters,
(2,42-D, salts and esters)
Phenol, pentachloro-, (Pentachlorophenol)
1-Propene, 1,1,2,3,3,3-hexachloro-, (Hexachloropropene)
Bis(dimethylthiocarbamoyl) disulf ide, (Thiram)
Bromine cyanide, (Cyanogen bromide)
Ethane, l,l,l,-trichloro-2,2-bis(p-methoxyphenyl),
(Methoxychlor)
VOLUME H
APPENDIX II-1
26
-------
EPA Hazardous
Waste Number
Descriotion of the Waste
U205*1)
U206
U207
U208
U209
U210
U211
U212
U213
U214
U217«>
U218
U219
U220
U221
U222
U223
U225(D
U226
U227
U22S
U230
U231
Selenious acid, (Selenium dioxide)
Sulfur selenide, (Selenium disulfide)
D-Glucopyranose, 2-deoxy-2(3-methyl-3-nitrosoureido),
(Streptozotocin)
Benzene, 1,2,4,5-tetrachloro-, (1,2,4,5-Tetrachiorobenzene)
Ethane, 1,1,1,2-tetrachloro-, (1,1,1,2-Tetrachioroethane)
Ethane, 1,1,2,2-tetrachloro-, (1,1,2,2-Tetrachloroethane)
Ethene, 1,1,2,2-tetrachloro-, (Tetrachloroethylene)
Methane, tetrachloro-, (Carbon tetrachioride)
Phenol, 2,3,4,6-tetrachloro-, (2,3,4,6-Tetrachlorophenol)
Furan, tetrahydro-, (Tetrahydrofuran)
Acetic acid, thallium(l) salt, (Thallium (I) acetate)
Carbonic acid, dithallium (I) salt, (Thallium (I) carbonate)
Thallium (I) chloride
Thallium (1) nitrate
Ethanethioamide, (Thioacetamide)
Carbamide, thio-, (Thiourea)
Benzene, methyl-, (Toluene)
Toluenediamine, (Diaminotoluene)
Benzenamine, 2-methyi-, hydrochloride,
(O-Toluidine hydrochloride)
Benzene, 1,3-diisocyanatomethyl-, (Toluene diisocyanate)
Methane, tribromo-, (Bromoform)
1,1,1-Trichioroethane, (Methylchloroform)
Ethane, 1,1,2-trichloro-, (1,1,2-Trichioroethane)
Trichloroethene, (Trichioroethylene)
Phenol, 2,4,5-trichloro-, (2,^,5-Trichlorophenol)
Phenol, 2,^,6-trichloro-, (2,4,6-Trichlorophenol)
VOLUME H
APPENDIX H-l
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Volume 13
Appendix II-1 28
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APPENDIX H-2
Chronology of WIT's Regulatory History
Volume n
Appendix n-2
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CHRONOLOGY OF EVENTS REGARDING WASTE TECHNOLOGIES INDUSTRIES
As of November 21,1996
09/04/81 WTI applies for permit.
11/13/82 U.S. EPA opens public comment period regarding draft permit, which remains
open until 01/03/83.
12/15/82 U.S. EPA holds public hearing regarding draft permit.
06/24/83 U.S. EPA issues permit and Response To Comments.
08/09/83 State of West Virginia petitions for review of permit decision.
03/29/84 Administrator remands permit pending final decision on petitions.
04/19/84 U.S. EPA issues public notice of second public comment period for the State of
West Virginia.
12/17/84 Administrator denies petitions for review.
01 /25/8S U.S. EPA makes permit effective on this date.
04/20/90 U.S. EPA issues Notice of Violation for failure to respond to information request.
$9500 settlement.
09/90 WTI breaks ground on facility, including test piles, grading, and relocation of
underground utilities. WTI proceeds with the construction of only one incinerator
and no inorganic treatment process.
10/02/90 WTI requests prior approval to proceed with a Class 1 permit modification to
change Attachment X of the permit, regarding tank thickness and materials of
construction.
