un«@a Slates       Office of          May 1990
           Environmental Protectiofi    Solid Waste
           Agency          Washington, DC 20460

           Solid Waste
&EPA      Background Document For
            Third Third Wastes To
            Support 40 CFR Part 268
            Land Disposal
           Third Third Waste Volumes,
           Characteristics, and Required and
           Available Treatment Capacity

           Volume IV
            APPENDIX J - APPENDIX M

-------
                        'TABLE OF CONTENTS (continued)
Section
    CAPACITY ANALYSIS METHODOLOGY
    4.1  Determination of Required Treatment Capacity..   .  .  .  .
         4.1.1   Waste Volumes Affected    .  ..........
                 4.1.1.(1).  Data Sources   ...........
                 4. 1:1. (2)  Identification  of Waste Volumes
                 4. 1.1. (3)  Determination of Affected Volumes
         4.1: 2   Treatabilityf Analysis '  .  .' '. '.  ...  . *.  .-• . .  .  .
                 4.1.2.(i)  Waste Characterization   ......
                 4. 1.2. (2)  Treatability Grouping/Assigning .  ',
                      .  "-'v Alternative Treatment    ......
                 4. 1.2. (3)  Treatment Residuals    .  . .  .....'.
                 4. ,1.2. (4)  Previous 'Management    .  .....  .  .  .  .

    4.2  Determination of Available  Treatment Capacity   ...  .  .
         4 . 2 .1, v Determination of Combustion Capacity   v  .'  .  .
                 U.2.l.(l)  Introduction   .....  .......
                 4. 2.1. (2)  Approach and Methodology for
                            the Original Combustion Data Set
                            Used for the Proposed Rule   .  .  .  .
         4.2.2  -Determination of Other Treatment System
                 Capabilities    ...,...."  ........
                 4.2.2: (1)  Unit Process Capacity    ......
                ,4. 2. 2. (2)  • Hazardous .Waste Treatment/Recovery
                            System Identification    ......
                .,4. 2. 2. (3). Determination of System Capacity
                 4. 2. 2. (4)  Projections of  Available Capacity
         4.2.3   Development of the  Treatment Capacity Data
                 Set and Results  .   ... ....... ^. • .......
                 4.2.. 3. (1)  Incineration/Reuse-as-Fuel Data Set
                            Results    .............
                 4. 2. 3. (2)  Development of  the Data Set for
                            Other Treatment Systems   .....
                 4. 2. 3. (3)  Treatment Capacity Data Set Results

    4.3  Capacity Analysis  (Comparison of Required and
         Available Treatment Capacity)   ............

Volume II

APPENDICES     .       :.'•''

Appendix A - Leachate    . ............. '« ......

Appendix B - Mixed Radioactive Waste   ........ .....
                          /
Appendix C - Available Capacity;iAnalyses for Each Rule and
             Addition of Recent ChemWaste Management Data    .  .

Appendix D - Capacity Analysis for Third Third Promulgated
             Wastes    .....  ................
4-1

4-1
4-1
4-1
4-2
4-2
4-5
4-5
4-8
4-10
4-11

4-12
4-12
4-12
4-15

4-19
4-19

4-22
4-25
4-32

4-33

4-33

4-37
4-39


4-43
A-l

B-l


C-l


D-l
                                    ' ' vi
                                               I

-------
                         TABLE  OF  CONTENTS  (continued)
Section

Appendix. E   Capacity Analysis for Contaminated Soil Wastes

Appendix F   Documentation of Waste Volumes for Waste Codes
             Addressed in Previous Rules

Appendix G   Documentation for California List HOCs

Appendix H   Bibliography for the Third Third Land Disposal
             Regulations

Appendix I   Memorandum on Availability of Surveys

Appendix J   Analysis of Commercial Alkaline Chlorination
             Capacity

Appendix K   Analysis of Commercial Sludge/Solid Combustion
             Capacity

Appendix L   Miscellaneous Phone Logs

Appendix M   Analysis of Large Volume Underground Injected
             P and U Coded Wastes
Page


E 1


F-l

G-l


H-l

I 1


J 1


K-l

L-l


M-l
                                     VLl

-------
                                LIST OF TABLES
Table ES-1    Summary of National Capacity Variances for Surface
              Land-Disposed Wastes

Table ES-2    Summary of Two-Year National Capacity Variances for
              Underground  Injected Wastes

Table ES-3    Determination of Available Commercial Capacity for
              Third Third  Wastes (million gal/yr)

Table ES-4    Required Alternative Commercial Treatment/Recycling
              Capacity for Surface-Disposed Wastes (million gal/yr)

Table ES-5    Required Alternative Commercial Treatment/Recycling
              Capacity for Deepwell-Disposed Wastes (million gal/yr)

Table ES-6    Required Alternative Commercial Treatment/Recycling
              Capacity For Soil and Debris Wastes (million gal/yr)

Table ES- 7    Summary of Capacity Analysis for Mixed Radioactive
              Wastes

Table ES-8    Summary of Capacity Analysis for Third Third Wastes
              by Waste Code [includes all wastes regulated under
              Third Third]

Table 1 1     Third Third  Final Rule Wastes by Waste Code

Table 2-1     Overview of All Surface Disposed RCRA Hazardous
              Wastes (revised based on ChemWaste Data)

Table 2-2     Overview of  Surface Disposed Solvent Wastes
              (revised based on ChemWaste)

Table 2-3     Solvent Capacity Analysis (revised based on new
              CheraWaste Management Numbers)

Table 2-4     Overview of  Surface Disposed Potential California
              List Wastes Containing Halogenated Organic
              Compounds

Table 2-5     Overview of Surface Disposed First Third
              Promulgated Wastes Containing Halogenated
              Organic Compounds

Table 2-6     Overview of All Other Surface Disposed Wastes
              Containing Halogenated Organic Compounds

Table 2-7     Capacity Analysis for HOC Wastes (Excluding First
              Third and Third Third Promulgated HOCs)
Page
 No.

E-8


E 9


E-13


E 15


E 18


E-19


E-20



E-22

1  12


2-16


2-18


2-20



2-21



2-22


2-23


2-25
                                     Vlll

-------
                           LIST OF TABLES (continued)
                                                                          Page
                                                                           No.
 Table 2-8     Overview of All Surface Disposed First Third
               Wastes

 Table 2-9     Overview of Surface Disposed First Third
               Promulgated Wastes

 Table 2-10    Capacity Analysis  for First Third Promulgated
               wastes

 Table 2-11    Capacity Analysis  for Underground Injected
               Solvent Wastes

 Table 2-12    Capacity Analysis  for Underground Injected
               California  List Wastes

 Table 2-13    Capacity Analysis  for Underground Injected First
               Third Wastes

 Table 2-14    Overview of Second Third  Promulgated Wastes

 Table 2-15    Overview of Surface  Disposed  Second Third
               Promulgated Wastes   .  .        ...

 Table 2-16    Capacity Analysis  for Surface  Disposed Second
               Third Promulgated  Wastes

 Table 2-17    Capacity Analysis  for Underground Injected
               Second Third Promulgated Wastes

 Table 2 -1'8    Soft  Hammer Wastes from the First Third  and
               Second Third Final Rules
 2-30
 2-33
 2-38

 2-42


 2-43


 2-45


 2-47
Table  2-19    Determination of Available Commercial Capacity
              for Third Third Wastes         ....

Table  2-20    Overview of Third Third Promulgated Wastes

Table  2-21    Summary of Capacity Analysis for Third Third
              Promulgated Wastes           ...

Table  2-22    Summary of Capacity Analysis for Underground
              Injected Third Third Promulgated Wastes     .  .

Table  2-23    Summary of Capacity Analysis for Third Third
              Promulgated Soil and Debris Wastes

Table  2-24    Summary of Capacity Analysis for Mixed
              Radioactive Wastes             .   •    •  •
 2-52

 2-54


 2-56


 2-58


2-60


2-63
                                      IX

-------
                          LIST OF TABLES  (continued)
Table 3-1


Table 3-237

Table 3-238
Capacity Analysis Tables for Each Waste Code
(Use Exhibit 3-1 Index)

Volume of Contaminated Soils Land Disposed

Summary of Capacity Analysis for Third Third
Promulgated Soil and Debris Wastes (Soil
and Debris only)
Table 3-239   Capacity Analysis for Each Waste Code (Soil and Debris)
Page
 No.

3-15
3-360



3-361

3-362
Figure 4-1    Process Codes

Figure 4-2    Flow Diagram of a Simple System

Figure 4-3    Flow Diagram of Systems with Unit Process
              Capacities

Figure 4-4    Flow Diagram of One System with Two Units
              Conducting the Same Process

Figure 4-5    Flow Diagram With Unit Capacities

Table 4-1     Summary of Commercial Hazardous Waste
              Incineration Capacity

Table 4-2     Summary of Commercial Capacity for Reuse of
              Hazardous Waste as Fuel

Table 4-3     Summary of Commercial Treatment System
              Capacities
                                                           4-20

                                                           -4 23


                                                           4-24


                                                           4-26

                                                           4-28


                                                           4-35


                                                           4-36


                                                           4-40

-------
                 APPENDIX J

ANALYSIS OF COMMERCIAL ALKALINE CHLORINATION/
       CHEMICAL PRECIPITATION CAPACITY

-------
                                  APPENDIX J

            ANALYSIS OF COMMERCIAL ALKALINE CHLORINATION/CHEMICAL
                            PRECIPITATION CAPACITY
                        (all data in gallons per year)


      To verify projected capacities reported in the TSDR Survey, EPA

contacted the facilities that anticipated in 1989 additional available

capacity for alkaline chlorination followed by chemical precipitation.  Based

on the information provided by the facility contacts, EPA has determined that

four facilities (American Waste Processing LTD (ILD00716894),  Envirite

Corporation (PAD004835146),  Mill Services Inc Yukon Plant (PAD004835146),  and

OSCO Treatment Systems Inc.  (TND980515779)) did not come on-line as projected.

For two facilities (Envirite Corporation (PAD004835146) and Mill Services Inc.

(PAD059087072)),  available capacity data are adjusted based on the additional

information provided by the facilities and by engineering judgement.   For one

facility (Cyano Kern (MID09801192),  the available capacity is updated based on

the information provided in the comment letter (Letter Number LD12-00110 dated

January 5, 1990)  submitted by the facility.  As a result of the facility

contacts and other information aide available during the comment period, 1989

available capacity data have been adjusted to reflect this additional

information as shown in Table 1.

-------
                                               J-2                            Appendix J

    Table  1.           Capacity  Analysis  For  Alkaline  Chlorinacion/Chemical Precipitation-



          Total  available  capacity  for  1989-90  (p.  791)                      -   51'8°6'oAO
          Add  capacity of  Mill  Service's gen. chem. precip.  process  (p.90)2  - +  2'^U'QQQ
          Add  additional capacity from  comment  letter L593 for Cyano Kern     - +    OOA nnn
          Add  additional capacity for USPCI, Uaynoka,  OK*5                   ' "*"    nOO 000
          Deduct capacity  reported  by American  Waste  Processing              " "  I''
          Deduct capacity  reported  by Osco Treatment  Systems                 " " 12
          Deduct capacity  reported  by Envirite(expansion  for  89-90)          • '  •>
          Deduct loss  of capacity reported by Envirite  for 1988              "    ?
          Deduct capacity  reported  by Mill Services Yukon Plant              - -  ^
                                                                                79
          Total  available  capacity                                               ^^

          Deduct required  capacity  for  the previous rules                    " ' 11,000,000

          Remaining  capacity  for Third Third vasces                          -   11,120,841
      1 All page numbers refer to fi?mm,yr,cial Trtiyujnt/Recoverv Capacity Data Set.  November
 1989    Prepared for  the Office of  Solid Waste.  Washington, D.C.:  U.S. Environmental
 Protection Agency.

      2 One of the systems of this facility is categories as general chaaical precipitation.  A
 review  of the schematics and survey indicated that this system has the capacity for  alkaline
 chlorination as well as chemical precipitation.

      3 This com*enter stated that they have about 13.8 million gallons per year maximum
 capacity at this  facility.  Of this, 12.8 million gallons per year is already  reported in the
 TSDR  Survey   The remainder is incorporated in the capacity analysis  (p.  78).

      4  Basis  is provided in phone logs for the details of discussion with facility  contacts.

      5The available capacity is about 85% of annual maximum capacity  (1,040,000 gallons).  The
maximum capacity  is calculated at the rate of 4,000 gallons per  day  for 260  days.

     'This  loss  of capacity is  due to mis-coding of the TSDR Survey information in the data
set.  The actual available capacity of the facility is  arrived as follows:   The maximum  annual
capacity for alkaline chlorination followed by chemical precipitation is  25X (4,260,000
gallons) of facilities maximum annual capacity (17,040,000 gallons).  Only 25Z  (based on annual
maximum capacity and utilization at the facility) of  this capacity is available capacity for
alkaline chlorination and chemical precipitation.  The  loss of capacity (3,203,640 gallons)  is
the difference of the available capacity reported in  the data set (4,268,640 gallons)  and
actual available capacity calculated (1,065,000 gallons) above.

-------
                                      J-3




                                 PHONE LOG FOR




                               FACILITY CONTACTS
Appendix J
Caller:           Ravindra Sannareddy




Name of Contact:  Craig Bruell




Phone Number:     405-697-3236




Title:




Location:         USPCI, Waynoka  (OKD065438376)




Date:             April 24, 1990, 4.25 p.m.




Purpose of Call:  Obtain the information on the permitted capacity for the




                  following process.




                  Alkaline Chlorination/Chemical Precipitation




Report on Discussion:




       1.    The maximum capacity  of the process at this facility is waste




            dependent.  The maximum capacity varies from 2,000 gallons per day




            to 6,000 gallons per  day.




       2.    The current utilization of this process is about 10X to 20X of the




            maximua capacity.
Any Follow up Planned:

-------
                                      J-4




                                 PHONE LOG FOR




                               FACILITY CONTACTS
Appendix J
 Caller:            Ravindra  Sannareddy




 Name  of  Contact:   Joseph  A  Strosnik




 Phone Number:      708-681-3999  (708-278-3999)




 Title:             Project Engineer




 Location:          American  Waste  Processing  (ILD000716894)




 Date:              March 20,  1990, 11.00  a.m.




 Purpose  of  Call:   Obtain  the  information on  the permitted capacity  for the




                   following process.




                   Alkaline  Chlorination/Chemical Precipitation




 Report on Discussion:




       1.    The planned treatment process with a maximum annual  capacity of 15




            million gallons for 1988 never came on-line.




       2.    The facility  has  dropped the plans of expansion  and, hence,  the




            capacity reported in  the TSDR Survey will not be  available in the




            future.
Any Follow up Planned:

-------
                                      J-5




                                 PHONE LOG FOR




                               FACILITY CONTACTS
Appendix J
Caller:           Ravindra Sannareddy




Name of Contact:  Samuel J. Campagna




Phone Number:     615-381 1058




Title:            Director of Environmental Services




Location:         Osco Treatment Systems Inc. (TND980515779)




Date:             April 20, 1990, 4.30 p.m.




Purpose of Call:  Obtain the information on the permitted capacity for the




                  following processes.




                  Alkaline Chlorination/Chemical Precipitation




Report on Discussion:




       1.    The planned treatment process  (maximum annual capacity of 1.3




            million gallons in 1988) never came on-line.




       2.    The facility has plans to bring about 150,000 - 250,000 gallons




            per year capacity by October 1990.
Any Follov up Planned:

-------
                                      J-6                           Appendix  J




                                 PHONE LOG FOR




                               FACILITY CONTACTS




Caller:           Ravindra Sannareddy




Name of Contact:  Curvin Snyder III




Phone Number:     717-846-1900




Title:            Operation Manager




Location:         Envirite Corporation (PAD010154045)




Date:             April 24, 1990, 10.30 a.m.




Purpose of Call:  Obtain the information on the permitted capacity  for  the




                  following process.




                  Alkaline Chlorination/Chemical Precipitation




Report on Discussion:




      1.    The planned treatment process (maximum annual capacity  of 12




            million gallons in 1989-90) never came on-line.




      2.    The facility operates in a batch process with a capacity of 50,000




            to 65,000 gallons per day (i.e., 71,000 tons per year as reported




            in TSDR Survey).  Only 20-25Z of this capacity is available for




            alkaline chlorination, even if there is demand for more capacity.




            The remaining 75X of the capacity is utilized by chrome reduction




            using ferric sulfate (up to 25Z of  total capacity), neutralization




            and other wastewater treatment processes available at the facility




            (up to SOX).




      3.    It looks like there is a decline in the amount of liquid wastes




            they are receiving at the facility.









Any Polloir up Planned:

-------
                                      J-7




                                 PHONE LOG FOR




                               FACILITY CONTACTS
Appendix J
Caller:           Ravindra Sannareddy




Name of Contact:  Gary Berman




Phone Number:     412-343-4900




Title:




Location:         Mill Services  Inc Yukon Plant  (PAD059087072)




Date:             April  25,  1990,  10.25 a.m.




Purpose of Call:  Obtain the information on the  permitted capacity for the




                  following  process.




                  Alkaline Chlorination/Chemical Precipitation




Report on Discussion:




       1.    The  State of Pennsylvania did not authorize the treatment of




            cyanide wastes at  this facility and, hence, the facility did not




            expand for the above process as planned.




       2.    Mr.  Berman said  that they don't have any customers for the above




            process; they will pursue their permit application if there is




            demand.
Any Follow up Planned:

-------
                      APPENDIX K




Analysis of Commercial Sludge/Solid Combustion Capacity

-------
                                      K-2
K.I. INTRODUCTION

      During the public comment period for the proposed Third Third rule, EPA
received several comments on available sludge/solid combustion capacity
Commenters indicated that EPA had omitted available units, included units that
may not actually be available, and incorrectly estimated capacity for some
units.  Sources of suggested error included new operating parameters resulting
from permits issued since the TSDR Survey, and new hazardous fuel blending and
burning techniques that increase capacity for reusing sludges and solids as
fuel.  Since the statutory deadline for incineration permit decisions passed
in November of 1989, EPA agreed that recent permits could have affected
national incineration capacity.  As a result, EPA has obtained updated
information from EPA regional and state environmental regulatory offices (and
in a few cases from the incineration facilities) and has reevaluated available
sludge/solid combustion capacity based on these data.  This Appendix, discusses
EPA's sludge/solid combustion capacity verification analysis.

      EPA  first compiled lists of commercial incineration facilities in each
EPA  region.  These lists contained more than 150 facilities identified from
the  TSDR Capacity Data Set, commercially published literature, public comments
on  the proposed Third Third rule and other sources.  EPA contacted regional
and  state  environmental regulatory officials to determine the operating and
commercial status of each facility on the lists, and identify commercial
facilities that burn or plan to burn sludges and solids.  Regional and state
contacts indicated that many of these facilities were planned commercial
incinerators at various stages of development.  EPA found many of these
facilities to be non-commercial incinerators that burn wastes generated on-
site  (on-site facilities) or off-site facilities under the same ownership
(company captive facilities)   A few facilities were identified as hazardous
waste fuel burners, reportedly burning liquids only, or specialized material
recovery facilities units that are not truly commercial since they accept a
very limited variety of wastes.  Permitting officials indicated that some
planned commercial incinerators appear to be inactive or abandoned.

      Through contacts with the regional and state regulatory agencies, EPA
has  verified 12 currently operating truly commercial hazardous waste
incineration facilities having sludge/solid capacity.  Alchem-Tron is excluded
from this  group since its operation will be delayed until 1991 while it awaits
a state permit.  The following facilities have been omitted from the data set
since the  proposed rule since they are not truly commercial hazardous waste
incinerators:

      •     RFE Industries in New Jersey is a materials recovery facility that
            does not accept wastes from the general public for incineration.

      •     BDT, Incorporated in Clarence, New York is a small metals recovery
            facility

      •     Groce Laboratories in Greer, South Carolina operates several small
            research units.