10/19/90 U.S. EPA grants prior approval of Class 1 permit modification described above.
10/29/90 WTI requests a permit modification to add a spray dryer to the incineration
system. In the original permitted design, combustion gases would have flowed
Volume II
Appendix II-2
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from the waste heat boiler directly into the electrostatic precipitator. whereas the
proposed spray dryer would quench the combustion gases immediately prior to
the precipitator by using scrubber blowdown water.
11/02/90 WTI publishes public notice regarding Class 2 permit modification for spray
dryer.
11/19/90 WTI holds public information meeting regarding spray dryer.
11/30/90 WTI begins construction of the actual incinerator (stack foundation).
01/18/91 U.S. EPA issues Notice of Deficiency regarding spray dryer modification and
requests extension of review time for Class 2 permit modification to 30 days after
receipt of complete application. U.S. EPA later upgrades modification to Class 3
in February of 1991.
08/23/91 U.S. EPA opens public comment period regarding addition of spray dryer.
08/27/91 U.S. EPA issues draft permit modification and fact sheet regarding addition of
spray dryer to the RCRA permit.
09/09/91 Citizen's roundtable.
09/24/91 U.S. EPA and OEPA jointly hold public information meeting in East Liverpool.
09/25/91 U.S. EPA and OEPA jointly hold public hearing hi East Liverpool regarding
permit modification to add spray dryer. Hearing has to be canceled due to
disruption by protesters.
11/22/91 WTI notifies U.S. EPA that it is implementing a Class 1 modification to update
waste code list in Attachment IX of the RCRA permit.
01/02/92 U.S. EPA inspects WTI facility and discovers illegal construction of the spray
dryer.
01/03/92 WTI notifies U.S. EPA that it is implementing a Class 1 permit modification to
install the spray dryer as a simple evaporative quench unit, using clean water only,
as an equivalent replacement for the waste heat boiler.
01/09/92 U.S. EPA files Administrative Complaint regarding 01/02/92 violation: $156,250
proposed penalty.
Volume II
Appendix II-2
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01/16/92 WTI requests temporary authorization to operate spray dryer.
01/30/92 U.S. EPA issues Consent Agreement and Final Order regarding construction of
spray dryer without a RCRA permit: $129.000 fine.
02/03/92 U.S. EPA issues permit modification to add spray dryer and to add the
Columbiana County Port Authority as an additional owner.
03/05/92 The State of West Virginia, the City of Pittsburgh, the Columbiana County Port
Authority, and several others appeal Region 5's issuance of the 2/92 permit
modification.
03/13/92 WTI again requests temporary authorization to operate spray dryer because the
first request was deemed procedurally deficient.
04/21/92 The Attorney General of West Virginia files suit against WTI, U.S. EPA. and the
Ohio EPA in Federal District Court for the Northern District of West Virginia
(Wheeling), because of alleged violations of RCRA requirements and alleged
endangerment of human health. The City of Pittsburgh and several citizen groups
intervene.
05/07/92 Hearing in front of House Subcommittee on Administrative Law and
Governmental Relations. Region 5 learns about a September 21,1990, contract
apparently making Von Roll (Ohio), Inc., an operator of the facility. This entity is
not listed on the permit.
6/17/92 U.S. EPA approves Training Plan.
07/07/92 U.S. EPA requests information under RCRA Section 3007 to aid in its
investigation into the ownership of the facility. Additional information requested
on 08/05/92.
07/09/92 U.S. EPA issues Phase 1 of the two-phased Risk Assessment.
07/09/92 U.S. EPA grants temporary authorization to operate spray dryer for 180 days.
07/15/92 U.S. EPA's Inspector General issues a Special Report regarding the WTI permit;
based upon the Region's response, the audit is closed on 11/25/92.
07/24/92 U.S. EPA Environmental Appeals Board (EAB) rules regarding spray dryer and
addition of the Port Authority. The spray dryer modification is upheld. Port
Authority issue is remanded to Region 5 for resolution.
Volume II •*"
Appendix II-2 3
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07/30/92 WTI completes construction.
08/24/92 U.S. EPA inspects facility to determine whether construction had been completed
as required under the RCRA permit.
09/01/92 In the West Virginia case, WTI stipulates to give 7-day notice to all parties before
receiving any hazardous waste on site. Temporary Restraining Order is lifted.
09/08/92 U.S. EPA notifies WTI of its preliminary determination that Von Roll (Ohio).
Inc., must be added to the permit as an additional operator, and that Von Roll
America, Inc., must be added as an owner.
09/11/92 Columbiana County Port Authority sells the incinerator property to WTI.
09/15/92 U.S. EPA meets with representatives of WTI at U.S. EPA Headquarters.
09/22/92 U.S. EPA meets with concerned citizens at Region 5 offices.
09/25/92 U.S. EPA issues letter regarding results of the August 24-25 permit compliance
inspection. U.S. EPA approves Closure Plan dated 7/31/92, Inspection Plan dated
8/19/92, and all piping and instrumentation drawings.
09/30/92 U.S. EPA approves Waste Analysis Plan dated 8/7/92, and Contingency Plan
dated 8/10/92, and authorizes WTI to begin accepting hazardous waste and start
the shakedown period.
09/30/92 U.S. EPA notifies WTI that it will process owner/operator changes as Class 1
permit modifications.
10/01/92 Grant/Zusman issue memo regarding issues of ownership and operational control.
10/02/92 U.S. EPA opens 30-day public comment period on issues related to ownership
and operational control.
10/09/92 U.S. EPA imposes interim stack emission levels and feed rates for toxic and
carcinogenic metals for the shakedown period.
10/08/92 Judge hi the West Virginia case dismisses U.S. EPA and Ohio EPA.
10/09/92 WTI gives its 7-day notice that it will begin receiving hazardous waste.
Volume II
Appendix II-2
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11/02/92 WTI submits signed Part A application which includes Von Roll (Ohio). Inc.
Public comment period closes.
11/12/92 Judge in the West Virginia case allows WTI to begin the shakedown period under
its permit.
11/13/92 WTI begins receiving hazardous waste and begins the shakedown period.
12/07/92 Senator Al Gore and other legislators request the GAO to conduct a detailed
review of several major WTI issues.
01 /06/93 Ohio EPA approves Trial Burn Plan Revision 4.
01/08/93 U.S. EPA approves Trial Burn Plan Revision 4 and imposes two conditions prior
to limited commercial operation.
01/12/93 Greenpeace and others file suit in Federal District Court for the Northern District
of Ohio (Cleveland) against U.S. EPA, Ohio EPA, and WTI to prevent the trial
burn from proceeding; a Temporary Restraining Order is requested.
01/15/93 Federal District Court (N.D. Ohio) issues Temporary Restraining Order against
proceeding with the trial burn.
03/01/93 GAO audits Region 5 from 03/01 through 03/05.
03/05/93 District Court lifts Temporary Restraining Order, allows trial burn to proceed, but
places preliminary injunction against any limited commercial operation after the
trial burn until the U.S. EPA reviews and approves the results.
03/10/93 WTI begins the trial burn. Testing continues through 3/18.
03/16/93 Sixth Circuit Court of Appeals (Cincinnati) issues a stay of the District Court's
preliminary injunction, allowing WTI to go into limited commercial operation
after the trial burn while it evaluates the merits of the appeal.
03/16/93 WTI requests prior approval to modify general facility inspection program in
permit.
03/22/93 United States Supreme Court Justice John Paul Stevens denies an emergency
request to overturn the Sixth Circuit Court stay.
Volume II
Appendix II-2
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03/26/93 U.S. EPA informs WTI that trial bum run 8 must be re-done because of sampling
problems which rendered it inconclusive.
03/30/93 WTI repeats trial burn run 8.
04/01/93 WTI notifies U.S. EPA of simple Class 1 modification regarding trial burn
POHCs, changed to reflect approved Trial Bum Plan.