-------
                                      K-3

      Table K-l summarizes the revised commercial sludge/solid incineration
capacity estimates.  This table provides the 1986 utilized capacity obtained
from the TSDR Capacity Data Set and used for the final rule.  It also shows
the maximum capacity estimates reported in the TSDR Capacity Data and used for
the proposed rule; along with the revised maximum sludge/solid capacity
estimates used for the final rule.   Table K-2 presents revisions to the
commercial sludge/solid reuse as fuel capacity data since the proposed rule.
The aggregated sludge/solid reuse as fuel capacity estimate includes all
estimates obtained from the TSDR Capacity Data Set,  including CBI facilities.
Facilities presented individually on this table are discussed in Section K.4.

      The remainder of this Appendix describes EPA's method of determining
maximum, or design capacity to burn sludges and solids at currently operating
and planned commercial incinerators that burn sludges and solids.  It also
describes EPA's analysis of the three Ash Grove Cement Company facilities that
were identified as burning sludges  and solids during the public comment
period,  and updated information on  several reuse as  fuel facilities reported
in the TSDR Capacity Data Set.   It  includes the following sections:

      •      Section K.2:  General Methodology and Assumptions for Commercial
            Incinerators:  This section describes general methodology and
            assumptions used to analyze sludge/solid incineration capacity
            It discusses the type of capacity data generally obtained from
            regional and state officials,  and the methods used to estimate
            annual maximum sludge/solid capacity from this data.

      •      Section K.3:  Individual Incineration Facility Analyses:   This
            section separately discusses EPA's analysis of each incineration
            facility

      •      Section K.4:  Sludge/Solid Reuse as Fuel  Analysis:  This  section
            discusses EPA's analysis of sludge/solid reuse as  fuel  capacity at
            Ash Grove Cement Company facilities.   It also describes updates to
            other reuse as fuel facilities reported  in the TSDR Capacity Data
            Set.

      •      Section K.5:  Planned Incineration Capacity Additions:  This
            section discusses the status and capacity of incineration units
            that  EPA expects to come on-line by the  end of 1992.   It also
            lists planned additions reported in the  TSDR Capacity Data Set for
            1989  through 1992 that  EPA believes will be delayed beyond 1992

      •      Section K.6:   Phone Logs:   This section  contains logs of each
            conversation that provided data used EPA's sludge/solid combustion
            capacity verification analysis.   Calls are organized
            chronologically for each EPA region.   Calls to facilities  are
            logged at the end of this section.

-------
                                TABLE HI
SUMMARY OF COMMERCIAL SLUDaBSOUD INCINERATION CAPACITY THROUGH 1002
NAME
ALCHEM-TRON, MC.
CLEVELAND. OH
OHMOMB43*
ATTUV
COFFEEVHE. KB
KOOM1608026
APTIM (WESTtNOHOUSE)
TOELE.UT
CAUFORMA THERMAL TREATMENT
VBWON.CA
CHEMICAL WATTE MANAGEMENT
KETnCMAN mJLM. CA
CHEMICAL WASTE MANAGEMENT
•ALMCT. •.
UMMM2424
CHEMICAL WASTE MANAGEMENT (8CA)
CHCAaO.lt
•JMOM72I2I
CHEMICAL WASTE MANAGEMENT
POUT ART HUH. TX
TKDOOOMM
ENKO
UAAACOPA.AZ
iMVMONMENTAL •VCTEM8 CO.
ELDORADO. AR
AADOW74*I*2
FLOMDA FIRST
POLK COUNTY. FL
LAMD. MC.
CAt.VEHT.KY
KVDOW49M17
ROUJMS ENVIRONMENTAL SERVICES
BATON ROUOE. LA
LADOI03M127
ROLLMO ENVMONMENTAL SERVICES
•noQEpom. NJ
NJD0433M739
ROU.MS ENVIRONMENTAL SERVICES
DEER PARK. TX
TX00MI4137*
UNIT
TYFB1
n
HK
m
RK
UK
FH
FH
FH
MflK
HX
RK
WRK
MRK
MHK
RK
RX
ttrn
RK
CM
CM
RK
RK
RK
RK
RK
RR
RR
MAY MAY DEC DEC DEC DEC
IftM MAXIMIMUM CAPACITY 1960 IWO IWO IMO IW1 IWt
UTILIZED FROMT80R MAXIMUM AVAH>BLE MAXIMUM AVAJLABLE MAXIMUM AVAEABLE
CAPACITY CAPACITY DATA SET CAPACTTV CAPACITY CAPACITY CAPACITY CAPACITY CAPACITY
(TONWVn) (TON8/YR) (TONWYR) (TONaTYR) (TONWVR) (TONWYR) (TONS/YR) (TONanrR)
0
0
0
0
0
CM
cat
cat
0
CM
CM
0
0
0
20.670
0
0
0
CM
CM
666
7.IOO
0
16.324
0
0
0
M.BOO
0
0
0
0
CM
CM
0
0
CM
CM
0
0
0
21.170
•.000
0
0
CM
CM
2 MOO
10,000
0
41.122
42.160
0
0
0
0
0
0
0
1.MO
1.MO
t.MO
».36»
16.0*4
0
0
0
0
w.aoo
0
14.400
0
3.312
30.431
31.7*4
16.600
0
32.400
36.640
32.400
0
0
0
0
0
0
CM
CM
CM
2»,M*
CM
0
0
0
0
i*.oao
0
14,400
0
CM
CM
31.22O
6,480
0
17 07A
36.S4O
32.4OO
0
0
0
0
0
0
i.too
i.too
1.600
2».36»
1 6,O*4
126. 1OO
0
0
0
3*.*00
0
I4.4OO
0
3.312
30.43*
31.7*4
16.500
0
32.4OO
36.640
32.400
0
0
0
0
0
0
CBI
CM
CM
20.36*
CM
CM
0
0
0
I*.OM
0
14.400
0
CM
CM
31.220
(.400
0
17,078
36.«40
32.4OO
0
28.MO
27.0OO
30.800
0
0
1,900
1.6OO
i.too
29.3M
16.0*4
126.1OO
12.600
12,100
12,800
3».*OO
0
14.4OO
0
3.312
30.43*
31.7*4
16,680
0
32.400
36.840
32,400
0
28.600
27.000
30,800
0
0
CM
CM
CM
28.36*
CM
CM
12.6OO
12.600
12.600
10.030
0
14.400
0
CM
CM
31.220
6.480
0
17.078
36,840
32.400
0
DEC DEC
1002 1S02
MAXIMUM AVAILABLE
CAPACITY CAPACITY
(TON8/YR) (TONSfYR)
26.800
27,000
30,800
18,676
27.760
1.SOO
1.600
i.too
29.36*
16.0*4
126. 1OO
12.6OO
12.600
12.600
30.800
0
14.400
27.706
3.312
30,43*
31.764
I6.68O
10.400
32.400
36.840
32400
0
2t.*00
27,000
3O.800
1*.*76
27.760
CM
CBI
CBI
20.36*
CBI
CM
12.6OO
12,600
I2.6OO
10,030
0
14.400
27.706
CBI
CM
31.220
*.48O
10.400
17.076
36.840
32.400
0
                                                     K-A

-------
                                                               TABLE K-I
                              SUMMARY Of COMMERCIAL Si UDOEJSOtlD INCINERATION CAPACITY THROUOH IW2
NAME
                                              MAY          MAY          DEC         DEC         DEC          DEC          OfcC          DEC
            1(66      MAXIMIMUM CAPACITY      10*0          I MO          10*0         I WO         IWI          1001          1001          1002
 UMT     l/nUZED        FROMTSOR        MAXIMUM     AVAILABLE    MAXIMUM   AVAILABLE    MAXIMUM     AVAILABLE    MAXIMUM     A V At ABIE
TYPBl   CAPACITY    CAPACITY DATA SET    CAPACfTY     CAPACITY    CAPACITY    CAPACITY    CAPACITY     CAPACITY    CAPACITY      CAPACITY
         (TON8/YR)        fTONSrVR)        (TONB/YR)     (TONS/YR)    (TOMS/YR)    (TONS/YR)    (TONS/YR)     (TONS/YH)    (TONSfifH)     (TONS/YH)
ROSS MCWERATION SERVICES CBI CM
ORAFTON.OH
ON004MI66W
RHONE -POULENC BASK CHEMICALS 8R 0
(FORMERLY STAUFFER CHEMICAL)
HOUSTON. TX
TXD00606M70
RHONE -POULEKC BASIC CHEMICALS BH 0
(FORMERLY STAUFFER CHEMICAL) SR 0
BATON nOUOE. LA
LAOOO*t61234
THERMALKEM FH 11.700
noCHHJLL.SC
SOD0444423M
IMTCI NKNOW 0
TOELE.OT
MUTE-TECH FB 0
KMBALL.NE
AOOREOATE CM 26.121
TOTAL (TONS/YEAR) • 1 ,460
NOTES:
ItMttTyp*.:
M.bilraradUnH
FB-FkiWIntfBtd
CBI 16.200 CBI 10,200 CM I6.2OO CBI 18.200 CBI
000 66.320 66.320 66,320 66.320 66,320 66.320
000 60.147 60.147 60,147 60.147 60.147 60.147
000 106,266 106.266 106.266 106.266 106.266 106.266
17.626 16.427 6.637 16.427 6.637 18.427 6,637 16,427 6,637
0 0 0000 0 12,606 12,606
0 0 0000 0 4.6OO 4.600
36.406
234.37* 320.003 166.10* 671.636 304.641 706.736 618.741 606.660 616.546

-------
                                                                                       TABLE K-2
                                                               COMMERCIAL HAZARDOUS WASTE REUSE AS FUEL CAPACITY FOR SLUDGES AND SOLIDS


UNIT
TYPB1
NAME
AGGREGATE FROM TSDR CAPACTIY
DATA SET
ASH GROVE - CADENCE CK
LOUISVILLE. NE CK
NED007200A72
ASH GROVE - CHANUTE CK
CHANUTE. KS CK
KSO03 12033 18
ASH GROVE - FOREMAN CEMENT CK
FOREMAN. AH CK
ARDO8 161 2270
KOSMOS CEMENT COMPANY CK
(SOUTHDOWN PORTLAND)
LOUISVILLE. KY
KYD024111M1
SOUTHDOWN PORTLAND CEMENT CK
KNOXVILLE. TN
UNITED CEMENT COMPANY CK
ARTESIA. MS
MSO0770SM78
MAY MAY DEC
1080 1990 1990 1990
UTILIZED MAXIMUM AVAILABLE MAXIMUM
CAPACITY CAPACITY CAPACITY CAPACITY
(TON8/YR) (TONS/YR) (TONS/YH) (TONS/YR)
0 29.885 20.885 29.885

0 12.000 12,000 12.000
0 12.000 12.000 12.000

0 12.0OO 12.OOO 12.000
0 12.000 12.0OO 12.000

0 12.000 12.000 12.000
0 12.000 12.000 12.000

000 12.000



000 12.000

000 77.500


DEC
1990
AVAILABLE
CAPACITY
(TONS/YH)
29.885

12.000
12.0OO

12.000
12.000

12.000
12.000

12,000



12.000

77.500


DEC
1991
MAXIMUM
CAPACITY
(TONS/YR)
29.885

12,000
12.000

12.000
12,000

12,000
12.000

12.000



12.000

77,500


DEC
1991
AVAILABLE
CAPACITY
(TONS/YH)
29.885

12.000
12.000

12.000
12.000

12.000
12.000

12.000



12,000

77.500


DEC
1992
MAXIMUM
CAPACITY
(TONS/YR)
29.885

12.000
12.000

12.000
12.000

12.000
12.000

12.000



12.000

77.500


DEC
1902
AVAILABLE
CAPACITY
(TONS/YR)
29.885

12.000
12,000

12.000
12.000

12.000
I2.OOO

12.000



12.000

77.5OO


TOTAL (TONS/YEAR)

NOTE  CK - CEMENT KILN
                                                        101.885
                                                                      101,885
                                                                                203,385
203.385
                                                                                                          203.385
                                                                                                                          203.385
                                              203,385
                                                             203.385
                                                                               K-6

-------
                                     K-7

K.2  GENERAL METHODOLOGY AND ASSUMPTIONS  FOR COMMERCIAL INCINERATORS

      EPA first contacted regional  and  state permitting agencies to obtain
both professional estimates of each facility's sludge/solid capacity and, if
applicable,  the permitted sludge/solid  capacity limit.   EPA obtained permit
limits on either (1)  mass feed rates for  specific waste forms (e.g., sludges
and solids,  containerized solids,  aqueous wastes),  (2)  overall mass feed rates
to a particular unit or the facility, or  (3) heat release or heat input limits
to a particular unit or facility.   These  limits came from draft or final
permits or from the permit application,  as applicable in each case.  EPA used
a slightly different method for estimating sludge/solid capacity in each of
these three cases.

      When specific trial burn mass feed rates were obtained, EPA summed and
extrapolated the sludge and solid feed  rates to estimate maximum sludge/solid
capacity   If no other limit was specified (e.g., total feed to the facility),
EPA simply projected the total sludge/solid feed rate directly to an annual
estimate by multiplying the hourly feed by 7200 hours per year,  the assumed
number of operating hours for hazardous waste incinerators.   For example, if
the trial burn demonstrated 500 Ib/hour of containerized solids, 1000 Ib/hour
of bulk solids, 2000 Ib/hour sludges, and 800 Ib/hr energetic liquids,  the
maximum annual sludge/solid capacity would be obtained as follows:

                           500 Ib/hr containerized solids
                  +      1,000 Ib/hr bulk solids
                  +      2,000 Ib/hr sludges
                  x      7,200 hr/yr
                  /      2.OOP Ib/ton	
                        12,600 tons/yr sludges and solids

      If an overall limit was imposed in addition to the trial burn feed
rates, EPA apportioned the overall maximum capacity to individual waste forms
based on the percentage of sludges and solids specified in the trial burn
plan.  For example if trial burns demonstrated 1500 Ib/hour of aqueous and
1500 Ib/hour solids,  and the overall feed rate to the unit was limited to 2000
Ib/hour (or the equivalent) the maximum annual sludge/solid capacity would be
estimated as follows:

                         1,500 Ib/hr containerized solids
                  /     (1,500 Ib/hr solids + 1,500 Ib/hr liquids)
                  x      2,000 Ib/hr total feed limit
                  x      7,200 hr/yr
                  /      2.000 Ib/ton	
                  -      3,600 tons per year solids


      If specific trial burn feed rates were not available, but some general
mass feed limit (e.g., total tons to unit per year); EPA relied on engineering
judgement to select the portion of the permit limit that could be practically
allocated to burning sludges and solids   For rotary kilns in general, EPA
used 75 percent of the permit maximum to represent the maximum sludge/solid
capacity   For fixed hearth kilns in general, EPA used 25 percent of the

-------
                                      K-8

overall permit specification.  While  it  is conceivable that any given facility
could burn more that these fractions  under select conditions, it is unlikely
that all units could maintain a higher fraction of sludges and solids over an
entire operating year   This judgement is based on the conclusion that certain
volumes of liquid wastes require incineration and will be burned at these
commercial facilities.

      The following assumptions were  used throughout analysis:

      •     We assumed that commercial incinerators operate 7200 hours per
            year (this corresponds  to 365 days of planned 24 hour operation
            with slightly more than 15 percent down time).

      •     EPA. used a conversion factor of 2000 Ib/ton to convert feed rates
            expressed in pounds to  tons.

      •     To convert between gallons and tons, EPA used a factor of 240
            gallons per ton based on  the density of waster.

-------
                                      K-9

K.3. INDIVIDUAL INCINERATION FACILITY SLUDGE/SOLID CAPACITY ANALYSES

Chemical Waste Management (Trade Waste Incineration), Sauget,  IL

      Four units are currently operating at this facility according to EPA
regional and state contacts.  Only two of these units were reported in the
TSDR survey response.  The third unit has come on-line in the past two years,
is fully permitted, and is currently burning hazardous wastes.  Trial burns
have been conducted and analyzed for the fourth unit, and it is currently
burning hazardous wastes under limited post-trial burn conditions pending
finalization of the permit which is expected within a few weeks.

      Units 1, 2, and 3 are fixed-hearth incinerators rated at 16, 25, and 30
MBtu/hr, respectively.   The only capacity estimates originally available from
region and state contacts were 2000 Ib/hr total waste feed estimates based
loosely on an assumed average waste heat value of 8000 Btu/lb and each units'
maximum thermal ratings.   EPA used 25 percent of these overall estimates as
our maximum sludge/solid estimates based on engineering judgement for fixed-
hearth units.  Extrapolating the resulting 500 Ib/hr method,  EPA obtained a
maximum annual sludge/solid estimate of 1,800 tons/yr for each of these three
units.
      The fourth unit at this facility is a potentially mobile rotary kiln
with a vertical secondary chamber rated at 50 MBtu/hr.   EPA based our estimate
of this unit's sludge/solid capacity on actual trial burn feed rates.  Since
no overall maximum limit is imposed by the permit,  EPA simply extrapolated the
combined feed rate of sludges and solids to obtain an maximum annual
sludge/solid capacity of 29,358 tons/yr

      Since permit limit data were not available for units 1, 2, and 3, EPA
contacted the facility directly   The facility contact stated that each of
these units can burn about 500 pounds of solids per hour, 24 hours per day,
seven days per week;  confirming our estimate for these units.  The facility
contact indicated that the fourth unit can burn between 2,000 and 15,000
pounds of solids per hour, depending on the heating value of the waste, but
that 10,000 pounds per hour is a good estimate.  Extrapolating this estimate
yields an annual capacity of 36,000 tons, almost 7000 tons more than the
estimate based on the trial burn data.  EPA concluded that this difference was
not great enough to warrant revising the estimate based on trial burn data.

Chemical Waste Management (formerly SCA), Chicago,  IL

      This facility incorporates a 120 MBtu/hr rotary kiln with liquid
injection.   According to the regional contact, the draft permit imposes
separate limits on hourly liquid and sludge/solid feed rates.  Because the
estimate obtained by applying the standard method to the permitted
sludge/solid limit vastly exceeded other indicators of the facility's capacity
(i.e.,  the facility's size and capacities reported in the TSDR survey) EPA
deemed the permit limit estimate to be unreliable.   Instead of using The
overall permit limits,  EPA based our estimates on trial burns conducted in
July 1989.   EPA extrapolated the highest demonstrated hourly solids feed rate

-------
                                     K-10

from these runs to obtain  a maximum annual sludge/solid capacity of 15,084
Because of these discrepancies, EPA contacted this facility to verify our
findings.  The facility contact indicated that the permit limits the heat
release from the rotary kiln  to 30 Mbtu/hr, and most sludges and solids
average between 6000 Btu/lb and 7000 Btu/lb.  Extrapolating the average of
this range. EPA obtained an annual sludge/solid capacity estimate of 16,714.
This estimate was 11 percent  greater than our estimate based on the trial burn
data.

Chemical Waste Management, Port Arthur, Texas

      This facility, the latest addition to the nation's commercial
incineration system, incorporates a 150 Mbtu/hr rotary kiln.  It is fully
permitted, operational, and is currently burning wastes under slightly
limiting post trial burn conditions pending analysis of trial buns completed
early this year   However, a  major obstacle jeopardizes uninterrupted future
operation of this facility   It is depending on a no migration variance for
its underground injection  well where it intends to dispose of its scrubber
water   EPA has proposed granting the no migration variance, and a final
decision is expected within the next six months.  EPA obtained a maximum
capacity estimate by apportioning the maximum permitted annual feed rates to
liquids, sludges, and  solids  based on demonstrated trial burn feed rates.
Using this approach, EPA estimates this facilities maximum annual sludge/solid
capacity to be 125,100 tons.