04/02/93 WTI certifies that it met carbon monoxide and particulate emission limits during
the trial burn.
04/02/93 WTI faxes a report to the U.S. EPA showing that the incinerator failed to achieve
the required Destruction and Removal Efficiency (DRE) of 99.99% during two of
the nine trial bum test runs.
04/06/93 U.S. EPA, acting on the carbon monoxide and particulate certification, authorizes
WTI to begin the post trial bum phase of operations.
04/12/93 U.S. EPA imposes restrictions on WTI, precluding it from operating under the
conditions maintained during the two failed trial bum test runs.
04/12/93 OEPA issues letter allowing WTI to go back into operation.
04/14/93 U.S. EPA gives prior approval to proceed with Class 1 permit mod requested on
03/16/93.
04/14/93 WTI notifies U.S. EPA that it is implementing a Class 1 modification to add
newly EPA-listed waste codes K149, K150, and K151.
04/26/93 WTI reports failure during the trial bum to meet the stack emission limits for
mercury during 2 days of the trial burn.
04/26/93 GAO audits Region 5 from 04/26 through 04/30.
05/06/93 U.S. EPA meets with concerned citizens and representatives of Greenpeace in
Region 5 offices.
05/06/93 Greenpeace/Swearingen/Spencer file Environmental Appeals Board petition to
review the matter of the U.S. EPA's 04/06/93 authorization letter, and halt limited
commercial operation. (EAB 93-7)
05/07/93 U.S. EPA issues revised interim stack emission limits and waste feed rates for
Volume II
Appendix II-2
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toxic and carcinogenic metals, in response to the report from WTI that mercury
emissions exceeded the allowable limits.
05/08/93 WTI submits trial burn results.
05/11 /93 City of Pittsburgh/State of West Virginia file EAB petition to review the matter of
the U.S. EPA's 04/12/93 letter. (EAB 93-9)
05/27/93 WTI brings facility down for rebricking of kiln.
06/16/93 U.S. EPA issues letter expressing concern over dioxin levels in the trial burn
report and requesting details of how WTI will lower dioxin emissions. U.S. EPA
asks WTI to only burn low chlorine wastes until matter is resolved.
06/17/93 WTI responds with proposal regarding reduced chlorine feed.
06/17/93 WTI requests prior approval to implement a Class 1 permit modification
regarding minor changes to the Contingency Plan.
06/18/93 U.S. EPA sends letter telling WTI that its reduced chlorine plan is unacceptable,
and suggests facility not go back into operation until after a meeting in Chicago.
06/18/93 Ohio Attorney General's Office issues the results of its investigation into the
background of WTI, including its opinion that the partnership had dissolved.
06/21 /93 EAB denies review of petitions by (1) Greenpeace/Swearingen/Spencer, and (2)
City of Pittsburgh/State of West Virginia for lack of jurisdiction. (EAB 93-7 and
EAB 93-9)
06/24/93 WTI meets with U.S. EPA in Chicago, U.S. EPA expresses concern over
dioxin/furan levels. WTI interested hi meeting new dioxin levels and in pursuing
Class 2 permit modification to allow installation of enhanced carbon injection
system (ECIS).
06/25/93 WTI submits Class 2 modification request for ECIS. (See 10/28/93)
06/28/93 WTI submits request for temporary authorization to install, test, and operate
ECIS.
07/01/93 WTI notifies of requested Class 2 permit modification for adding labpacks to the
WAP, adding waste codes to the list of acceptable wastes, and for modifying the
Volume II
Appendix II-2
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Trial Bum Plan to perform a new test similar to condition 2 of the original trial
burn. (See 10/28/93)
07/02/93 Public notices published by WTI regarding all three Class 2 permit modification
being requested.
07/06/93 GAO audits Region 5 from 07/06 through 07/08.
07/08/93 U.S. EPA issues temporary authorization regarding ECIS.
07/19/93 Greenpeace/Swearingen/Spencer file hi the D.C. Circuit Court of Appeals
regarding the U.S. EPA's 04/06/93 decision to allow post trial burn operation.
07/23/93 WTI (via Waterman) notifies U.S. EPA of simple Class 1 permit modification to
resolve 3000 pound per square foot permit language issue.
07/23/93 City of Pittsburgh files hi Third Circuit Court of Appeals (Philadelphia) regarding
the U.S. EPA's decision to allow post trial burn operation (one petition
challenging 04/12/93 decision and a second petition challenging EAB's 06/12/93
denial on the basis of lack of jurisdiction).
07/27/93 WTI holds public information meeting regarding Class 2 permit modifications.
08/05/93 WTI begins 3-day ECIS performance test.
08/05/93 WTI submits Class 1 * permit modification request to add Von Roll America, Inc.
("VRA"), as an owner of the facility. (See 08/24/93)
08/06/93 WTI notifies U.S. EPA that it is implementing a Class 1 permit modification to
update two pages of the Waste Analysis Plan.
08/11/93 U.S. EPA authorizes WTI to go back into operation based on preliminary ECIS
test results.
08/24/93 U.S. EPA approves Class 1 permit modification adding Von Roll (Ohio), Inc., as
an additional operator; announces a tentative decision and public comment period
regarding adding VRA as owner; and files an enforcement action for failure to
notify of operator change and certain minor storage violations.
08/30/93 Start of 30-day public comment period regarding adding VRA to pennit.
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09/13/93 U.S. EPA informs WTI that WTI's 07/23/93 attempted Class 1 permit
modification to change language of Condition I.B.33. is not appropriate.
09/22/93 City of Pittsburgh appeals to EAB permit modification to add Von Roll (Ohio).
Inc., as additional operator. (EAB 93-11)
10/06/93 Court grants motion to transfer Third Circuit appeals to the D.C. Circuit.
10/20/93 U.S. EPA accepts revised interim feed rate limits for toxic and carcinogenic
metals.
10/20/93 WTI requests approval for a Class 1 * permit modification to resume use of
front-wall aqueous lance. (See 10/12/94 and 12/08/94)
10/28/93 U.S. EPA approves Class 2 permit modification requests for (1) modified trial
burn test condition 2; (2) adding seven newly listed K-series wastes; and (3)
permanent operation of ECIS. Proposed additions of labpacks to Waste Analysis
Plan is not acted on.
10/28/93 Court grants motion to consolidate Pittsburgh's transferred Third Circuit appeals
(Nos. 93-1682 and 1683) with Greenpeace's D.C. Circuit appeal (No. 93-1458).
11/19/93 Sixth Circuit Court of Appeals overturns the 03/05/93 Cleveland District Court
preliminary injunction.
11 /29/93 WTI appeals to the EAB the U.S. EPA's Class 2 permit modification of 10/28/93.
(EAB 93-16)
12/08/93 Risk assessment peer review panel meets for two days in Washington, D.C.
12/09/93 Wn files amended EAB appeal, dropping issue of 30 ng/dscm emission value for
PCDDs/PCDFs. (EAB 93-16)
12/10/93 Scrubber pump failure causes trip of induced draft fan while waste was still
burning in the rotary kiln, resulting in 3-5 minutes release of paniculate matter
from kiln seals.
12/18/93 WTI begins rerun of trial bum condition 2, but after having a string of equipment
failures, OEPA disapproves further attempts at testing until further notice.
01/03/94 U.S. EPA cites WTI for December 10,1993, violations.
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02/15/94 WTI begins second ECIS performance test, which continues through February 18.
02/22/94 WTI performs rerun of trial burn condition 2. Actual test runs occur on February
24 through 26.
03/07/94 WTI requests approval of a Class 1 * permit modification to change the
Contingency Plan to change 2 sump pumps from automatic to manual, to reduce
potential for accidental contamination of wastewater. (Approv 11/07/95)
03/12/94 WTI down for approximately 2 weeks for rebricking of kiln.