Environmental Systems  Company (ENSCO), El Dorado, Arkansas

      This facility  incorporates one rotary kiln that burns primarily PCBs.   A
second  rotary kiln and a recently added mobile rotary kiln burn most of the
facility's sludge/solid RCRA  wastes.  Since it was added since 1987, the
mobile  rotary kiln was not reported in the TSDR Capacity Data Set.   Region and
state permit officials indicated that this facility's permit limits only the
heat release of the  incinerator units -- mass feed rates are not directly
limited.  The on-site  state inspector at the facility estimated ranges of
hourly  sludge/solid  feed rates to both the main unit and the mobile unit based
on recent operating  records.   EPA extrapolated the average of these ranges to
obtain  a maximum sludge/solid capacity of 39,600 tons per year for the fixed
rotary  kiln and 14,400 tons per year for the mobile rotary kiln.  These unit
capacities combine to  a total facility sludge/solid capacity of 54,000
tons/yr   Our estimate exceeds the maximum capacity reported in the TSDR
Capacity Data Set by 26840 tons/yr or 99 percent.  This difference is
attributed to the addition of the mobile unit and a shift toward more sludges
and solids (relative to liquids) in recent years.  The on-site inspector
confirmed that this  shift  has taken place.

LWD, Calvert City, Kentucky

      Two rotary kilns --  rated at 30 and 37 Mbtu/hr -- are currently
operating under interim status at this facility   The state has published its
intent  to deny a final permit, but the denial is being appealed by LWD and the
facility is not expected to close in the foreseeable future.   For unit one,
one set of maximum hourly  feed rate limits are specified in the draft permit

-------
                                      K-ll

 as  demonstrated in trial burns.   No  overall  maximum feed  rate  limit  is
 imposed.   EPA extrapolated these  feed rates  to  obtain  a maximum  annual
 sludge/solid capacity of 3,312  tons.

       The  draft permit specifies  two  different  sets of operating condition
 limits for unit 2,  each with a  different maximum  feed  rate  for sludges  and
 solids.   The amount of time spent operating  under each condition is  left  to
 the discretion of the facility, and  no  overall  mass feed  rate  is imposed.   EPA
 assumed equal operating time under each set  of  conditions.   Extrapolating
 these  hourly rates,  EPA obtained  a maximum annual sludge/solid capacity of
 30,438 tons.   These unit capacities  summed to an  overall  facility sludge/solid
 capacity  of 33,750 tons/yr

 Rollins  Environmental Services, Baton Rouge, Louisiana

       This facility's integrated  system includes  a  rotary kiln with  an  after
 burner and a Loddby liquids  burner.   The total  heat release  from the
 incinerator complex is  limited  in the draft  permit  to  95.6 MBtu/hr.  The draft
 permit also explicitly  limits hourly  feed rates of  wastewater, wastes fed  to
 the  afterburner,  and  hazardous waste  fed to  the entire incinerator complex.
 To  estimate the  maximum permitted sludge/solid  feed rate, EPA deducted  the
 wastewater and  afterburner  feed limits  from  the total  complex limit  and
 assumed that  the  remaining  feed rate  represented  the maximum permitted
 sludge/solid  feed rate.   Since specific, demonstrated, sludge/solid  feed rates
 were not available, EPA used 75 percent of the  remaining  capacity limit as our
 sludge/solid  capacity estimate.   Using  this  method  EPA obtained  a maximum
 sludge/solid  capacity of 31,784 tons/yr.  This  estimate exceeds  the  maximum
 capacity reported in  the TSDR Capacity  Data  Set by  10,384 tons/yr or 49
 percent.   This  difference  is  attributed primarily to a shift toward  more
 sludges and solids  relative  to liquids.

 Rollins Environmental Services, Bridgeport,  New Jersey

       This  facility incorporates  a complex similar  to  that of Rollins'  Baton
 Rouge  facility  containing  a  rotary kiln, afterburner,  and Loddby liquids
 burner.  This facility's  final RCRA permit limits heat release from  the rotary
 kiln and Loddby burner  to  35  and  90 MBtu/hr  respectively.  The permit also
 limits hourly waste mass  feed rates to  the kiln,  afterburner, Loddby, and  the
 entire incinerator  system.   Since  the overall limit is less  that the sum of
 the  individual  limits,  EPA  apportioned  the overall  limit  to  the  individual
 system components based on  the relative size of the individual component
 limits   EPA used  75  percent  of the resulting net rotary  kiln capacity  to
 obtain a maximum  sludge/solid capacity  estimate of  15,560 tons/yr

Rollins Environmental Services, Deer  Park, Texas

      This  facility has  two  independent incinerator "trains" according  to  it's
 final RCRA  Permit.  The  first train consists of a rotary  kiln (80 MBtu/hr
maximum rating),  rotary  reactor (36 Mbtu/Hr  maximum rating), Loddby liquids
burner (100 MBtu/hr maximum  rating),  and afterburner.  The second train (train
II)  consists of a rotary kiln (120 MBtu/hr maximum  rating),  rotary reactor
 (33.5 MBtu/hr maximum rating), and afterburner.    Maximum overall  hourly waste

-------
                                     K-12

feed rates are specified in the permit for each unit of each train.

      The TSDR Capacity Data Set reports only two units, the two rotary kilns,
both of which are reported to include liquid injection ports (these ports are
presumably the Loddby burner, although the permit only identifies one Loddby
Burner)   This facility's final RCRA Permit limits heat input to these two
kilns to 120 and 80 MBtu/hr.  It also limits waste feed rates to each unit.
Taking 75 percent of these waste feed limits and extrapolating,  EPA obtained
maximum sludge/solid capacities of 32,400 and 35,640 tons/yr for these units.
These estimates are 8,722 tons/yr (21 percent) and 7,210 tons/yr (17 percent)
less than the maximum capacities reported in the TSDR Capacity Data Set.   A
contact from Rollins indicated that these units typically burn between 50 and
75 percent sludges and solids, but could burn 100 percent solids for some
wastes.  This contact suggested that the capacities reported in the survey
should still be accurate, but the estimate based on the permit limit coincides
more closely with permit limits and the percent sludges and solids suggested
by the contact.

      Rollins' comment on the proposed Third Third rule indicated that EPA
omitted rotary reactor #2 from its capacity analysis;  but did not mention
rotary reactor #1, which was also excluded from the analysis for the proposed
rule.  A contact from Rollins confirmed that the second rotary reactor has not
been constructed.  EPA estimated the existing rotary kiln's overall
sludge/solid capacity based on 75 percent of the permitted maximum, and 7200
operating hours per year (versus 75 percent and 8060 hours per year suggested
by Rollins' comment on the proposed Third Third rule).   This units maximum
capacity was thus estimated at 32,400 tons/yr

      The combined maximum sludge/solid capacity for the three units at this
facility is estimated to be 100,440 tons/yr.  This estimate is 16,468 tons/yr
or 20 percent higher than the maximum capacity reported in the TSDR Capacity
Data Set.  This difference is attributed to the addition of the rotary
reactor, but is offset by slightly lower estimates for the two rotary kilns.

Ross Incineration Services, Grafton, Ohio

      This facility consists of a single unit for which the final RCRA permit
limits hourly liquid and sludge/solid feed rates.  These limits may be raised
following successful trial burn demonstrations that are currently delayed
while Ross appeals certain permit conditions   Taking 75X of this permit
limit, EPA estimates this facility's maximum sludge/solid capacity to be
16,200.  If and when the planned trial burn is successfully conducted, this
facility's sludge/solid capacity could increase by 25 percent.

Rhone-Poulenc Basic Chemicals Company (formerly Stauffer Chemical Company),
Houston, Texas

      This facility operates a sulfuric acid regeneration furnace that is
permitted as a hazardous waste incinerator.  It is reported in the TSDR
Capacity Data Set as a liquids only incinerator rated at 205 MBtu/hr, but EPA

-------
                                      K-13

has  received  information indicating  that  it  can burn blended sludges1
According  to  this  information,  Rhone  Poulenc,  in cooperation with Calliet
Technologies,  is able  to burn  slurried  sludges, specifically K048-K052
petroleum  refining wastes that have  been physically separated.  Rhone-Poulenc
claims  that this facility and  its  facility in  Baton Rouge, Louisiana have  a
combined capacity  of  300,000 tons  per year for burning  such sludges   This
facility's permit  limits the mass  feed  rate  of hazardous wastes  (excluding
spent  sulfuric  acid)  to  360  Ib./min.   Extrapolating this limit, EPA estimates
this facility's maximum  capacity to  be  77,760  tons/yr.  Assuming that the  unit
would  continue  to  burn 25 percent  liquids, EPA estimates this facility's
sludge  capacity to be  58,320 tons/year.  Because of the pretreatment  required
for  this facility  to  burn sludges, EPA  expects this capacity to be fully
available  within six  months.

Rhone-Poulenc  Basic Chemicals  Company (formerly Stauffer Chemical Company),
Baton Rouge,  Louisiana

      This facility operates two sulfuric acid regeneration furnaces rated at
100 MBtu/hr and 180 MBtu/hr according to the TSDR Capacity Data Set.   Like
Rhone-Poulenc's facility in Houston,  Texas,  this facility was reported in  the
TSDR Survey as burning liquids  only but is now planning to burn pre-processed
K048-K052  sludges.  Both units  are permitted as hazardous waste incinerators,
but  this facility's permit does not  limit mass feed rates.  Moreover,
according  to  Louisiana state permitting officials, petroleum refining wastes
are manifested as  recovery or  reuse materials  for this facility and would  not
be subject to hazardous  waste  permit  limits.   To estimate this facilities
capacity,  EPA  divided  the combined thermal rating of the two units by the
average heating value  of K048-K052 as obtained from the National Survey of
Hazardous Waste Generators (4,489 Btu/lb).   Extrapolating this hourly feed
rate over  a year and  again assuming  the facility will burn 25 percent liquids
over the course of the year, EPA estimates this facility's maximum sludge
capacity to be 168,412 tons/year.   All  together, EPA estimates Rhone-Poulenc's
sludge  capacity at the Houston, Texas,  and Baton Rouge, Louisiana to be
226,732 tons/year.  This  estimate is  about 73,000 tons/year less than the
estimate provided  by Rhone-Poulenc (refer to previous paragraph).  This
difference is attributed to estimation  error and EPA's conclusion that despite
what is technically conceivable, facility's  are likely to burn some liquids
for practical considerations (i.e.,  the types  of wastes their customers are
likely  to ask them to  accept).   Because of the pretreatment required for this
facility to burn sludges, EPA  expects this capacity to be fully available
within six months.

ThermalKEM, Rock Hill, South Carolina

      This fully permitted facility uses a fixed hearth incinerator   The
permit does not limit  mass feed rates explicitly,  but does limit total heat
     1   Klepeis ,  John E.,  and Scalliet, Robert M.  (October,  1989).   "Total
Treatment Service for Refinery Hazardous Wastes", Presented at the October 3.
1989 Meeting of the American Petroleum  Institute: Solid Waste Program
Committee on Refinery Environmental Control.

-------
                                     K-14

release to 42 Mbtu/hr.  ThermalKEM's comment on the proposed Third Third rule
argued that EPA had underestimated this facilities sludge/solid capacity by a
factor of ten (EPA obtained its estimate of 17,528 tons/yr from the TSDR
Survey)   EPA contacted ThermalKEM to clarify this comment.  The facility
contact indicated that trial burns conducted since 1987 raised the maximum
heat release from 19 MBtu/hr to 42 Kbtu/hr; and that ThermalKEM has modified
their process to allow higher sludge/solid feed rates   These modifications
include a ram feed system for charging containerized solids, a system for
transporting wastes from steel drums to fiber packs, and an oxygen enrichment
system for improving combustion, and improved air pollution control equipment.
The facility contact indicated that these modifications allowed the facility
to burn as much as 80 to 85 percent sludges and solids, and that ThermalKEM
typically burns wastes with heating values ranging from 5000 Btu/lb to 8000
Btu/lb.  EPA concluded based on a technical considerations that this modified
unit could burn higher percentages of sludges and solids than would be
expected from a typical fixed hearth unit.  Using 75 percent sludges and
solids as for rotary kilns, and the average of the range of heating values
provided by the facility contact; EPA estimated this facilities maximum annual
sludge/solid capacity to be 18,427 tons.  This estimate is 5 percent higher
than the sludge/solid capacity reported the TSDR Capacity Data Set.

-------
                                     K-15

K.4    SLUDGE/SOLID REUSE AS FUEL ANALYSIS

       This section discusses EPA's analysis of sludge/solid reuse as fuel
capacity   Section 4.1 provides details of EPA's analysis of Ash Grove
Cement's sludge/solid capacity   Section 4.2 describes EPA's revisions  to  the
sludge/solid capacity estimates reported in the TSDR Capacity Data Set.

K.4.1  ANALYSIS OF ASH GROVE CEMENT'S SLUDGE/SOLID COMBUSTION CAPACITY

       During the public comment period, EPA received a comment from Ash Grove
Cement Company and Cadence Chemical Resources, Incorporated describing  a
recently patented process for burning containerized sludges and solids  in
cement kilns.  The system involves a network of licensed fuel blenders who
receive and package solid wastes suitable for reuse as fuel into standard  six
gallon containers.  These containers are then transported to one of the Ash
Grove  facilities where they are charged to the cement kiln in mid-process
(either through a hole in the rotating body of the kiln or between the
stationary preheater or precalciner and the rotating section of the kiln).
This process has reportedly been incorporated by six cement kilns at three Ash
Grove  facilities.

       Before assuming that Ash Grove's recently patented technology should be
included in its capacity estimates, EPA reviewed the process,  and contacted
EPA regional and state officials who have witnessed and/or are familiar with
the Ash Grove/Cadence process.   EPA found no technical reason to doubt that
the process could work as claimed in Ash Grove's comment.  State and regional
contacts confirmed that Ash Grove had implemented the technology on at least
four operating kilns at its facilities in Foreman,  Arkansas;  Louisville,
Nebraska; and Chanute,  Kansas.   State officials from Arkansas  and Kansas have
evaluated the process and concluded that it is legitimate energy recovery.   As
a result of these confirmations, EPA has included the sludge/solid combustion
capacity at Ash Grove's six operating modified kilns in it sludge/solid
combustion capacity estimates.

      The Ash Grove/Cadence comment stated that Ash Grove's three facilities
currently possesses a combined sludge/solid capacity of 90,000 tons/year, but
they did not indicate how this number was obtained.  EPA estimated each kiln's
sludge/solid capacity in the following manner:

                     6   Gallons per charge
            x        1   Charge per kiln rotation
            x       60   Kiln rotations per hour
            x     8000   Hours per year
            /      240   Gallons/ton
                12,000   Tons/year

      Each charge was assumed to contain 6 gallons of sludge/solids as
specified in the process patent.  One charge was assumed per rotation of the
kiln (as determined from the patent),  and the kiln was assumed to operate 8000
hours per year (based on EPA's judgement of a normal operating year)    Each
kiln was assumed to rotate at 60 revolutions per hour, the limit imposed by
the permit issued to the Foreman,  Arkansas facility   EPA's standard

-------
                                     K-16

conversion factor of 240 gallons/ton is based on Che density of water and was
used for consistency with other analyses.  Using this method for each of the
six kilns, EPA estimates Ash Grove's overall maximum sludge solid capacity to
be 72,000 tons/year

-------
                                     K-17

K.4 2  UPDATING THE RAF SLUDGE/SOLID CAPACITY

      EPA contacted EPA regional and state officials to verify the activities
of each RAF facility in the TSDR Capacity Data Set reported as having
sludge/solid capacity in either 1988 or 1989/90.   In general capacity data was
unavailable, but in most cases EPA was able to determine whether the facility
was accepting hazardous wastes at this time.   EPA did obtain updated data for
two cement companies.

United Cement, Artesia, Mississippi

      This facility has been delayed by litigation regarding its state permit.
It has now cleared the courts, and is fully permitted to burn hazardous waste
fuels.  Final feed system and truck-unloading area modifications are underway
This facility is permitted to burn up to approximately 155,000 tons of wastes
that exceed 8000 Btu/hr and contain up to 30  percent solids.  Based on the
fraction of sludges and solids capacity reported in the TSDR Capacity Data Set
(50 percent liquids,  50 percent sludge/solids),  EPA estimates this facility's
maximum practical sludge/solid capacity to be 77,500 tons/year   EPA expects
this facility to complete modifications and begin burning wastes by the end of
1990.

Southdown Portland Cement Company

      Two cement kilns owned by Southdown Portland Cement Company have
incorporated the Ash  Grove/Cadence mid-process solid fuel charging system (one
kiln in Tennessee and one in Kentucky) .   Both of  these facilities are
reportedly operational and very close to final authorization.   A third
Southdown kiln is currently under construction in Ohio.   Since none of these
facilities is currently accepting wastes,  EPA has not included them as
currently available capacity.   EPA expects the Louisville,  Kentucky,  and
Knoxville,  Tennessee  facilities to be available  by the end of 1990.  Using the
same method described for Ash Grove,  EPA estimates the combined sludge/solid
capacity of these two  kilns to be 24,000 tons/year.

      For the remainder of the reuse  as fuel  facilities,  EPA obtained its
estimate sludge/solid capacity estimate from  the  TSDR Capacity Data Set.
Estimates of planned  1989/1990 capacity were  used with the following omissions
resulting from regional and state updates:

      •      Koppers Company in Mississippi no longer burns hazardous wastes.

      •      Environmental Waste Resources, Waterbury Connecticut, is a fuel
            blender but does  not burn hazardous  wastes

      •      San Juan  Cement,  planned  to close three  of its four units by the
            end of  1990

      •      Ideal Cement Company,  Saratoga, Arkansas,  has been delayed to 1991
            and will burn liquids only.

      •      GSX,  Pinewood,  South Carolina, burns  nonhazardous  wastes  only

-------
                                     K-18

      •     Lehigh Cement Company burns liquids only at its kilns in
            Frederick, Maryland.

      •     Ohio Lime, Incorporated of Millersville, Ohio, will not burn
            hazardous wastes as planned due  to  local opposition.

      •     Allied Chemical  in Ironton, Ohio, will  not burn hazardous waste
            fuels in  its planned industrial  boiler

K.5  SLUDGE/SOLID COMBUSTION CAPACITY THROUGH 1992

      EPA recognizes  the uncertainties facing new commercial incinerators, but
through its discussions with regional and state officials has identified
several facilities that it expects will bring new sludge/solid capacity on-
line by the end of 1992.  This section summarizes EPA's analysis of these
planned additions.

K.5.1 PLANNED ADDITIONS TO NATIONAL SLUDGE/SOLID INCINERATION CAPACITY IN 1991

      While siting problems, local opposition, and permitting hurdles make it
difficult to predict  the fate of planned hazardous waste incinerators, EPA has
identified four incineration facilities it expects to come on-line in 1991.
Their permits are either granted or imminent.  Their status indicates that
construction, if necessary,  could proceed quickly.  Capacity estimates for
these facilities are  based primarily on Part B permit applications.   These
estimates were obtained using the same methods and assumptions as for the
currently operating facilities.

Environmental Systems Company. Maracop*, Arizona

      According to Region IX contacts, this  facility is one to six months away
from receiving its permit.   This facility is likely to be brought on-line
quickly since it intends to  incorporate three existing 33 MBtu/hr mobile
rotary kilns.  Using  75 percent of the facilities design capacity, EPA
estimates this facility's sludge/solid incineration capacity to be 37,500
tons/year

Aptus, Coffeeville, Kansas

      According to Region VII contacts this  existing 62 MBtu/hr PCS
incinerator is about  a year  from receiving its operating permit and one and a
half years from burning RCRA wastes   Using  75 percent of the sludge/solid
feed rate limit specified in the permit application, EPA estimates this
facilities sludge/solid incineration capacity to be 27,000 tons/year

Aptus, Tooele, Utah

      Region VIII expects this facility to receive  its final RCRA permit
sometime by the summer of 1990   Preliminary construction preparations for a
120 MBtu/hr rotary kiln are  already underway   Based on the trial burn plan
specified in Part B of the permit application,  EPA  estimates this facility's
maximum sludge/solid  incineration capacity to be 30,600 tons/year

-------
                                     K-19

Alchem-Tron  (GSX), Cleveland, Ohro

       This  currently operational modified sludge drying bed was  included  in
the proposed rule, but EPA subsequently determined  that it  is  not yet
accepting wastes because it is awaiting a state permit.  EPA expects a  final
permit decision from Ohio state officials this summer.  Because this uni:  is
only suitable for treating sludge and solids, EPA used 100  percent of its
permitted limit to obtain a maximum annual sludge/solid capacity of 28,800
tons/year

K.5.2 PLANNED ADDITIONS TO NATIONAL SLUDGE/SOLID INCINERATION  CAPACITY  IX  1992


      The 1992 horizon is far less certain, though  EPA included only those
facilities that appear at this time to have strong  prospects according  to
information  provided by EPA regional and state officials.   These facilities
are included because their permit applications are  being actively processed,
and permits  are expected by early next year.