04/19/94 WTI submits results of 02/94 trial burn. Results demonstrate compliance with all
performance standards.
04/25/94 WTI conducts quarterly ECIS performance test, which runs through April 27.
04/29/94 U.S. EPA announces 60-day public comment period, starting on May 2, 1994,
regarding the 6 Plans which are attachments to the RCRA permit.
07/12/94 U.S. EPA opens 2-week comment period regarding Permittee's request to replace
slag quench tank. Comment period runs through 07/28/94. (See 8/19/94)
08/19/94 U.S. EPA approves WTI to proceed with proposed Class 1 permit modification to
replace slag quench tank, but defers decision on related request to simultaneously
add temporary storage tank for slag quench water. Response To Comments
document is sent to commenters.
08/19/94 WTI requests Class 2 permit modification to operate at lower temperature during
the November stack test.(See 11/09/94)
08/25/94 WTI publishes public notice of Class 2 permit modification request to change
upcoming November ECIS Performance Test. WTI proposes testing at lower kiln
temperature to give U.S. EPA more data at the lower temperature that had been
demonstrated during the trial burns.
08/29/94 WTI conducts quarterly ECIS Performance Test. WTI conducts two additional
test runs for a total of seven runs, and conducts extensive speciation of the volatile
and semi-volatile organic compounds captured from the stack gas during the test
runs. This speciation is done to more completely characterize the emissions so
that the U.S. EPA risk assessment can more accurately reflect actual emissions.
ECIS test runs and other testing conducted for Ohio proceed over a period of five
days.
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09/02/94 WTI facility brought down because of CO monitor problems and to begin
installation of new slag quench tank.
09/09/94 U.S. GAO releases its report on its 1 !/2-year investigation into the U.S. EPA's
issuance of the WTI RCRA permit, the validity of that permit, and the safety of
the WTI plant. The GAO finds that the U.S. EPA generally followed correct
procedures, that the RCRA permit is indeed valid, and that there are and will be
measures in place to ensure that the plant will not pose a threat.
09/13/94 U.S. EPA publishes its draft Dioxin Reassessment.
09/15/94 U.S. EPA Region 5 sends nine officials to East Liverpool to present information
on the Contingency Plan, Closure Plan, Waste Analysis Plan, Inspection Plan.
Training Plan, and Trial Bum Plan. This meeting was in response to a request
from three citizens' groups in the East Liverpool area, and was meant to assist the
community in participating in the public comment period on these plans.
Although the 60-day period ended in early July, comments were taken for an
additional two weeks after this public meeting. None of the representatives of the
citizens' groups attended the meeting.
09/15/94 WTI holds public information meeting for the Class 2 permit modification
proposal which was published on August 25,1994.
10/12/94 U.S. EPA announces a two-week public comment period regarding WTI's
proposal to be allowed to feed aqueous waste to the kiln and to increase total
waste feed rate to the quantity demonstrated during the February 1994 trial burn.
10/31/94 Oral arguments hi D.C. Circuit consolidated case brought by Pittsburgh and
Greenpeace.
11/09/94 U.S. EPA approves Class 2 permit modification request to conduct 4Q94 ECIS
performance test at a minimum kiln temperature of 1800°F. Response To
Comments document is sent to commenters on this issue.
12/05/94 WTI begins fourth and final quarterly ECIS performance test. This is comprised
of nine runs at the lower kiln temperature, followed by two runs at a higher
temperature similar to that of previous tests. Testing continues through
December 13.
12/08/94 U.S. EPA lifts some of the restrictions imposed in its April 12, 1993, letter.
Specifically, WTI is allowed to resume feeding aqueous waste to the front wall of
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the kiln, and to feed up to a total of 28,565 Ib/hr of waste. Aqueous waste feed to
the secondary combustion chamber remains prohibited.
01/13/95 D.C. Circuit Court of Appeals dismisses the consolidated petitions for review by
Greenpeace and the City of Pittsburgh.