Rollins Environmental Services,  Bridgeport, New Jersey

      Rollins intends to add a rotary kiln to its Bridgeport,  New Jersey
facility by  the end of 1992.   This planned unit is  included in the facility's
final RCRA permit.  Based on the TSDR Capacity Data Set,  EPA estimates  this
unit's maximum sludge/solid capacity to be 10,400 tons/year.

California Thermal Treatment,  Vernon,  California

      This facility has received a permit to build  a 42 MBtu/hr rotary  kiln.
The ultimate fate of this planned facility depends  on the outcome of a  permit
appeal against the facility   Based on 75 percent of the maximum total
facility capacity, EPA estimates this facility's maximum sludge/solid capacity
to be 16,875 tons/year.

Waste-Tech,   Kimball,  Nebraska

      This facility as received a permit from the state,  and could begin
construction by the end of 1990.   EPA expects this  fluidized bed incinerator
to burn mostly liquids.   Based on 25 percent of the total maximum feed  rate,
EPA estimates this facility's maximum sludge/solid  capacity to be 4,500
tons/year.

Chemical Waste Management,  Kettleman Hills, California

      Chemical Waste  Management  is currently addressing deficiencies in this
facility's  permit application.   This facility could receive its permit  to
begin construction of its 50  MBtu/hr rotary kiln by the end of 1990.   Based on
75 percent  of the total  capacity specified in the permit application,  EPA
estimates this facility's sludge/solid capacity to  be 27,750 tons/year

Florida First,  Polk County.  Florida

-------
                                     K-20

      According to a Region IV contact, Florida First is scheduled to receive
a construction permit for this facility in early 1991.  Based on the trial
burn plan in Part B of the application, EPA estimates this facility's maximum
sludge/solid capacity to be 27,705 tons/year.

USPCI, Tooele, Utah

      USPCI is currently addressing deficiencies in this facility's permit
application.  This facility could receive its permit by early 1991, according
to a Region VIII contact.  Based on the Part B trial burn plan, EPA estimates
this facility's sludge/solid capacity  to be 12,595 tons/year

K.5.3 PLANNED ADDITIONS DELAYED UNTIL  1993

      Through its discussions with regional and state officials, EPA has
identified several new facilities and  additions to existing facilities that it
expects to begin operating after the beginning of 1993.  The following
additions were reported in the TSDR Capacity Data Set as planned for 1989 to
1992, but are likely to be delayed until at least 1993:

      •     Fort Barton Holdings Incorporated, Warwick, Rhode Island

      •     Rollins Environmental Services, Baton Rouge, Louisiana (new unit)

      •     Industrial Service Corporation (formerly Radium Petroleum
            Company), Kansas City, Missouri

      •     ThermalKEM, Rock Hill, South Carolina (new unit)

      •     GSX Thermal Oxidation Corporation, Roebuck, South Carolina (new
            unit)

      •     Envirosafe Services of Texas, Devers,  Texas

      •     LWD, Calvert City, Kentucky (new units)

-------
                                     K-21

K.6   PHONE LOGS

      This section contains  logs  of  each discussion  with  regional  or state
officials that provided information  used in  this  analysis.   These  calls are
grouped by EPA region,  and ordered chronologically for  each region.   In many
cases,  several calls  were  required to obtain the  necessary  information.
Supplemental information from  state  and regional  contacts,  including excerpts
from permits,  are  included at  the end of regional sections.   Calls to
facilities are presented separately  at the end of this  section.  A list of
abreviations used  in  the phone  logs  is provided at the  end  of Section K.6

-------
                                     K-22

REGION I


3/5/90  10:10  -  Stephen Yee.  (617} 573-9670 -  left message.

3/6/90   9:45  -  called Stephen Yee

1.     Fort Barton Holdings, Warwick, RI
            not built
            being contested
            currently conducting state hearing
            Frank Battaglia is state contact 573-9603
            permit not drafted
            company appealing
            capacity unknown

2     Environmental Waste Resources, Waterbury,  CT
            not an incinerator or RAF
            sludge recovery (WWT)
            no plans to change

3     Clean Harbors, Braintree, MA
            no application submitted
            application expected this summer
            call Steve Dreezen, 292-5630

4.     GE, Pittsfield, MA
            PCB's only
            no plans to go RCRA

5.     Pfizer
            on-site pyrolizer
            TB scheduled for April
            no problems anticipated
            currently IS
            may be public opposition
            burns plant's pumpable sludges
            2 RK units
            4700 Ib/hr total (no physical form limits)

6.     Polaroid, MA
            currently on-site IS
            will shut down: waste minimization and shipment off-site
            call Gary Gosbee, 5740
            closing within six months
            burns unknown volumes   believed liquids only
      General Dynamics
            proposed on-site RK
            application expected this summer
            being redesigned
            capacity unknown
            1993 +

-------
                                     K-23

3/6/90  10:15  -  Frank Battaglia (617) 675-9603   Busy


3/6/90  10:16  -  Steve Dreezen (617) 292-5832

1.    Clean Harbors, Braintree, MA
            in process of siting
            still far from permit
            will need RCRA, TSCA and local permits
            town strongly opposes
            according to application a RK (40 ft long)
            60 MBTu/hr  max (50 nominal)
            new unit at existing facility
            many problems with site
            1993+ if at all (doubtful)

2.    GE, Pittsford
            TSCA only
            no planned changes

3     Polaroid, MA
            will withdraw application
            will close in six months
            believed to be liquids only
            volumes affected unknown


3/9/90  11:15  -  Frank Battaglia, RI State Office

1.    Fort Barton Holding, Warwick,  RI
            proposed greenfield
            permit not issued, decision expected early summer
            possible by end of 1992, 1993 or later more likely
            call Mr. Terry Grey (401) 277-2797 for more details
            capacity unknown


3/12/90  10:20  -  Terry Grey. RI State Program (404) 277-2797

            will return around 1:00
            left message to call


3/12/90  11:40  -  Terrv Grev (RI EPA) returned call


3/12/90  12:55  -  Terry Grey. RI EPA. (401) 277-2797

1.    Fort Barton Holding, Warwick,  RI
            permit hearing concluded
            decision expected in May
            may not be permitted
            proposed 20 MBtu/hr  RK
            max throughout 30,000 tons/yr
            plans to accept dioxins/furans
            no PCBs/explosives

-------
            if ac all, 1993+


3 '21 -90  10-35  -  Stephen

            left message


3 21/90  10--tO  -  Susan Green. CT. EPA

            no longer at EPA

      Transferred Co Jerry Sotolongo (617) 573-9680. Section Chief. CT RCRA

            left: message


3.26.90  9:-o  -  George Dews. CT DOEnv. P.  (203) 566-2264

            In meeting, left message


3 2^ 90  1:25  -  Jerry SotolonEa. CT State  (617) 573-9680

1     Environmental Waste Resources
            not burning sludges and solids
            do blend fuels
            burning would require state permits
            call George Dews at CT EPA  (203) 566-226*


3/28.90  10:15  -  George Dews. CT DOEP. returned call

1     Environmental Waste resources, Waterbury
            does not burn hazardous waste
            fuel blender only
            no cement kilns burn wastes in CT,  closest is NY


3 29.90  1:20  -  Jerry Sotolonga. CT State  (,617) 573-9680

            left message

-------
                                     K-25

REGION II


3/5/90  10:20  -   John Brogard (212)  264-8682

1.     BDT     call Marvin Frank (212) 264-9578

2.     Rollins,  Bridgeport,  NJ
            currently only 1 RK operating
            permit (March 1989) covers additional unit   replacement RRK
            no dioxins/furans/PCBs
            RRK being designed -  sure thing
            RRK will be on-line before 1992

      Capacity for existing RK

      RK          7000 Ib/hr  total
      Loddby      6875 Ib/hr  total    no breakout by physical from
      AB          4800 Ib/hr  total

3.     GAF, Linden, NJ
            very preliminary commercial incinerator
            heavy opposition
            passed siting commission
            no application submitted
            not possible by end of 1992

4.     DuPont   Chambers Works,  Deepwater,  NJ
            application under review
            50 percent commercial
            will fax details on capacity
            contact wants written request
            hung up


3/5/90  1:50  -  left message for John Brogard


3/6/90  10:30  -  John Brogard   I left fax # and message to call


3/9/90  9:20  -  John Brogard (212) 264-8682

            will  send fax again since last one didn't come through
            call  John Scott,  NJ DEP,  (609) 292-9880, regarding Rollins,
            Bridgeport
            call  Jim Dolen (518)  457-7269 (NY RCRA) or Jack Lavber  (NY Air)
            (518) 457-7454

1.     University  of Rochester,  Rochester,  NY
            probably not RCRA

-------
                                     K-26

2.     RFE,  NJ
            nonhazardous

3     American Cyanamid, Bridgewater, NJ
            exempt recycler

4     Blue Circle, Ravenna, NY
            never heard of, ask state

5     CWM,  Model City, NY
            call Jim Dollen

6     Lehigh Cement, Cementon
            call Jim Dollen

7     NJ siting commission, Millstone, NJ
            never heard of

8     Envirocare, NJ
            dead project

9     GE, Waterford, NY
            PCS permitted
            call Jim Dollen

10    Schenectachy Chemicals, NY
            call Jim Dollen

11.   BASF, Kearny, NJ
            onsite
            liquids only
            constructed, permitted and operating

12.   Pfizer, PR
            call Cliff Ng, 9579

13    Phillips, ECG, NY
            call Jim Dollen

14.   Union Carbide
            denied permit
            on-site lab wastes only
            small unit

15    DuPont, Deepwater, NJ
            denied permit
            will be redone
3/9/90  11:00  -  John Scott (NJ PEP)

            out till Monday
            left message

-------
                                     K-27

3/9/90  11:00  -   Jim Pollen (NY RCRA Office) (518) 457-7269

            of all existing facilities in NY, only GE, Waterford and Kodak.
            Rochester burn sludges and solids
            left  list of facilities and described needs
            he will call this afternoon


3/12/90  10:50  -   John Scott (NJ PEP) returned call


3/12/90  10:55  -   John Scott (6091 292-9880

1.     Rollins, Bridgeport,  NJ
            multiple input ports
            consists of RK
                  Loddby Burner (Liquids only)
                  After Burner (Wastewaters)
            Loddby will be closed in near future
            has received conceptual permit approval for proposed RR
            RRK design is expected this month
            current permit feed rate limits:
                  to RK       -  7000 Ib/hr (could be all solids)
                  to Loddby   -  6,875 Ib/hr (liquids only
                  to AB       -  4,800 Ib/hr (liquids/gases)
            estimated sludge/solid throughout is 1000 Ib/hr
            total  input limit:   15,575 Ib/hr
            RKR could be up sometime in 1992

2.     Call Jim Bridgewater on GAP,  Linden,  NJ

3.     RFE burns nonhazardous wastes

4     Dupont, Deepwater,  NJ
            currently DuPont wastes only
            has submitted application to become commercial
            will probably modify existing RK system
            call Anthony Fontana (same //) for more info

5     U . C . ,  NJ
            has closed

6.     NJ  Siting Commission
            Millstone Township Site unsuitable
            State  is looking for another site
            may back off if DuPont goes commercial
            no operator for site has been selected
            call Susan Boyle,  Assistant Director of Commission, for more info
            (609)  292-1459

-------
                                     K-28

3/12/90  1:20  -  Jim Pollen (NY RCRA Program) (518) 457-7269

            unavailable, left message


3/16/90  2:50  -  John Scott. NJ PEP

1.     Rollins, Bridgeport,  NJ
            max heat release from RK is 35 MBtu/hr; 90 MBtu/hr from Loddby
            Air permit based on heat input limit
            maximum total organic feed to RK, Loddby,  and AB is 15,575 Ib/hr
            1000 Ib/hr is estimated s/s throughput limit for proposed Rotary
            Reactor
            Part B allows 365 day/yr,  24 hours/day operation
            no A, B, or C explosives or F024 permitted
            estimated critical unit is positive displacement pump for
            sludges/liquids up to 3000 Ib/hr
            blending eliminates problems at low Btu/lb constituent limits

2.     RFE,  NJ
            recovers precious metals by incineration

3.     General Comments
            not aware of any cement kilns burning hazardous fuels in NJ
            contact Air office for more info on RAF exempt facilities:  Joel
            Leon (609) 984-3027


3/21/90  10:50  - Cliff Ng. NY RCRA (212) 264-9579

            left message to call


3/22/90  9:00  -  Clift Ne

1.     San Juan Cement, PR
            liquids only, primarily solvents
            onsite and company capture wastes
            possibly some commercial customers
            not a TSD
            not sure if units have closed
            call Ton Moy @ 264-1785 (out till Monday)
            call Carl Martinez (PR) (809) 767-8116
            call Air Compliance Office, Kenneth Eng, 264-4711

2.     Safety Kleen, RP
            has been burning spent solvents for some time
            thinks liquid only, not sure

-------
                                     K-29

3/26/90  4:50  - Ton Mov. Region II. returned call

1.    San Juan Cement, PR
            Accept blended fuels from safety kleen
            no storage permit
            believe liquids only
            no idea of capacity

2.    Safety Kleen, PR
            primarily a fuel blender
            were planning to add unit


3/27/90  1:10  Richard Ho, returned call (Region II)

1.    San Juan Cement, PR
            3 kilns planning to close
            not sure if already closed

4/23/90  9:45  Jim Pollen. NY RCRA (518) 457-7269

1.    Chem Waste Management, Model City, NY
            Preliminary application incomplete
            Already a landfill
            2 RKs rated at 50 mbtu/hr each
            Could possibly be permitted in one year and constructed in one
            year

2.    Blue Circle Atlantic Cement,  Ravena,  NY
            New York State requires permit for RAF
            Has not responded to NOD
            Not burning hazardous wastes

3.    Lehigh Cement,  NY
            Demonstration permit has expired
            Not currently burning
            Had to report TB
            May still be planning to burn
            Call Sev Chetty at (518)  457-9254

4     Norlite,  NY
            May have stopped burning,  failed TB
            Has added new APCE and will try again

-------
                                      K-30
            UNITED STATCS  IHVZUCWHWTAL FftOTXCTZOM  AGtNCY, RSGJON II
&EPA
          Gary Light
           ICF Corp.
FROM
                      John N. Brogard, P.E.
                                        MAXCOOi
QtfKl
                U.S.  EPA Region II/N«w York City
OATI
        March 1990
        MUMUM Of PAOU TO INCtUM TMtt COVtM SHtfT
                  INFORMATION POK SINOINO PACSIMILI MEtSAOBS
  Ptnifax  PX-100
FTS:  264-7613
(212) 264-7613
                                                                VUWICATM
                                                                  MUM ft Ml
FTS:  264-2301
(212) 264-2301
                               »A01   i   OF  ?   »AOM
                           X03/09/90  11:44   P.

-------
                                                                                     uune  13
                                                TABLE  3.1-5

                                              BURNER  SUMMARY
                                                                                                 *
Item  tjuipmant NO.
 No.
     £542-6303-01
 2.
4.    -542-6307-01




6.    4542-6305-1,1


7.    4542-6403-01





9.    4542-6704-01


10.   4542-6702-01


 I.   4542-6701-01


12.   4542-6707-01

13.   4542-6705-01




15.   4542-6706-01


16.   4545-6716-01
                         Otteriot ion
                    Liquid wasta spray
                                           Location
                                            Kiln
                                                     Thermal      Liquid Clow       Higher heating  value   Vi|(0!
                                                     Capacity     Win.     Max,   Design    Miri.     H»x.   Mm, i
                                                     MM etu/hr   ib/hr    Ib/hr  8tu/lb  Btu/lB  Btu/lb    cj
900   3,600   2,000
                                                                                            0    8,000   0.8
PurpebU tludcje
Liquid waite
Hign freezer waste
.*l oil
Direct ourn
Heavy tludge wa?te
liquid waata apray
Liquid waata apray
Low NOx burner
Low NOx burner
Liquid watte
Fuel oil
Liquid watte
Fuel oi I
Kiln
Kiln
Kiln
KUn
KUn
Kiln
ABC weat
Ate Eatt
AK Ea*t
ASC tfett
AtC North West
ABC North u««t
ARC North EMt
ABC North Eaat
30
30
30
50
60
30
-•
--
30
30
30
30
30
30
773
773
773
430
773
1,000
900
900
313
515
515
2S6
315
258
3,750
3,750
3,730
2,580
3,750
20,000
3,600
3,600
3,730
3,750
3,730
1,546
3.730
1,546
10,000
12,500
12,500
19,400
8,000
4,000
2,000
2,000
12,300
12,300
12,300
19,400
12,300
19,400
8,000
a, oco
8,000
NA
0
0
0
0
8,000
8,000
8,000
NA
8,000
NA
19,400
19,400
19,400
19,400
19,400
8,000
8,000
8,000
19,400
19,400
19,400
19,400
19,400
19,400
0,1
0.8
0.8
0,5
o.a
600
0.9
0.8
0.8
.0.8
0,8
O.J
0.8
0.5
                    Fluond«/fu«l Oil
                                          ABC North
                                                                   86
        534   9,400   7,000   19,400    0.5
                                                   V-3.1-32
          0928H   2360-005-605-5

-------
                                     K-32

REGION III


3/5/90  1:15  -  Gary Gross (215) 597-7940

1.     Keystone Cement Co., Bath, PA
            believes liquids only
            call state offices

2.     Medusa Cement, Wampum, PA
            no information available

3.     Pyrochem, Mason County.  WV
            application submitted (commercial)
      _     currently dormant while plan is reevaluated
            not before end of 1992

4     Westinghouse/Apts,  Apple Grove, WV
            no application submitted
            probably canceled

5.     Coplay Cement, Frederick, MD
            no info   call State coordinator

6.     PPG   no incinerator in PA

7     Zapata, on-site     liquids only   denied permit

8.     Freeman, on-site   liquids only   denied permit

9     Union Carbide
            U.C.  wastes only
            on-site S/S  RK
            33 MBTu/hr
            2 years from permit
            1992+

RAF facilities in general   no data   call state offices   no changes since
beginning of 1989


3/6/90  10:40  -   Patrick Anderson (PA) (215) 597-7937

            replaced by Niel Swanson
            call tomorrow


3/6/90  10:50  -   John Humphries CMD/WV) (215) 597-0320

            not in
            try Dennis Zielinsku or Cynthia Burrow at state office
            (215) 597-7546


3/21/90  10:55  -  Patrick Anderson, PA State Coordinator

-------
                                     K-33

            replaced by Neil Swanson
            call Mr  Ron Lee tomorrow at (215) 597-3181
            for Region III non-PA call John Humphries, Section Chief,
            (215) 597-0320

      Transferred to Gary Gross

            call Ed Hammberbury at MD State Office (301) 631  3356


3/21/90  11:30  -  Ed Hammerburg (301) 631-3356

            left message to call


3/21/90  1:40  -  Ed Hammerburg. MD DOEnv returned call

1.    Lehigh Cement, Frederick, MD
            has submitted state permit application
            currently operating but not burning hazardous wastes
            currently second tier priority:   8-10 months from decision
            Jim Francis will call (301) 631-3343

2.    Coplay Cement
            never heard of


3/22/90  3:10  -  Michael Martin.  MD DOEnv (301) 631  3344

1.    Lehigh Portland Cement,  Frederick,  MD
            limited facility application submitted in 1988
            specifies 20,000,000 gpy maximum liquids  capacity
            kilns have been operating for years
            currently accept wastes from fuel blenders
            thinks they've been burning hazardous waste fuels for years
            no other cement kilns in MD burn hazardous wastes


3/26/90  1:4.5  -  Mike Martin.  MDE (301)  631-3344

1.    Lehigh Cement,  Frederick, MD
            burn liquids only
            began burning around end of 1986
            burned 1.5 million gallons in 1988
            burned close to 2  million gallons in 1989
            Lehigh is the only cement kiln burning hazardous waste as fuel  in
            MD

-------
                                     K-34

3/26/90  1:55  -  Hon Lee, returned call

1.     Medusa Cement, Wampum, PA
            applying for storage permit
            kilns already exist
            no idea how much or what wastes burned

2.     Keystone Cement, Bath, PA
            burn liquid F003-F005 and some D001
            permitted for storage
            2 kilns operating  (possibly 3)
            Part B says maximum capacity  is 19 mgpy
4/3/90  1:30   -  Liz Michaels. Lehigh Portland Cement. Allentown.  PA
                 (215) 776-2753)
            won't provide  information over phone
            requires verification of my  identity

-------
                                     K-35

REGION IV


3/5/90  11:00  -   Bettv Willis (404)  347-3433   out till Tuesday or Wednesday
                  Transferred to Evellvn Ponton (NC & SC)

1.     Groce Labs,  Greer,  SC
            no changes since beginning of 1989 (none planned)
            no incinerator

2.     GSX TOX, Roebuck (Abco,  GSX)
            1 unit operating - no liquids only since beginning of 1989
            2nd unit on hold   not  before 1993
            application in   permit not drafted

3     ThermalKEM
      a)          permit under appeal for 1 unit which is operating under
                  interim status
                  42,000 BTU/hr
                  appealed by locals  and ThermalKEM
                  no changes to operation since beginning of 1989

      b)    second unit (same as existing unit)
                  planned for 1992
                  will check on capacity

            neither burns D/F/PCBs

4.     GSX Pinewood
            will check

5.     SC Incinerator,  Tyrell County,  SC
            will check

6.     Owens Corning, SC
            went non-hazardous
            was liquid

7     Westinghouse   closed -  onsite  unit

8     Century Furniture - onsite
      Dupont,  NC  - on-site

      will check  on others from list  (15)

      Transferred to Chip Start,  (responsible for KY and TN)

9     LWD,  Calvert City
            state  missed deadline
            has issued intent to deny permit for three IS incinerators
            1 new unit   100 MBTu/hr"
            will  pursue more details

-------
                                     K-36

10.    LWD,  Clay,  KY
            permitting efforts inactive
            will  check   won't operate

11.    CECOS,  Louisville,  KY
            proposed new facility
            state denied permit
            won't happen

12.    Pyrochem,  Louisville, KY
            won't happen

13    CWM.  (SCA), Memphis,  TN
            major changes to design
            will  submit new application
            NOD issued 3/89   no response
            not before end of 1992
            RK

14    IT (DOE),  Oak Ridge,  TN
            permitted and operating
            not commercial
            munitions only

15.    Aptus/Westinghouse
            not commercial
            not operating
            closed 1983

16    DuPont,  KY
            on-site
            liquids only

17    Kentucky Solite   will check
            cement kiln

18.    M&T Chemicals
            Ltd commercial
            RK   18 MBTu/hr
            small tin recovery only

19    Olin, Calvert City, KY (same as Brandenburg)
            Ltd commercial, liquids only
            131 gal/hr maximum

20.    Pennwalt,  Colt City,  NY
            liquids only
            on-site

21.    Rohm & Haas
            proposed RK
            Ltd commercial (Rohm & Haas wastes only)
            after 1992

-------
                                     K-37

22    Tennessee Eastman, Kingsport, TN
            on-site

23    Velsicol   Liquids only
            call in morning for more info

AL/MS   Lissie Ketcham
        not available, call again
3/5/90  1:55  - GA/FL - Hugh Hazen

24    Florida First
            proposed RK (commercial)
            75 MBTu/hr
            2nd round of NOD
            No D/F/PCB
            expect construction permit 1991 (1st, 4th)
            possible by 1992

25.   "State Officials"   Taylor County,  GA
            very preliminary
            public opposition
            after 1992 at best

26.   FL Env  Reg. Commission, FL
            has selected union county, FL
            after 1992 at best
            discussion only

27    Honeywell,  Clearwater, FL
            on-site liquids only

28.   Mid Florida Mining,  Lowell,  FL
      _     on-site   liquids only (RAF)
            considering non-hazardous solids

29    Olin,  Norwest,  FL
            onsite only
            liquids only
            call  John Griffin, FL (904) 488-0300

30.   Resource Recovery of America,  Miami,  FL
            fuel  contaminated soils  only
            not for hazardous wastes

31.   Oldover,  Green Cove  Springs,  FL
            liquids only

-------
                                     K-38

3/6/90  11:25  -  r404) 347-3433
            left message for Evellyn Ponton
            left message for Chip Stuart
            left message for Hugh Hazen
            Lissie Ketham not in   left message
3/6/90  1:00  -  (404) 347-3433

            Evellyn Ponton not available
            Chip Stuart not available
            Lissie Ketcham not available
            Reached Hugh Hazen

1.     Florida First, Polk County, FL
      Proposed greenfield, 75 MBtu/Hr RK
      Capacity from application
      Total capacity 38,640 tons/yr

      Kiln              Low Btu                       High Btu

      Liq         3750 Ib/hr  (8000 Btu/lb)      1500 Ib/hr (20,000 Btu/lb)
      Sludge      6000 Ib/hr  (8000 Btu/lb)      2400 Ib/hr (20,000 Btu/lb)
      Bulk
        Solids    10,400  (0 Btu/lb)             4200 Ib/hr (12,000 Btu/hr)
      Contaminated
        Solids    6000 Ib/hr  (0 Btu/lb)         3000 Ib/hr (12,000 Btu/hr)

      Secondary chamber
            liquids to each of three nozzles
            3000 Ib/hr (0 Btu/lb)
            1200 Ib/hr (20,000 Btu/lb)
3/7/90  3:30   -  Chip Stuart  (404) 347-3433)

1.    LWD, Calvert City, KY
            Three existing units
            unit 1, 30 MBtu/hr RX
            unit 2, 37 MBtu/hr RK
            unit 3, 100 MBtu/hr RK

            two proposed units
            unit 4. 100 MBtu/hr RK
            unit 5, 100 MBtu/hr RK

            call KY permit writer, Beth Antley for capacity details
            ^404) 347-7109

      State office contacts:
      KY   Mohammed Aladdin,  (502) 564-6716
      TN   Jackie Obeerah   Baah, (615) 741-3424

2     LWD, Clay, KY
            exists

-------
                                     K-39

            was municipal
            won't ever operate

3     IT,  Oak Ridge, TN
            munitions only

4     Aptus/Westinghouse, Louisville, KY
            closed 1983

5     Kentucky Solite, Brooks, KY
            cement kiln

6.    01 in, Brandenbury, KY

            no incinerator at Calvert City
            company captive
            liquids only
            131 gal/hr total  throughout
            may be fraction commercial

7     Rohm & Haas, Louisville, KY
            5 tons/hr permitted maximum  (all forms)
            company captive

8.    Tennessee Eastman
            on-site liquids and solids
            two 100 MBtu/hr RKs
            one 50 MBtu/hr  LI

9     Velsicol, Memphis, TN
            existing  on-site  (permitted)
            liquids only
            20 MBtu/hr
            second unit  never operated
            Lissie Ketham unavailable
            transferred  to Evellvn Ponton

                  still  checking on  GSX, TOC, Roebuck, SC
                  still  checking on  ThermalKEM, Rockhill, SC
4:30  - Lissie Ketham still unavailable
 3/8/90   1:45   -  Evellvn Ponton, unavailable,  left message
                 Chip Stuart

            Tennessee Eastman exists and operates
            company captive
            burns sludges, solids and  liquids

      Lissie Ketham - unavailable
 3/8/90  Beth Antlev  (KY  Permit Writer)  (404)  347-3433

-------
                                     K-40

LWD, Calvert City, KY
            public notice of permit denial
            two units operating
            unit 3 is not allowed to operate

CWM, Memphis,  TN
            proposed greenfield facility
            1993+ at best
3/9/90  10:10  -  Evellyn.Ponton (404) 347-3433

1.     GSX, Pinewood, SC
            operating kiln
            nonhazardous wastes only

2.     DuPont,  NC
            denied permit
            liquids only
            on-site

3     DuPont,  SC
            currently operating
            liquids only  •
            on-site

4     GSX, TOG, Roebuck, SC
            currently liquids only
            RK proposed
            permit not drafted, not active
            1993+ at best
            capacity unknown

5     ThermalKEM
            still checking capacity
            will call or fax data
3/9/90  11:40  -  Lissie Ketham (404) 347-3433

            not available, left message


3/9/90  12:15  -  Beth Antley returned my call and left message to call

-------
                                     K-41

3/9/90  1:00  -  Beth Antlev  (404) 347-7109

            unavailable, left message Co call


3/9/90  1:20  -  Beth Antlev returned call

1.    LWD, Calvert City, KY
            two units operating
            second (and third) unit has two operating conditions specified
            amount of time operating in condition I or II is at facility's
            discretion,  but must be reported
            has faxed throughput limits for each condition


3/9/90  Lissie Ketham (Region IV) (404) 347-3433

1.    United Cement Company
            call Betty Willis

2.    CWM, Emelle, AL
            permit application submitted but rejected
            application resubmitted
            AL isn't permitting any new units
            chances are good that Emelle won't happen
            if at all, won't be until 1993+

3.    Mississippi Thermal Treatment Corp.
            no application submitted
            call Jerry Banks at MS State Program for more info (601) 961-5171

4.    DuPont,  Axis, AL (not Mobile)
            on-site liquids only

5.    Akzo,  AL
            has been closed for some time

6.    Kay-Fries,  AL
            was liquids  only
            closed sometime after, May 1988

7     Sony,  AL
            closed 8/16/88

8.    USA Anniston Depot,  AL
            burned on-site munitions only
            currently closed, may reopen

9     3 M Chemical, AL
            currentLy generator only
            either closed of operating exempt boiler
            on-site wastes

10    Allied Chemical, Birmingham, AL
            company captive batch incinerator
            currently operating

-------
                                     K-42

            on-site wastes

11    Ciba Geigy, Mclntosh, AL
            on-site corrective action wastes
            entered system via 1985-86 permit modification

12.    First Chemical
            on-site
            application submitted
            construction to be completed in two years

13.    M & M,  Attalla,  AL
            exempt fuel blender


3/13/90  11:00 Evellvn Ponton (4041 347-3433

1.    ThermalKEM, Rockhill, SC
            liquid/sludge feed limit is 33 Ib/min
            no solids limit specified
            multiple hearth

2 .    SC Incinerator
            no info available
            call David Wilson at SC State Office (803) 734-5200


3/13/90 11:10 David Wilson. SC  State ProEram Office (803)  734-5200

            unavailable, transferred to Shirley Fawcett

1.    ThermalKEM
            solids capacity not specified
            concurred with 42,000 Btu
            concurred with 33 Ib/min  L/S
            total throughout limit (L/S/S) is 2.625 tons/hr or assuming 85%
            operating time, 19,500 tons/yr
            no change since 1986 other than permit application for proposed
            second identical unit which has been denied,  is under appeal and
            not likely by 1993

2.    GSX,  TOC, Roebuck, SC
            still liquids only
            requested permit for proposed RK.
            state is generally opposed
            1993+ is best guess

3.    SC Incinerator,  Tyrell County
            no Tyrell County in SC

3/21/90  10:25  -  Lissie Ketham (4041 347-3433

            returns Thursday, left message
            also left messages for Chip Stuart and Evellyn Ponton

-------
                                     K-43

3/22/90  9:50  -   Chip Stuart. Region IV. EPA,  returned call

1     Kentucky Solite; Brooks, KY
            no storage permit
            call  Mohamid Alloudin (502)  564-6716 (or Hanna Helm)

2.     Kosmos Cement Co.,  Louisville,  KY
            has applied for storage permit
            needs local permit

3     American Resource Recovery Corp.,  Memphis, TN
            call  Larry Fitchhorn, Region IV

      Transferred to Larry Fitchhorn

1.     American Resource Recovery Corp.

      Transferred to Wayne Garfinkel

1.     American Resource Recovery Corp.
            Leo Romminowski is Project  Coordinator
            call  Dale Osher (TN Permitting/Compliance) (615) 741 3424
            facility has  caused local uproar and may have changed


3/26/90  -  Lissie Ketham.  Region V (404) 347-3433

1.     Allied Chemical, Fairfield, AL
            Does  accept wastes from off-site
            burns wood preserving wastes K001,  D004,  D007,  U051, and K087
            not fully commercial
            burns mostly on-site wastes
            maximum capacity is 6 tons/day total

2.     First Chemical
            on-site wastes only
            recently permitted
            not yet constructed
            will  burn distillation bottoms and  wastewaters

3.     Koppers Company
            on-site corrective action underway
            was a wood treater
            now closing SI
            call  Pat Anderson or Leo  Romminowski

      Transferred to Pat  Anderson

1.      Koppers
            was burning K001 in boilers
            was on-site only
            fined $41,000  on 7/28/89
            not currently  burning any hazardous waste


3-2/6/90  -  Mohammid Alloudin.  KY State Permit Writer (502) 564-6716

-------
                                     K-44

            left message to call


3/27/90  1:45  -  Mohammid Alloudin. KY State Permit Writer,  returned call

1.     Kentucky Solite
            not restricted by waste form but believes liquids only burned
            are permitted for storage
            wastes pumped from blender, Environmental Conservation Systems
            one aggregate kiln operating


4/20/90  11:50  Jerrv Banks. MS State RCRA, (601) 961-5171

1.     United Cement Company, Artesia, MS
            Litigation over
            Air permit granted
            Currently modifying injection system
            Constructing truck unloading area for direct feed
            Primarily liquids
            Permit limits:
                  <30% solids
                  <86 gallons/minute
                  >8000 btu/lb
            50% Hazardous fuel is more practical

2     Mississippi Thermal Treatment
            Abandoned project

4/24/90  5:20  Glenn Mov. EPA

1.     TherraalKEM
            Operating under IS
            Permit conditions appealed by TherraalKEM
            Facility is rated at 42 Mbtu/hr
            No overall or sludge/solid feed rate specified
            Limit previously given was for lower chamber only

5/20/90  9:25  Richard Everhart. Jefferson County Air Pollution Control
                  officer,  (502) 625-6000

1.     Southdown Portland
            Owns Kosmos Cement
            Have local permits
            Not yet burning
            Will burn primarily clean solvents, xylene,  thinners,  and off-spec
            oil
            Believes liquids only
            May burn tires
            Have draft RCRA permit
            No capacity limit

-------
                                          K-45
                UNITtD STATES ENVIRONMENTAL  PROTECTION AGENCY, REGION IV

                               345 COURTLAJJD STR£iT, N.E.

                                   ATLANTA,  GA  3v>365
     FACSIMLE TRANSMISSION SHEET
     DATE:       .j/y/yfl          NO. OF  PAGES  (INCLUDE COVER SHEET)
                  / /
     TO:       /d/U,     °lv          FAX
                    J     7
ADDRESS:     (jw'* C,~h^     (//°T       PHONE:
IF THE FOLLOWING MESSAGE IS RECEIVED POORLY, PLEASE CALL
     IN OUR OFFICE AT FTS 257-   7/CJ ?  OR  COMMERCIAL (404) 347-    1 / C
     SPECIAL NOTES OR INSTRUCTIONS
     PLEASE NUMBER ALL PAGES
    MACHINE TYPE      FAX NUMBERS

    HARRIS/3M         FTS 257-5206
    Modal  2225         COMM.   (404) 347-5206
                                                                    r/7   /TAn-^A

-------
13:29
                                      0PM - REGION [
                               K-46
/-w£

                                            ,C   lAMt




                                                 JLue

                                                                      K/0
                           A-*+i't  .i
         CbiJ.lt}      3tT30
                                                                     /{ 500

                           So AX?  tp+c*+«i}

-------
                     34,25/96    39:33
                                               j. S,  E.p.fl. -
                                            K-47
             Urvtctd Ss»C4« Environmental Protection Agency,  Region IV
                          Courtland  Street, N.E.
                         Atlanta,  GA.   30365
  Facsi'ala  Transmission 8htte
ct:
No. of Pages (Include  Cover Sheet)
                         Fax Number i
  tss :
                                   Phon«:   "Teal -
.  che  following mesaag* is receivad  POORLY, please call  	(g\cvvv
-  our  office ac FTS 257-  34^3   or Commerical (404)  347-
icial  Notts or Instructions
     Number All Pages
  me Type
  1  2225
Pax Numbers
FTS 257-5205
Coma.   (404)  347-5205
                                                 WASTK MANAGEMENT DIVISION
                                                 THE FAX, MAN,
                                               AND NOTHING BUT

-------
V.At
                                  K-48
                                                    SxaA
                           PART V - ZNdNZRAIXCN
                               Bcisting Unit
          The Permittee  shall maintain the facility in accordance with the
          design plant and •pacifications  contained in the approved permit
          application.
V.B. fEWUFWANCZ 9ZANDFVPD

          The  Permittee  shall  maintain  the incinerator  so  that,  whan
          operated  in accordance with the operating requireraants specified
          in this permit, it will meat tha following performance standards.

V.B.I.    Tha incinerator oust achiava a destruction removal efficiency
          (EKE) of  99.99% for each principal organic hazardous constituent
          (PCHC) designated in thia permit for each waste  feed.  DRE shall
          be determined using tha method specified in R. 61-79. 264. 343 (a) .

v.B. 2.    The Permittee most control hydrogen chloride  (HC1) emissions,
          such that the rate  of enissions is no greater than the larger of
          either  1.8  Xg/hr or 1%  of the HC1 in the  stack gas prior  to
          entering  any pollution control equipment.

V.B. 3.    The incinerator oust not  emit partial late natter in excess of ISO
          milligrams per  dry standard cubic  meter when collected  for  the
          amount of oxygen  in the  stack  gas  in accordance with tha  formula
          specified in R. 61-79. 264. 343 (c) .

V.B. 4.    Evidence  that compliance with operating conditions specified in
          permit conditions is insufficient to ensure  compliance with  the
          above  performance  standarda  may  be  "information"  justifying
          modification, revocation  or reissuance  of the permit 'pursuant  to
          R, 61-79. 270. 41.

v.c. LmnKncN or  WASTES

          The  Permittee  shall  incinerate  only  those  hazardous   wastes
          identified in the approved permit application and  in accordance
          with  the terms  of the  approved  permit application  and  this
          psc&it.

V.C.I.    The Permittee shall not Incinerate any hazardous waste containing
          an Appendix VHI  organic hazardous constituent of incinerability
          index below 0.22 Xcal/gran.

v.c. 2.    No waste  or combination of wastes, as fed to the incinerator,
          shall have a  heating value greater than  42,000,000 Biu/hr.  This
          heating value  should  include  solid, waste,  liquid/sludge waste,
          industrial gases and auxiliary  fuel.

-------
V.C.3.    ihe ash content of the *««te or combination of wastes as  fad to
          the incinerator shall be no greater than 29.9 weight
          per cent.

v.c.4.    ihe mwt*.^ halogen uuriteiit of the wast* or combination of wastes
          as fad to the incinerator shall b« no greater than 27.2 weight
          par oant.

V.c.5.    Liquid/sludge feed rata to tha lower chamber measured as
          specified  in condition  V.D.15.,  shall be  no  greater  than  33
          Ib/min.