01/23/95 EAB denies the City of Pittsburgh's petition for review (RCRA Appeal No. 93-
11) of the Region 5 permit modification to add VonRoll (Ohio), Inc.. to the
RCRA permit. Majority opinion is that the Region employed, with slight
variations, a USEPA-initiated modification under 270.4 l(b)(2), and that the
Region's action was a permissible exercise of its authority.
01 /27/95 EAB denies RCRA Appeal No. 93-16. This was WTI's petition for review of
certain additional, unrequested, requirements inserted into the facility RCRA
permit on October 28,1993, concurrent with the approval of the addition of the
enhanced carbon injection system.
02/10/95 WTI requests Class 2 permit modification proposing change to the Waste
Analysis Plan to allow for the receipt and incineration of labpacks. (See 02/28/95
and 05/08/95)
02/28/95 WTI holds Class 2 permit modification meeting regarding proposal submitted on
February 10, 1995, regarding the receipt and incineration of labpacks.
03/15/95 Extreme odor incident in surrounding community caused by WTI handling
paradichlorobenzene waste containing thiophenol. NOVAA asks WTI to not
handle waste until changes are in place to prevent recurrence.
04/20/95 OEPA holds a general information public meeting regarding several old and
current WTI permit modifications which still need to be acted on.
05/08/95 U.S. EPA reclassifies WTTs 02/10/95 permit modification request for labpacks
from Class 2 to Class 3.
07/11/95 USEPA approves 03/07/94 Class 1 * permit modification regarding sump pumps.
07/14/95 WTI requests approval of Class 1 * permit modification for updates to various
narrative sections and drawings in the Contingency Plan. This includes changes
to emergency coordinator list, relocation of safety equipment, and update of SPP
to include residue container areas.
07/26/95 USEPA approves 07/14/96 request for Class 1 * permit modification.
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11 /07/95 WTI requests Class 2 permit modification for additional waste codes and updated
procedures for the sampling and analysis of residues generated by the incinerator.
11/21/95 U.S. EPA releases draft of comprehensive risk assessment for the WTI facility.
This risk assessment includes a human health risk assessment, a screening
ecological risk assessment, and an accident analysis.
12/18/95 WTI holds a public meeting for a 11/07/95 Class 2 permit modification request
for additional waste codes and updated procedures for the sampling and analysis
of residues generated by the incinerator.
01/11/96 Meeting of Peer Panel in Washington, D.C., regarding the draft of the
comprehensive risk assessment.
01/30/96 U.S.EPA approves Class 2 permit modification requested on 11/07/95.
04/24/96 Dr. Robert Huggett, Assistant Administrator for Research and Development meets
with the East Liverpool community, as well as touring the WTI plant and meeting
with the Mayor.
05/02/96 Final Peer Review report regarding the WTI risk assessment is issued.
07/19/96 WTI requests Class 2 permit modifications for (1) direct liquid tanker truck
off-loading in bay 3 of the feed building, (2) processing of wet "rolloff'
containers of waste, (3) modifications to tank farm overflow and vapor recovery
piping, and tank level gauges, (4) modifications to waste flow piping in the tank
farm, and (5) steam heating of Tank T-7.
07/25/96 U.S. EPA issues written Response to Comments document regarding the
August 24 public meeting held by Dr. Huggett.
07/31/96 Timothy Fields, U.S. EPA's Deputy Assistant Administrator for the Office of
Solid Waste and Emergency Response, and David Ullrich, Deputy Regional
Administrator for U.S. EPA Region 5, hold two public meetings in East
Liverpool, tour the WTI plant, and meeting with community leaders.
08/16/96 U.S. EPA asks WTI to discontinue placing waste in the solid waste pits until WTI
submits a satisfactory plan to the U.S. EPA on how future fires will be prevented
in the future. After inspection and receipt of such information, USEPA allows
WTI to resume this operation on 08/23/96.
08/20/96 WTI holds public information meeting regarding the 07/19/96 Class 2 permit
modification proposal.
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