V.c.6.    Noninal flowrata of the waste industrial gasee to the lower
          chamber, measured as specified  in Condition  V.D.15,  shall not
          exceed 100 cfm, or approximately 20% of the atomization air  flow,

V.c.7.    The Permittee shall test each batch of liquid/sludge and  solid
          feed, as fed to the incinerator,  for the following metals:
          antimony, arsenic, barium, beryllium,  cadium, chromium, lead,
          mercury, nickel, silver,  thallium, and vanadium.  Records shall
          be made available to this Department upon Inspection or request.
          A summary of metal concentrations for each quarter must be
          forwarded to this Department within thirty (30) days after the
          end of each quarter.  Within 90 days after the end of one year of
          tasting for vanadium, the Permittee shall submit to the State
          Director a Risk Assessment for vanadium based on this data.

V.D. OFERATDIS CCWDTTICNS

          The Permittee shall  feed  the wastes rteflcrifrert  in  Condition v.c.
          to the incinerator only under the following conditions:

V.D.I.    Combustion temperature of the lower chamber,  measured as
          specified in Condition V.D.15., shall hav« a set point of 2100 F,
          and will be maintained above a minimum temperature of 1730 F.
          This condition must be implemented within six (6) months after
          the effective date of this permit.

V.D.2.    Conbusticn temperature of the upper chamber measured as specified
          in Condition V.D.15.,  shall be maintained  at 2000 degrees  F or
          greater.

V.D.3.    Combustion gas velocity indicator, measured as specified in
          Condition V.D.15, shall be no greater than 99  psig,  as measured
          at the  steam pressure  to  the scrubber  ejector.  The  Permittee
          shall install a continuous recorder for the steam pressure within
          six (6)  months after this permit is effective.

V.D.4.    The duration of carton monoxide levels below 50 ppm,  measured as
          specified in Condition V.D.15, shall not be  less than 32 minutes
          per 60 minutes based  on  a rolling 30 second sampling time.  This
          condition must  be implemented within  six  (6)  months after the
          effective date of this permit.

-------
                               K-50
                      SftRT IV - MBEAL EMISSION LIMITS


The total ccwbined waste feed rate to the lower chamber shall not introducs
the following metals as metals or metal compounds at rates higher than the
following rates.

    Name of                           Maximum Allowable Feed race
    Metal                                 in pounds per hour

  * Antimony                                    2.42
  *• Arsenic                                     0.99
    Barium                                     10.0
    Beryllium                                   0.0044
  «• Cadmium                                    11.98
  *Chronium                                   26.3
  «Lead                                       22.08
    Mercury                                     0.6
    SiIver                                      0.7
    Thallium                                    1.3

N3 m»tals or metal ccropovnda exceeding the final specifications  under  40 CFR
Part 266 shall be fed to the upper combustion chanber.
                                    • c ~'

-------
                                     K-51

REGION V      (312) 353-2000


3/5/90  2:35  IL. Juana Rojo. 996-0990

1.    CVM, Sauget, IL
            three units currently operating   no change
            TB for 4th unit was in 12/89
            Air permitted granted with consent decree to upgrade  all  four
            units
            45 MBtu/hr RK with AB
            tested for PCBs
            tested for D/F
            permit should be finalized by July/August 1990
            planned for Superfund site wastes

      Capacity (from TB conditions as permit)

      Kiln
            High energy fuel, 700 Ib/hr
            Bulk solids 10,000 Ib/hr

      Secondary chamber
            Fuel 25,000 Ib/hr
            44 MBtu max total

      Call state (Rob Wedsin (217) 785-2891)   returns Thursday

2.    SCA, Chicago   no change since beginning of 1989

3.    Oglesby Cement   no info available

4.    Sun Chemical Corp.,  Bedford Park, IL
            submitted application, permit drafted
            company wastes only
            much opposition
            liquids and solids (all Sun plants)
            schedule unknown, not built


Transferred - OH.  Lisa Pierard (312) 353-4789

5.    GSX, Cleveland,  OH
            permitted 1988
            no changes since beginning of 1989 or planned
            no D/F/PCB
            four tons/hr   permitted max
            will fax data

6     Ross, Grafton,  OH
            permit being appealed by Ross
            no change in capacity since 1989
            no plans

-------
10.
11.
12.
                               K-52

Waste Tech, East Liverpool, OH
      proposed commercial
      permitted 1984 or 1985
      appealed by state of WVA
      undergoing design change
      not by 1992 (1993+)
      2 RK units (100 MBtu/hr each)
      100,000 tons/yr   biggest in country
      foreign design
      will fax data

Ohio Lime, Millersville,  OH
      RAF lime kiln
      liquids only
      withdrawing part B application for storage

Allied Chemical, Irontown, OH
      generator only
      no info
      no application
      could be RAF

CWM, OH (West Carrollton)
      RAF
      Liquids only

Ohio Tech, Nova, OH
      application submitted
      new, greenfield site
      13 months + for permit
      much opposition
      1993+ at best
      30 tons/hr max (application)

Thermaltron, Cleveland, OH
      not RAF or incinerator
13    Sanatize Industries, Youngstown,  OH
            commercial
            1993+
             125 tons/hr maximum

14.    PPG,  Circleville,  OH
            new unit replacing old
            on-site only
            permitted and operational
            liquids/sludges/solids
            58 MBtu/hr
            faxing capacity data

15    BP America Research, Warrensville,  OH
            on-site

-------
                                     K-53

16    BP Chemicals,  Lima OH
            on-site

1^    Catalyst Resources,  Oleria,  OH
            liquids  only on-site

18    Lubrizol,  Dainsville,  OH
            on-site
            not yet  permitted

19    RMI,  Sodium
            on-site  D001 only -  permitted

20    Lubrizol   Wickliffe,  OH
            permitted
            on-site
Transferred to IN.  Hak Cho (312)  886-0988

21.   Stauffer,  Hammond,  IN
            modified industrial furnace
            reactivated as incinerator
            possibly commercial
            draft permit  scheduled 1991
            1993+ on-line

22.   ENSCO,  Troy,  IN
            nothing submitted
            dead project

23    Coplay Cement, Logansport,  IN
            storage permitted
            trial burn approved
            non-commercial
            liquids only

24    BASF,  Terre Haute,  IN
            very preliminary
            not  dead
            1993+ at best

25    Amoco,  Lake Charles
            on-site S/S/L
            fluidized bed
            permitted Nov  1989
Transferred to MI,  Lorna Jereza

26.   Augusta Development, Lanawee County, MI
            proposed
            no application submitted
            1993+

27    St. Mary's Peerless Cement Co  , Detroit, MI

-------
                                      K-54

             scheduled for 1992  (on-line)
             liquids  only

28     Michigan  Technology,  Detroit,  MI
             no  info
             preliminary  at  best
29
Wayne Disposal is Augusta Development
30    Nortro/Petro  Chem
             no  incinerator,  tank  treatment  only
             fuel blender,  not  burner

31.   UpJohn
             captive only
             won't close
             burns clean solvent and animal  carcasses

32.   DOW, Midland, MI
             liquids only    IS
             on-site
             changing over  to RK
             operating and  permitted (recently)
             1 "6 9s" RK for dioxins being built
             construction to be complete 3/91
             TB  complete 9/91
             final permit by 12/91
3/6/90  2:00   -  Lisa Pierard

1     GSX, Cleveland
            4  tons/hr permitted maximum sludges + solids combined

2     Waste Tech, Circleville, OH
            greenfield facility
            redesigning equipment
            propose 2 RKs
                  each with:  100 MBtu/hr max
                              -100,000 tons/hr total

3     Allied Chemical, Ironton, OH
            would take some time to track

4     PPG, Circleville,  OH
            58 MBtu/hr
            will fax data on GSX,  Wastetech + PPG
            Wen Huang not available
            Lorna Jereza,  in training, left message
            Jauna Rojo,  in training, left message

3/6/90  4:00   -  Amy Dragovich from Region V called and left message


3/6/90  4:30   -  Amy Dragovich (217) 782-6762   no answer

-------
                                     K-55

3/6/90  5:05  -   Amv Dragovich (IL  State)

            CWM,  Sauget was denied permit
            has  appealed
            no details available


3/7/90  3:45  -   Jana Roio out till Friday


3/8/90  2:05  -  Rob Watsin (IL State)  (217) 785-2891

            will  check on capacities for SCA,  Chicago and CWM, Sauget

            Sun  Chemical
                  permit application under review
                  new facility
                  company capture liquids and solids
                  schedule unknown

            call  back around 3:30


3/8/90  2:15  -  Lisa Pierard (312)  353-4789

            call  Thelma Codina,  permit  writer  for:
                  GSX,  Cleveland,  OH
                  Waste Tech,  East Liverpool,  OH
                  Ross,  Grafton,  OH


3/8/90  2:30  -   Hak Cho (312)  886-0988

            not  available,  left  message

-------
                                     K-56

3/8/90  5:00  -  Rob Watsin (IL State)

      From Sara CAP Report:

                              Liquids Capacity        Solid Capacity
      TWI  (CWM) Sauget           (tons/yr)              (tons/vr)

            1987                    17,472                  8,736
            1989                    17,472                  8,736
            1995                    32,340                 71,400
            2009                    32,340                 71,400
                              Liquids Capacity        Solid Capacity
      CWM (SCA)  Chicago          (tons/vr)               (tons/vr)

            1987              25,998 or 43,470        12,999 or 21,735
            1989              25,998 or 43,470        12,999 or 21,735
            1995              25,998 or 58,338        12,999 or 84,399
            2009              25,998 or 58,338        12,999 or 84,399

      TWI:
            Unit //I     16 MBtu/yr
            Unit #2     18 MBtu/hr
            Unit #3     18 MBTu/hr
            Unit #4     RK with unknown thermal rating

            Call Hope Wright (same #) for capacity numbers from trial burn
            report

            call Jim Cobb (Air Pollution Group) for status of TWI  unit //4

            Mr  Watsin is not willing to look up Ib/hr specifications from
            applications
3/8/90  5:20  -   Thelma Codina (312)  886-6181

      GSX,  Cleveland
            sludges and solids only
            modified drying bed with  vapor burner
            permitted maximum is 4 tons/hr

      Ross,  Grafton, OH
            does not burn dioxins
3/9/90  11:50  -   Wen Huang (312)  353-2000  (886-6191)

            call  Thelma Codina on Waste Tech,  OH

            Ohio  Tech, Nova,  OH
                  sludge/solid capacity not in application
                  62-65 MBtu/hr proposed
                  will call me back

-------
                                     K-57

3/9/90  3:40  -  Thelma Codina (312) 886-6181

1.    GSX
            slightly limited in waste codes allowed
            maximum permitted capacity for combined sludges and solids is 4
            tons/hr (no liquids accepted)

2     Ross, Grafton, OH
            maximum permitted limit for combined sludges and solids is 6000
            Ib/hr
            upon successful TB,  max sludge solid limit will be increased to
            7500 Ib/hr
            maximum liquid feed rate (all ports combined)  22,190 Ib/hr
            upon successful TB,  max liquid rate will be increased to 25,190
            Ib/hr
            second unit planned,  no application submitted


3/12/90  10:25  -  Thelma Codina (Region V) (312)  886-6181

1.    Waste Tech, East Liverpool,  OH
            no TB yet
            total permitted maximum is 22,000 Ib/hr
            estimated as 50 percent solid, 36 percent liquid,  14 percent
            sludge
            permit is close to expiring
            call Bob Babik, OH EPA (614)  644-2917


3/12/90  Jauna Roio. Region V Office (312) 886-0990

1.    SCA (CWM),  Chicago

            Permitted feed limits  for single existing unit:
            (design capacity)
                  liquids 15,000 Ib/hr
            sludges/solids 24,000  Ib/hr
                  no annual limit
            just submitted new Part B for proposed 130 MBtu/hr RK
            currently burn liquid  PCB's in secondary chamber
            permit was denied because of storage practices
            will FAX TB feed rate  data


3/13/90  1:40  -  Jauna Roio (312)  886-0990

            left message requesting CWM,  Sauget capacity figures


3/15/90  8:45  -   Jim Cobb, Region V State Office

1.    CWM (SCA) Chicago
            from 1983 Air Permit,  (RCRA permit held up)
            thermal rating more limited than throughout limit,  consequently
            high Btu/lb liquids more limited
            call Harry Chapel (217) 782-6760 on IL CAP

-------
2.
                               K-58

      total throughout estimated at 12,000 Ib/hr
      storage capacity is not a problem
      call Rob Watsin in Land Division

For existing unit:
      120 MBtu/hr max heat release total
                  30 MBtu/hr   non-liquids to kiln
                   3 MBtu/hr   contained solids changed
                  90 MBtu/hr   after burner limit

CWM (TWI) Sarget, IL
Unit #1
            14 MBtu/hr max, 2000 Ib/hr
            fixed hearth with secondary chamber
            must burn some liquids to burnt ash
      Unit
      Unit #3
      Unit #4
            16 MBtu/hr, 2000 Ib/hr
            very similar to Unit #1
            burns liquids in secondary chamber
            State requires and reports feed rates in an annual report


            Identical  to #2
                  currently accepting wastes
                  50 MBtu/hr RX with vertical secondary chamber (kiln 25
                  MBtu/hr, secondary chamber 30 MBtu/hr liquids)
                  35 ft long, 7 ft inside diameter
                  prototype "mobile" unit
                  many input ports
                  from TB plan:
            To kiln:  Aqueous wastes
                      Fuel oil
                      Sludges
                      drummed solids
                      bulk solids

            Feed to secondary chamber:
                  waste fuel
                  fuel oil
                                      666 Ib/hr
                                      529 Ib/hr
                                      657 Ib/hr
                                    2,958 Ib/hr
                                    4,540 Ib/hr
                                    1,103 Ib/hr
                                      455 Ib/hr
            storage not a problem
            not planning to burn dixons and furans
            specified feed rates are simultaneous
            no overall throughput maximum specified on Part B application
3/19/90  12:50
             Jim Cobb. IL State Program
1.    CWM (TWI),  Sauget, IL
            feed rates given for TWI units 1, 2, and 3 (2000 Ib/hr) are
            estimates of maximum practical throughput based on general waste
            Btu value (8000 Btu/lb) , and maximum thermal ratings

-------
                                     K-59

            real chemical wastes typically have Btu/lb' greater than  8000
            3rd unit is permitted and has been on-line for about 2 years
            feed rate estimates for unit 4 are based on TB which has yet  to  be
            approved
3/21/90  11:45  -  Lisa Pierard.  Region IV (312) 352-4789

1.     Allied Chemical, Ironton,  OH
            closing tank and drum storage area
            not sure if closing burner
            call Mike Mochelle,  OH State Inspector

2.     Ohio Lime
            not going to happen
            company yielded to public opposition
3/21/90  12:00  -  Mike Mochelle (614) 385-8501

            returns from vacation on Monday
            no one else can help
3/21/190  2:10  Hak Cho.  Region V EPA (IN)

1.     Coplay Cement, Logansport,  IN
            industrial furnace

2.     Stauffer Chemical,  Hammond, IN
            call Date Beel or Elane Greg at IN RCRA program (317) 232-8855)
            call Gary Victorine (886-1479), EPA Permit Writer for IN
            for facilities in IL, call George Hamper,  IL Section Chief (886-
            0987)
3/21/90  2:15  -   Dale Beel.  IN RCRA (317)  232-8855
            out today, left message
            Elaine Greg also out today

-------
                                     K-60

3/21/90  2:20  -  Gary Victorine. IN Permit Writer (312) 886-1479

1.     Stauffer Chemical, Hammond, IN
            still operating under RAF exemption
            sulfuric acid regeneration facility
            in process of obtaining RCRA permit but no physical changes


3/22/90  3:25  -  Shamela Sherry  Region V IN (317) 232-8852

1.     Coplay Cement
            burns solvents only
            can burn sludges (if injectable)
            no storage area for sludges
            2 kilns operating
            no permit for kilns
            operate 2 blending tanks
            2 storage tanks permitted last year
            TB conducted in 1986

2.     Lone Star Cement
            has storage permit
            burns liquids only
            will look into capacities


3/26/90  9:30  Elaine GreE. IN DO Env Mgmt (317) 232-8866

1.     Coplay Cement, Logansport, IN
            obtains fuels from PatChem Fuels
            filters fuel as unloaded and drops resulting "bags" of
            sludge/solids into clinker cooler
            has storage permit
            is not  allowed to accept sludge/solids, wastes must be pumpable
            total waste feed rate is limited to 1800 gallons/hr (2 kilns
            combined)
            only sludge/solids burned are those removed from "liquid" fuels

2     Lone Star Cement, Green Castle, IN
            Systech is  fuel handler
            burns sludge/solid filter cake (from filtering liquid fuels) in
            "injection  cannon"
            currently IS storage
            can't accept sludge/solids from off-site, only burns sludge/solid
            removed from liquids
            1 kiln has  capacity  to burn 3000 gallons/hr
            no state permit but  "Approval Letter"

3.     Stauffer Chemical
            call Mitch  Mosner, 232-3221

-------
                                     K-61

3/26/90  1:35  -   Mich Moser. Ohio EPA, (317) 232-3221

1.    Stauffer Chemical, Hammond, IN
            plan to submit Part B for incineration
            are currently operating as RAF
            do burn sludges
            capacity unknown


3/27/90  9:50  -   Thelma Codinas. Region V (312) 886-6181

1     GSX,  Alchem-Tron,  Cleveland, OH
            not currently operating
            awaiting trial burn
            awaiting state permit
            state recently authorized
            call  Bob Babik (614) 644-2917


3/27/90  10:00  -  Bob Babik. OH State RCRA

1.    GSX,  AlchemTron, Cleveland, OH
            permit being reviewed by board
            unit  is constructed
            call  Ed Lim at (614) 644-2974


3/27/90  4:05  -   Ed Lim.  OH EPA (614) 644-2974

1.    GSX,  Alchem-Tron,  Cleveland, OH
            facility is  constructed
            permit expected in 1991
            had been sludge drying pits

2     Southwest Portland,  Dayton, OH
            burns hazardous liquids as fuel
            maybe some sludges

3     General Portland (Lafarge), Paulding, OH
            burns hazardous fuels
            believes liquids only

4/5/90  12:25  Juana Rojo.  312-886-0990

1.    CWM,  Chicago, IL
            Permit limits:   15,000 Ib/hr liquids
            24,000 Ib/hr sludges & solids
            May include  PCB capacity
            Conducted trial burn in 1989
            Will  fax data

-------
                                     K-62

4/5/90  4:45  Thelma Codina. returned call

1     Ross Incineration, Grafton, OH
            Lower pretrial burn limits currently in effect (indefinitely)
            TB was completed at higher rates
            Ross is appealing permit conditions

4/24/90  4:00  Larry Estep.  IL State RCRA permit worker (217)  782-9882

            U075 and U121 prohibited from CWM, Sauget
            SCA has been denied permit but can burn U075 and U121 under
            interim status during appeal

4/26/90  2:00  Lori Stevenson. OH EPA  (614) 385-8501

1.    Allied Chemical,  Ironton, OH
            Undergoing  complete closure of last TSD unit

-------
                                  K-63
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION V
 /* t*r>A                    230 South Durborn Strut
Otr/A                      CHICAGO IL 60604
                             fUA$t mtuf in §m ex /** o*t r
703-'^.^
MACHINE KR:
3 - ^3^ -**'
7^0
VERIFICATION NR: ""
ROM
      L(5
-pi
              353-

                                    - 13
                      P I2> -  OK'
                   , o
                                           c -h
 9AH
                         NUM«M o» p*AOtt TO majuDf TH« COVM cntrr
                                     number tff

                   INFORMATION FOR SENDING FACSIMILE MESSAGES
                                                                 VlfUnCATION
                                                                  NUMMft
PANAFAX PX-100


J[EROX AOO
                               PTS:   886-9096Uuto)
                               COMB:  ( 31 2) 886-9096
                               PTS:
                               Coma:  (312)886-3096
                                             FTS:   886-3096
                                             COM: (312)886-3096

                                             FTS:   886-3096
                                             COM: (312)886-3096
                                PACE
                         OF
                                               PACES

-------
                                   K-64
                Modification of me RC*A Permit Issued to PPG ! ndust r-es . - Ore /cvj lit
 Inc.,  ID SO. OHO Qui 30: 639.
                  — ^^^^^^BM^^n^^^^^

 The U.S. PA has determined that so^e of Attachment I  Permit Conditions
 Attac^~ert  ii Waste Analysis Plan should he revised, clarified and/or a
 m orcer to  incorporate tne results of tne trial bur- submitted by P?G
 Industries  on ".ay 5. 1988.  the following table Msts  the permit conaiti
 and waste analysis pia- that have been changed and the changes and/or a
 which  h^ve  been made,  words or phrases that have been added or revised
     l i n^a,  and words or phrajes that have been deleted are lined out.
       Condition        Addition
C,23.(^                "...shall not exceed 100 ppn by dry volume basis p- ^
                         SO-T.i'-ute ting weigngd rolling average anc shell  j e^
                         rror, i to red. . .

                        Change

C.23.(b)(i)             "Tne total feed rate,
                            waste fees ?«%e
                                       thermal  load to the. incinerator
                        4s J4R4ted to the f««§e
                                               te §8.d
                              (3
                        shall De 9re&t^an 3 x 106 6TU/hr ar.d shall  not
                                        _
                        exceed 5 ylD  BTu/nr on 10-minute tine average"
C.23.(b) . I i i i )          "The feed rate of gaseous
                        4A€^«44A§ waste feed a«4
                        auxiliary fuel to the incinerator must be monitored.,.,"

C.23.(b)(iv)             "..., whichever is greater lesser;"

C.23.(b)(vi)             "... the rotary kiln shall «9t neither
                        exceed i-,999 6^.600T pounds per hour
                        424 eperat4fl§ «SWP a*er«8e) no*- 500 pounds
                        per charging cycle;"

C.23(b)(vii)             "...may not  exceed 200 lb per hr.
                        (3 »peFat4fl9 nea^ average^; and"
C .23 .(b)( vi 1 1 i)          "...shall  not contain any chemical
                        ee«st4t«e*ts constituent listed in 40 CFR
                        Part 261,  Appendix VIII, which *«*e has a heat
                        of combustion lower tnan that of
                                          carbon tetrachloride.

-------
                                     K-65
                        AdditiQft/Chjnge

C . 2 3 . ( c )                "The temperature of Mln outlet  gas  shall  be  maintained
                        it 185^gr"br O'-eaieT]   Tne temperature  of  the combustion
                        gas in the secondary combustion  chamber,
                        prior to the seeeffda^y  «4f
                        red rculating Hue gas  injection,  shall  be
                                 maintained at'  a
                        (1799) ef i2942g (22992F),  s«b4.e€t
                        te the festiUs ef the  tf4a*  b«f«s
                        1600°P or greater.   if the  tfa4* &B^«  fit  92?2C
                             "            the
                                               e. 4
                        The temperature of  tne  combustion  gas  in  the  secondary
                        combustion cnamber  j«*t  prior  to the
                        secemafy a4f reci rculating  flue gas  Injection  shall
                        be monitored., 77"

                         Change

C.23.(d)                "...,  shall  not  exceed  31,999  27.000  standard cubic
                        feet per minute... ."
                                                                               %
C.23.(e)     '           "...must be  greater than  «Hfee (3) seven  (7)  per cent
                        by dry volume basis ...."

C.23.(g)                "...shall be no less  than 7.0   6.5 . "

                        Revision

C.23.(i)       '         "The feed rates  of  lead,  chrome and mercury shall not
                        eTceed 320 Ib /nr,  170  Ib/hr and 61b/hr,  respectively."

C.23.(»                Within six (6)  months from the issuance of this
                        Permit modification,  the  Permittee shall  submit to
                        the Regional  Administrator a written  implementation
                        plan for control of other toxic metals  (antimony,
                        barium, silver,  thallium, arsenic, cadmium and
                        berryllium)  and  hydrogen' chloride  emission from the
                        incinerator.  The  implementation plan  shall Include
                        all  necessary steps the Permittee will take to comply
                        with the then-effective  emission limits specified in
                        the U.S. EPA  "Draft Guidance on Toxic  Metals  and
                        Hydrogen Chloride Controls for Hazardous  Waste Incinerators
                        dated  June 9, 1988, within one year from  the  Issuance
                        of this permit  modification.

-------
C.20   Inspections.                      K"66
       The Incinerator and associated equipment shall  be  Inspected  in  accordance
       with the Inspection plan (permit attachment  IV)  and  40 CFR 264.347.
C.21.   Inspection Records.
       The Incinerator monitoring and inspection data  must  be recorded  and the
       records foist  be placed in the operating log  in  accordance with  40 CFR
       264.347(d).
C.22.   Incinerator Closure.
       The Incinerator 1s to be closed in accordance with 40 CFR 264.351.  The
       Incinerator closure is detailed 1n the closure  plan  (permit  attachment
       VI).
C.23.   General Operating Require/rents for Incineration System.
   (a)  The carbon monoxide (CO) level  in the flue  gas leaving the  electrostatic
        precipitator shall not exceed 100 ppm by dry volume basis and  shall be
        monitored and recorded on a continuous basis.
   (b)  The waste feed operating and monitoring requirements are:
           (1)   The total feed rate, including the waste feed rate and auxiliary
                 fuel to the incinerator, is limited to the range of 34.8 million
                 Btu/hr to 58.0 million Btu/hr heat input (3 operating  hour average);
          (11)   The feed rate of pumpable materials,  including waste  feed and
                 auxiliary fuel , to the Incinerator must  be monitored  and recorded
                 on a continuous basis;
         (111)   The feed rate of gaseous materials, including waste feed  and
                 auxiliary fuel , to the incinerator must  be monitored  and  record-
                 ed on a continuous basis;

-------
                ~~               K-67
  (1v)    The  feed rate of nonpumpable material s,Including waste feed and
         auxiliary fuel, to the Incinerator must be monitored and logged
         on a  periodic basis; not to exceed the charging cycle or fifteen
         (15)  minutes, whichever 1s greater;
   (v)    Only  gaseous and aqueous liquids materials may be Injected into
         the  secondary combustion chamber;
  (vi)    The  solid waste feed to the rotary Uln shall  not exceed 6,000
         pounds  per hour (24 operating hour average);
 (vii)    Based upon the waste analysis plan, the total  chlorine content of
         the materials fed to the Incinerator (Including both the rotary
                              /
         kiln  section and the secondary combustion chamber) may not exceed
         200 Ib  per nr. (3 operating hour average);  and
(v111)    Based upon the waste analysis plan, tht waste  feed shall  not
         contain any chemical  constituents listed 1n  40 CFR Part 261,
         Appendix VIII, which have a heat combustion lower than trlchloro-
         monof1ouromethane.
   (c)    The temperature of the combustion gas 1n the  secondary combustion
         chamber, just prior to the secondary air Injection, shall  be
         maintain at a minimum temperature of 927°C (1700) or 1204*C
         (2200°F), subject to the results of the trial  burns.  If the
         trial burn at 927°C falls to achieve the performance standards
         1n condition C.4, then the minimum required temperature shall
         be 1204°C.  The temperature of the combustion  gas in the
         secondary combustion chamber just prior to the secondary air
         Injection shall  be monitored and recorded continuously.

-------
                                    K-68
EPA
UNITED STATES CXVItOMMEXTAL HOTECTION AGENCY, UCION V
             230 South Dearborn Street
                 CHICAGO 1L 60604
    FACSIMILE REQUEST AND COVI
d/PHONt
-703 - ^
Tto
OH 4s €
MACHINE NR: ?
-------
                             K-69                   F«v.  al  Express §3401151401
CWM Chemical Services, Inc.
11 700 S. Stony
Chicago, IL 60617
3 12-W 6-5700

August 22, 1989


Mr. Ctrl Bremer
waste Management Division, 5HR
United States Environmental
 Protection Agency
230 S. Dearborn Street
Chicago, IL  60604

      RE:    CWM Chicago Incinerator, Trial Burn Results

Dear Mr. 8 rawer:

Please find attached a letter transmitting the preliminary  results  on the RCRA
Trial Burn performed at the Chicago Incinerator by MRI.  To assist  the USEPA
in maintaining Its critical permitting schedule, we are  providing this key
Information from the burn which Indicates:
      1)  DRE - all runs greater than 99.
      2)  Participate emissions - all runs less than 0.08  gr/dacf.
      3)  HC1 removal efficiency - all runs greater than 99*.
      4)  Waste feed rates and process Information for all  runs.
      5)  Heat Input rates for all runs.
      6)  Chlorine Input rates for all runs.
      7)  Metal feed rates and emission rates for all runs.

      Note:  Run 1 was disqualified.

Despite the best efforts of CWM, MRI and regulatory agencies,  the  final  Trial
Burn report 1s not yet available.  CWH 1s confident, however,  that with  the
data submitted herewith and a final report which MRI will  complete and CWM
will submit by September 11, 1989, the USEPA can finalize  those  permit
conditions requiring Trial Burn data.

If any additional information 1s required, please contact  me  immediately.
Douglas H. Fisher, Manager
Health, Safety l> Environmental Compliance

DHF/mJr

Attachment

cc:  Kurt Frey
     Johan Beyer
     Ed Kenney
     Pred trunner
          if CMmtt WUM M**»»n«nt. me.

-------
                                  K-70

                                                                 MIOW18T RfSCARCH IN3TI7U
                                                                             428 Vo
-------
                                 K'71
Mr. Douglas Fisher
Page 2
August 21. 1989
MIOWtfT
                                                                            CH
presently undergoing QA review,  so the results 1n the draft report may be
different from those shown  1n  the attached tables, but any changes are
expected to be minor.

                                              Sincerely.

                                              MIDWEST RESEARCH INSTITUTE
                                              Paul Goman
                                              Principal  Chemical Engineer
Approved:
Chatten Cowherd. Director
Environmental Systems Department

cc:  K. Frty—CWM
     J. Bayer.-CWM

-------
                                K  72
               TABU 1.  SUMMARY OF EMISSION PERFORMANCE

ORE m
Carbon tetrachlorlde
Tetrachloroethylene
1,2, 3-Tr 1 ch 1 orobenzene
Part 1cu late concentra-
tion (gralns/dscf)
corrtcttd to 7% Oa
HC1 Mission (Ib/h)
HC1 removed efficiency
(X)
Average 0. (X)
Plant CEM
Orsat
Average CO (pp«)
Plant CEM
MftI CEM
Run 2
> 99.9981
> 99.9980
99.9989
0.0795
1.42
99.92
9.7
10.0
5
1
Run 3
> 99.9984
> 99.9978
99.99986
0.0530
0.72
99.95
10.4
10.4
5
< 1
Run 4
> 99.9986
> 99.9982
> 99,999987*
0.0405
0.48
99.97
10.8
10.0
4
1
Run 5
> 99.9990
> 99.9981
99.99991
0.0315
0.42
99.97
10.5
10.4
4
< 1
* ORE for TC8 1n Run 4 1s uncertain, due to low surrogate recovery
  efficiency.

-------
                                 K-73
             TA81E  2.   SUMMARY OF  INCINERATOR OPERATING  DATA

Feed rates
Organic liquid feed (lb/«1n)
K1ln
SCC No. 1
SCC No. 2
Aqueous feed to SCC (QPM)
Fuel oil to SCC (QPM)
Sludge (Ib/a1n)
Drum solids (Ib/h)
Operating parameters
Kiln teap. ("F)
SCC tenp. (*F)
Scrubber Inlet te«p. (4F)
Red re. water to quench
(QPM)
City water to quench (6PM)
Red re. water to scrubber
(QPM), No. 1
No. 2
Scrubber Inlet pH
SCC pressure (1n w.c.)
Stack velocity (acfi)
Plant continuous aonltors
oVW —
CO 2 (X)
CO (pp»)
THC (pp«)
HC1 (ppa)
Run 2
27
36
34
3.0
0.48
0
3,950
1746
2027
178
416

139

559
569
8.8
•0.50
41,600

9.7
9.4
5
4
15
Run 3
27
26
M-
4.1
0.56
0
4,130
1755
1869
174
413

173

523
530
9.1
-0.40
43,400

10.4
9.0
5
2
17
Run 4
28
27
8-
5.9
0.48
0
^M9
-------
                                     K-74
REGION VI
2/28/90  5:10
Maria Daniels. EPA Region VI
1.     Chemical Waste Management, Port Arthur, TX
            currently operating under post-trial burn conditions (90 days •+• 90
            additional possible)
            permitted feed rate limits based on trial burn:
      Liquids to kiln
      Liquids to Afterburner
      Sludges to kiln
      Solids to kiln
                              Nonenergetic Wastes
                               (X5000 Btu/lb)
               10.000 Ib/hr
               41,375 Ib/hr
      Maximum mass feed to unit including fuel:
Energetic Wastes
 (> 5000 Btu/lb)

      3000 Ib/hr
      8900 Ib/hr
      5300 Ib/hr
      3000 Ib/hr

    50,270 Ib/hr
 or 150,00 tons/yr
3/5/90  4:10  - Jim Sales (214) 655-6785

1.    Rollins, Deer Park, TX
            two trains
            faxing data

2.    American Envirotech (Lullint/Houston) ,  TX
            application submitted
            commercial
            responding to NODs
            not constructed
            could be permitted by end of 1990
            much opposition
            faxing capacity data

3.    Gulf Coast Waste Disposal Authority
            withdraw application
            won't be built

4.    Ideal Cement Co., Saratoga, AR
            no info available
            no storage permit

5     Oglesby Cement Co  , Houston, TX
            no storage permit
            no info available
      Marine Shale Processors, LA
            under enforcement
            call Jerry Truitt, 6794

-------
                                     K-75

7     Houston Chemical Services (HCS)
            fluidized bed
            constructed
            public hearing extended
            much opposition
            not permitted
            could be permitted by 1991
            no dioxins/furans/PCBs

8.    Thermal Kinetics, Lonester,  TX
            R&D permit only

9     Boxcrow Cement
            no info available

10    Catalyst Resources
            existing   will shut down
            liquids only
            on-site

11.   ENSCO, El Dorado, AR
            two units
            no change since beginning at 1989
            second rotary kiln added in 1989
            permitted and operating
            also a fixed/transportable unit
      Max practical throughout (based on current operators   from on-site
      inspector)

            10 75 tons/hr (kilns 1+2 combined)
             + 25% (kiln 3)
             - 14 tons/hr

            PCBs   yes                          overall facility practice
            D/F    no                           liquids 21,500 Ib/hr
            permit doesn't limit capacity       solids 12,900 Ib/hr

12.   Rollins.  Baton Rouge, LA
            no change since beginning of 1989
            missed deadline because of protracted LA process
            many deny permit
            currently under "Adjudicary Hearing"
            if closed,  appeal would allow operation for 2-3 years

13    Ash Grove Cement, Foreman, AR
            no info available
No incinerator in the country (at least commercial) is permitted for dioxins
and furans

-------
                                     K-76

3/6/90  2:30  - Maria Daniels  (214) 655-6785

13    CWM, Port Arthur, TX
            data already obtained
            call TX Underground Injection Control board 655-7160

14.    Envirosafe, Devers, Texas
            faxing data

15    BASF, Freeport, TX
            operating
            not commercial
            on-site
            faxing

16.    Celanese, Seabrook, TX
            (missed deadline)
            call Lydia Bolada  (6785)
                  not in now

17.    Mobay, TX
            had on-site (small)
            withdrew permit application
            will resubmit

Transferred to Henry Ansgard   wanted written request

18.    Stauffer Chemical, Houston, TX
            liquids and some pumpable sludges only
            sulfuric acid regeneration
            commercial energy  recovery

19    DuPont, LaPorte, TX
            on-site liquid injection
            liquids only (maybe some pumpable sludges)

20    IT, Corp., Ascension Parish, LA
            won't be built
            lost state permit

21.    Waste Tech, Lake Charles, LA
            only PPG wastes
            fluidized bed
            mostly liquids, some sludges
3/7/90  4:55  -  Jim Sales unavailable, left message
                 Maria Daniels unavailable, left message
3/8/90  11:55  Maria Daniels (214) 655-6/85

            faxing data

-------
                                     K-77

3/8/90  2:45  -   Stan Burger (214) 655-6775, unavailable, left message


Transferred to Jim Sales

Houston Chemical
            call state Facility Manager, (512) 463-8173


3/8/90  2:55  -   Sandy Harwopd (TX state)
            unavailable, left message


3/8/90  3:20  -   Sandy Harvood. left me a message


3/8/90  4:30  -   Sandy Harwood

            call Lisa Ligas on Houston Chemical (512) 463-7999


3/9/90  12:10  -  Lisa Ligas. Texas Water Commission (512) 463-7999

1.    Houston Chemical Services,  Bayport, TX
            was  owned by Quaker Oats
            two  giant FB incinerators for rice hulls
            new owner proposed adding RK
            hearing ended 2/9/90
            permit decision expected 5/90
            will be fully commercial
            1 RK   90 MBtu/hr
            2 FB each 230 MBTu/hr

2.    call Kyle  Shelton, 8278 on Rollins, Deer Park

3     call Wayne Harry,  8534 on CWM, Port Arthur

4     call Rex McDonald, 7969 on American Envirotech

5.    call Office of Notification and Classification at 463-8175 on notices of
      registration by cement kilns

6.    never heard of Thermal Kinetics

7     call Troy  Wappler, 465-2296 on Stauffer Chemical, of Houston

8.    Hoesct Celanese,  Pasadena,  TX
            operating
            on-site
            liquids only

-------
           BACKGROUND DOCUMENT FOR
    THIRD  THIRD WASTES TO  SUPPORT  40  CFR
     PART 268 LAND DISPOSAL RESTRICTIONS

                  FINAL RULE

 THIRD THIRD WASTE VOLUMES. CHARACTERISTICS,
AND REQUIRED AND AVAILABLE TREATMENT CAPACITY

                  Volume IV
                  CHAPTER 4
           APPENDIX J   APPENDIX M
     U.S.  Environmental  Protection  Agency
            Office of Solid Waste
              401  M Street,  S.W.
           Washington, D.C.  20460
                   May 1990

-------
                              TABLE  OF  CONTENTS

                                                                          Page
Section                                                                   -^-

Volume I

EXECUTIVE SUMMARY                                                         E-l

1   INTRODUCTION                                                          1  i

    1.1  Legal Background                       •                          1-1
         1.1.1   General Requirements Under HSWA    .                      1-1
         1.1.2   Schedule for Developing Restrictions   .                  1-1
         1.1.3   Variance from the Schedule                               1-2

    1.2  Summary of Previous  Land Disposal Restrictions                   1  3
         1.2.1   Solvents and Dioxins                       .              1-3
         1.2.2   California List                                          1-5
         1.2.3   First Third  Wastes                 .                      1-6
         1.2.4   Underground  Injected Wastes  .  .                          1-7
         1.2.5   Second Third Wastes  (surface disposed and
                 underground  injected wastes)         .                    1-9

    1.3  Introduction to the  Third Third Final Rule                       1  10
         1.3.1   Surface-Disposed Wastes                                  1-10
         1.3.2   Deepwell-Disposed Wastes                   .              1  11
         1.3.3   Soil and Debris      .  .        .  .        .                1  11
         1.3.4   Mixed Radioactive Wastes         .                        1-11

2.  CAPACITY ANALYSES RESULTS                   .      .      .              2-1

    2.1  General Methodology                                   .  .          2-1
         2.1.1   Data Set Development   .                    .              2-2
                 2.1.1.(1)   National  Survey of Hazardous Waste
                            Treatment.  Storage.  Disposal,  and
                            Recycling Facilities     ....          2-2
                            2.1.1. (l)(a)  Background                      2-2
                            2.1.1.(l)(b)  Schedule and status    .          2-3
                            2 l.l.(l)(c)  Technology capacity
                                          information   .    .      .        2-4
                            2.1.1.(l)(d)  Waste  volumes land
                                          disposed      .                  2-5
                            2.1.1.(l)(e)  Overview of data
                                          handling,  technical
                                          review,  and quality
                                          assurance     .    .  .            2-6
                            2.1.1.(l)(f)  Chemical Waste
                                          Management   Emelle
                                          Alabama                          2-7
                 2.1.1.(2)   National  Survey of Hazardous Waste
                            Generators              .  .    .    .            2-9
                            2.1.1.(2)(a)  Background  	        2-9
                            2.1.1. (2)(b)  Schedule and status              2-9
                            2.1.1.(2)(c)  Uses    ...      .  .            2-9

-------
                         TABLE  OF  CONTENTS  (continued)
Section
                 2 . 1. 1. (3)  Mulci-Source Leachate Data Sources           2-10
                 2 . 1.1. (4)  Mixed Radioactive Waste Data Sources         2-10
                 2.1.1.(5)  Other Data Sources                           2-10
         2.1.2   Capacity Analysis Methodology                           2-11
                 2.1.2.U)  Required Capacity                            2-11
                 2.1.2.(2)  Available Capacity                           2-13

         Results    .      .    .       .                                    2-14
         2.2.1   All RCRA Wastes                                         2-15
         2.2.2   Solvents   .                     .                        2-17
         2.2.3   Nonsolvent RCRA Wastes Containing
                 Halogenated Organic Compounds (HOCs)                    2-19
         2.2.4   First Third Wastes                                      2-26
                 2.2.4.(1)  All First Third Wastes                       2-26
                 2.2 4. (2)  First Third Wastes for Which Formal
                            Treatment Standards have been
                            Promulgated                                  2-26
                 2.2.4. (3)  Soft Hammer Wastes from the First
                            Third Final Rule                             2-31
         2.2.5   Underground Injected Solvent Wastes                     2-32
         2.2.6   Underground Injected California List Wastes             2-34
                 2.2.6.U)  Free Cyanides         .                       2-34
                 2.2.6.(2)  Metals    .                                   2-34
                 2.2.6.(3)  Chromium Wastes                              2-34
                 2.2.6.(4)  Corrosives                                   2-36
                 2. 2. 6.(5)  Halogenated Organic Compounds                2-36
                 2.2.6.(6)  Polychlorinated Biphenyls (PCBs)             2-37
         2.2.7   Underground Injected First Third Wastes                 2-37
                 2.2 7 (1)  K062 Wastes                                  2-37
                 2.2.7 (2)  K049, K050,  K051, and K052 Wastes            2-37
                 2.2.7 (3)  K104 Wastes                                  2-39
                 2.2.7 (4)  K071 Wastes    .                              2-39
                 2.2.7 (5)  K016 Wastes          .                        2-39
                 2.2.7 (6)  K019 Wastes                                  2-40
                 2.2.7. (7)  K030 Wastes      .    .                        2-40
                 2.2.7 (8)  K103 Wastes                                  2-40
         2.2.8   Second Third Wastes                                     2-40
                 2.2.8.(1)  Overview                                     2-41
                 2.2.8. (2)  All Second Third Wastes                      2-41
                 2.2.8.(3)  Second Third Wastes  for Which Formal
                            Treatment Standards Have Been
                            Promulgated               .                   2-41
                 2. 2. 8. (4)  Surface  Disposed Second Third
                            Promulgated Wastes    .            .          2-44
                 2.2.8.(5)  Underground Injected Second Third
                            Promulgated Wastes        .    .               2-46
                 2.2.8 (6)  First and Second Third Soft Hammer
                            Wastes                        .   •            2-48
         2.2.9   Determination of Available Capacity for the
                 Third Third Proposed Rule     	               2-50
                                       11

-------
                         TABLE  OF  CONTENTS  (continued)
Section
             2.2.9 (1)  Effects of Previous Land Disposal
                        Restrictions
             2.2.9 (2)  Impacts of Third Third Final  Rule
                        on California List HOCs
     2.2.10  Third Third Promulgated Wastes
             2 . 2 . 10 (1) Overview
             2.2.10.(2) Surface Disposed Third Third  Wastes
             2. 2. 10.(3) Underground Injected Wastes Included
                        in Third Third Rule
             2.2.10.(4) Soil and Debris
             2.2.10 (5) Mixed Radioactive Wastes

Waste Code Specific Capacity Analysis for Third Third
Promulgated Wastes              .  .

2 1  Characteristic Wastes    .              ...
     3.1.1   D001  Ignitable Wastes          	
     3.1.2   D002  Corrosive Wastes
     3.1.3   D003  Reactive Wastes              ...
     3.1.4   EP  Toxic Pesticides (D012-D017)

3 2  Metal Wastes          .....
     3.2.1   Arsenic  Wastes
             (D004, K031,  K084,  K101,  K102,  P010, P011,
             P012,  P036,  P038,  U136)
     3.2.2   Barium Wastes (D005,  P013)
     3.2.3   Cadmium  Wastes (D006)               .  .
     3.2.4   Chromium Wastes (D007 and U032)
     3.2.5   Lead  Wastes
             (D008, P110,  U144,  U145,  U146.  (K069,  K100)
     3.2.6   Mercury  Wastes
             (D009/K071,  K106,
     3.2.7   Selenium Wastes
             (D010, P103,  U204,
     3.2.8   Silver Wastes    .                     ...
             (D011, P099,  PI04)
     3.2.9   Thallium Wastes                  .   .  .
             (P113, P114,  P115.  U214,  U215,  U216, U217)
     3.2.10  Vanadium Wastes
             (P1L9 and P120)
3.3
                                    P065,  P092, U151)
                                    U205)
         Treatment Standards for Remaining F and K Wastes
         3.31    F002  and F005
         3.3.2    F006  and F019                    ......
         3.3.3    F024      .    .
         3.34    F025
         3.3.5    K001  and U051                        ,    .
         3.3.6    Waste from Pigment Production      ...
                 K002, K003, K004,  K005 ,  K006, K007 ,  and K008
         3.3.7    Acrylonitrile production wastes K011, K013 and K014
         33.8    Benzyl chloride distillation Wastes  K015  .   . .
                                                                          2-50
                                                                          2-51
                                                                          2-51
                                                                          2-53

                                                                          2-55
                                                                          2-59
                                                                          2-62
                                                                          3-1

                                                                          3-13
                                                                          3-13
                                                                          3-17
                                                                          3-20
                                                                          3-25

                                                                          3-34
                                                                          3-34
                                                                     3-42
                                                                     3-44
                                                                     3-47
                                                                     3-50

                                                                     3-58

                                                                     3-65

                                                                     3-68

                                                                     3-70

                                                                     3-74
                                                                      3-77
                                                                      3-77
                                                                      3-79
                                                                      3-85
                                                                      3-87
                                                                      3-88
                                                                      3-90

                                                                      3-97
                                                                      3-101
                                      111

-------
                         TABLE OF CONTENTS (continued)
Section
    3 4
         3.3.9
         3.3 10
         3.3.11
         1.3.12
         3.3.13
         5 3 14
         3.3.15
         3.3 16
         3.3.17

         3.3.18
         3.3 19

         3.3.20
K017
K021
K022
K028
K032
             and K073
              K025, K026, K035. K083
              K029, K095, and K096
              K033, K034, K041, K097, and K098
        Disulfoton Production Wastes  K036 and K037
        K042,  K085, and K0105
        K044,  K045, K046, K047   .      	
        K048,  K049. K050, K051, and K052 Petroleum
        Refining wastes
        Coking operations wastes  K060
        Electric furnace steel production
        Wastes  K061
        Ink Production Wastes  K086
                                    and
Treatment Standards for U and P Wastewaters
Nonwastewaters Excluding Metal Salts and
Organo-metallics         ...          .  .
3.4.1   Halogenated Aliphatics
        (U044, U074, U076,  U077,  U078,  U079,  U080,  U083
        U084,  U131, U184, U208,  U209,  U210, U211, U226,
        U227,  U228, U243)
3 4.2   Halogenated Pesticides and Chlorobenzenes
        (P004, P037, P050,  P051,  P059,  P060,  P123,
        U036,  U037, U038, U060,  U061,  U070, U071,
        U072,  U127, U128, U129.  U130,  U132, U142,
        U183,  U185, U207, U207,  U240,  U247)
3 4.3   Halogenated Phenolics        .    .        .  .
        (U039, U048, U081,  U082)
3 4.4   Brominated Organics
        (P017, U029, U030,  U066,  U067
3 4.5   Miscellaneous Halogenated Organics
        (P016, P023, P024,  P026,  P027,  P028,
        P058,  P095, P118, U006,  U017,
        U025,  U026, U027, U033,  U034,
        U043,  U045, U046, U047,  U049,
        U075,  U097, U121, U138,  U156,
        U222)
3.4.6   Aromatics and Other Hydrocarbons
        (U019, U055, U056,  U186,  U220,  U239)
3.4 7   Polynuclear Aromatic Hydrocarbons
        (U005, U016, U018,  U022,  U050,  U063,
        U064,  U094, U120, U137,  U157,  U165)
3.4.8   Phenolics
        (P020, P034, P047,  P048.  U052,  U101,  U170,
        U188,  U201)
                                                U068,  U225)
                                               U020
                                               U041
                                               U062,
                                               U158
                                     P057,
                                    U024.
                                    U042,
                                    U073,
                                    U192,
Page
 No.

3-102
3-105
3-107
3-111
3-112
3-115
3-116
3-120

3-121
3-129

3-130
3-131
                                                                         3-133
                                                                         3-133
                                                                         3-152
                                                        3-177

                                                        3-182

                                                        3-189
                                                                         3-218

                                                                         3-225


                                                                         3-232
                                      IV

-------
                         TABLE OF CONTENTS (continued)
Section
         349   Oxygenated Hydrocarbons and HeterocycLics                3-242
                 (P001,  P003,"P005, P088, P102, U001, U002,
                 U004,  U008, U031, U053, U057,  U085. U108,
                 U112,  U113, U117, U118, U122.  U123. U124,
                 U125,  U126, U140, U147, U154,  U159. U161,
                 U166,  U182, U197, U213, U248)
         3 4.10  Organo-Nitrogen Compounds                                3-275
                 (1) Nitrogen Heterocyclic  Compounds  (POOS,
                     P018,  P054,  P067,  U011, U148,  U179,
                     U180,  U191,  U196)
                 (2) Amine  and Amide  Compounds  (P046,  P064,
                     U007,  U012,  U092,  U110, U167,  U168,
                     U194,  U238)
                 (3) Aminated Diphenyls and Biphenyls  (U014,
                     U021,  U091,  U093,  U095, U236)
                 (4) Nitriles (P069,  P101,  U003, U009,  U149,
                     U152)
                 (5) Nitro  Compounds  (P077,  U105, U106, U169 ,
                     U171,  U181,  U234)
                 (6) Nitroso Compounds  (P082,  P084, Ulll,
                     U172,  U173,  U174,  U176, U177,  U178)
         3 4.11  Organo-Sulfur  Compounds  .        ...                 3-312
                 (P002,  P014,  P022, P045, P049, P066,  P070,
                 P072,  P093, P116, U114, U116,  U119, U153, U193,
                 U218,  U219. U244)
         3.4.12  Additional Organic Wastes--Pharmaceuticals              3-326
                 (P007,  P042,  P075, P108, U010, U015,  U035,
                 U059.  U089, U090, U141, U143,  U150, U155, U163,
                 U164,  U187, U200, U202, U203,  U206, U237)

    3 5  Potentially Reactive  P  and U Wastes          .                   3-334
         3.5.1   Incinerable Reactive Organics  and Hydrazine
                 Derivatives             . .  .                            3-334
                 (P009.  P068,  P081, P105, P112, U023,  U086, U096,  U098,
                 U099,  U103, U160, U109, U133)
         3.5  2   Incinerable -Inorganics  (P006,  P096, P122,
                 U135,  U189, U249)    ...    .       ....             3-342
         3.5.3   Fluorine  Compounds (P056,  U134)         .      .    .       3-346
         3.54   Recoverable Metallics (P015, P073,  P087)                 3-349

    3.6  Gases  ......                         .       3-353
         (P076,  P078, U115)

    3.7  U and P Cyanogens                                               3-355
         (P031,  P033, U246)

    3.8  Contaminated Soils                         .                     3-357
                                      v

-------
                                     K-78
      Sandoz, Baumont, TX
            on-site pesticides
            LI
            awaiting TB
12:30  -  Kvle Shelton not in
Transferred to Rex McDonald

1.     American Envirotech
            have responded to NODs
            could be permitted by 1st, 4th 1991
            two RK's proposed   130 MBtu each
            not willing to look up throughput limits
3/9/90  12:40  -  Kvle Shelton (512) 463-8278, not available

Transferred to Troy Wappler

1.    Stauffer, Houston, TX
            liquids only
            no recent changes in capacity

2.    Pennwalt, Baumont, TX
            changed name to Atochem North America
            on-site liquids only


3/9/90  3:10   -  Kvle Shelton (TWO returned call

1.    Rollins, Deer Park, TX
            first permitted late 1987
            no planned changes to capacity
            trying to amend permit for dioxins and furans

2.    Occidental Chemical, Engleside, TX
            proposed on-site facility
            company captive
            vinyl chloride liquid wastes only


3/12/90  1:40  -  Gail Artall. LA State Permit Office (504) 342-4685

            will call back with capacity data on Rollins, Baton Rouge


3/13/90  2:15  -  Gail Artall (504) 342-4685

            left message to call


3/14/90  10:30  -  Gail Artall. LA State

-------
                                     K-79

            transferred to Don Nugent

      Rollins, Baton Rouge
            will fax capacity data from permit


3/14/90  4:20  -  Dan Johanson. AR State. Permit Coordinator  (215) 655-6760

            left message

      Transferred to Lee Haves

            AR Permit Section (502) 562-7444

      Transferred to Stan Burger

      Transferred to Mark McKorkel. Permit Writer

1.    ENSCO, El Dorado,  AR
            call Cecil Harrell or Mike Bates at AR Permit Section //
            (502) 562-7444
            2 large RK's
            1 boiler
            1 transportable RK
            2 ABs
            2nd kiln permitted since 1986
            call on-site inspector, Mohammed Abdulhared (501) 863-7173
            more storage capacity than feed potential

      Transferred to Mike Porta

1.    Ash Grove Cement,  Foreman,  AR
            are currently burning s/s
            fully permitted by State (6/89)
            1 container/revolution (< 80 Ib/container) maximum
            kiln speed averages 1 RPM
            wet process  kiln
            has heard of another Ash Grove kiln in OR or WA
            no other kilns in AR burn s/s

2.    Ideal Cement,  Saratoga, AR
            in process of obtaining permit to burn hazardous liquids
            permit does  limit waste form


3/16/90  10:05  -  Mohammed Abdulhafed (501) 863-7173

            not available left message

-------
                                     K-80

3/16/90  10:05  -   Mohammed Abdulhafid (5011 863-7173

1.     ENSCO,  Bacon Rouge,  LA
            fully  RCRA/TSCA permitted (no dioxins/furans/explosives)
            2 RKs  with ABs (referred to as main unit with total thermal rating
            of 129 MBtu/hr)
            1 liquids only boiler
            1 fixed mobile RK, 42 MBtu/hr
            Permit only limits PCBs to 3700 Ib/hr
            Second RK of main unit was added only 1 year ago and is designed
            specifically for sludges and solids
            capable of burning low Btu/lb wastes
            first  RK in main unit is used primarily for PCB caps
            ENSCO  is definitely shifting toward relatively more sludges and
            solids
            heat release limits feed rate more than mass feed rates
            recently incorporated computerized continuous heat release
            monitoring system (replaces random hand sampling)
            hard to predict Btu/lb for RCRA codes
            will investigate actual throughput limits and call me back
3/16/90  3:40  -  Mohammad Abdulhafid returned call

1.    ENSCO
            F024 on permit
            capacities
            Practical estimates based on random selection of feed rate
            records:

            to mobile unit
                  3000 to 5000 Ib/hr sludges/solids

            to main unit (primarily #2 RK):
                  6000 to 16,000 or 17,000 Ib/hr

            according to waste analysis wastes
            blended to between 6000 and 10,500 Btu/lb
            optional feed blend is 8000 to 11,000 Btu/lb
            //I kiln is used for PCB's with some RCRA s/s on campaign basis
            Storage   not a problem for s/s
                      occasionally, liquids back up
                      ENSCO is permitted for additional storage than currently
                      exists
            wastewaters average 0 to 15 Btu/lb
            RCRA permit assumed average of 10,000 Btu/lb


3/19/90  Kyle Shelton. TWX (512) 463-8278

1.    Rollins, Deer Park, TX
            Doesn't know when individual units came on line, suggests calling
            Rusty Dunn at Rollins
            could call Shannon Disarbo at TX Air Control Board

-------
                                     K-81

4/2/90  4:30  -  Wayne Harry. TWC. returned call

1     Chemical Waste Management, Port Arthur,  TX
            received final RCRA permit 6/7/88
            call Tom Roth of UI Control Group  (512) 463-8240
            trial burn completed,  results expected in 1 to 2 months
            currently operating at slightly reduced capacity
                  maximum gas flow will be 219,000 ACFM
                  under Post-TB conditions 185,000 ACFM


4/3/90  2:00  -  Mike Porta. AR State RCRA (501) 562-7444

1.    Ash Grove Cement, Foreman, AR
            transferred to Mike Bates,  Section Chief
            Permit Writer is Mohsen Kourehdar  (501) 562-7444, ext. 267
            transferred to Mohsen Kourehdar
            Blender is Rineco Chemical Industries

2.    Rineco Chemical Industries
            no dioxins/furans accepted
            currently is recycler, submitted Part B about 2 years ago
            Ash Grove doesn't burn wastes below 6,000 Btu/lb, but can be 5,000
            Btu/lb before blending
            liquids decanted from drums into tank
            solids removed from drums by hand  or using a hydraulic hammer
            solids fed to shredder
            shredded solids packaged in buckets
            salesman take sample for Btu analysis before accepting
            Rineco contact:  John Whitney (501)  778-9089
            K048-K052 in Part A
            API sludge would make  a good fuel
            will look into K048-K052 Btu content and call back
4/4/90  11:00  -   Tom Roth.  TWC.  returned call

1.     Chemical Waste Management,  Port Arthur,  TX
            public hearings  held
            in final stages  of public comment
            call  Ronnie Crossland (EPA)  (214)  655-7160
4/4/90  11:10  -   Ronnie Crossland.  EPA (214)  655-7160

1.     Chemical Waste Management,  Port Arthur,  TX
            no migration variance approval proposed 2/16/90
            comment period closed Monday
            now responding to many comments
            final decision hoped for by May 8

-------
                                     K-82

4/20/90  4:20  Georze Hartman. (512) 463-8230

1.     Envirosafe,  Devers,  Texas
            Awaiting revised application
            Not constructed
            Proposed RK
            Lots of opposition
            1993+

4/24/90  5:15  Mohamid Abdulhafid. AR State Inspector for ENSCO
              (501) 863-7173
1.     ENSCO, El Dorado, AR
            U075 and U121 (freons) damage refractory
            Not prohibited by permit
            Can blend with other wastes to mitigate problem

-------
                                      K-83
          UNITED  STATES ENVIHOTMWTAi, FHOTtCTXOK AGENCY, IECXON VI
                           1445 Ross Ave. at Fountain Pltce

                              0alu$» TX
                   PACSIMIL REQUEST
        PLEASE REMOVE ALL STAPLES
                                                          SIMILE
                                                        CONFIRMATION

                                                        ""«"
                    •w.
                                                 - Of
o
                          ^ 6
»*n 6£KT
TIK£ SfNT
NUMSIK OFPAOtS TO MCLUDC W» C
s
ovmsxtFT
                                                       •**••*» *



                 MFOKMUT1ON POft ttNOINO MCSIMtU MUSAOSS
                                                                     .••«•»•«»••»«•«
FAKATAX KV3000
                                      FTS:   255-2142           FTS:   255-2140
                                      COW:  (214) 655-2142      COW:  (214) 655-214
                            PACE ^   or    SPACES

-------
                                    K-84
 PERMIT NO. HU-50089-001

 NAME:   Rollins Environmental Servic»s (TX)
                            CONTINUATION SHEET 51 OF 11
 Maxims
 ht»t input.
 MM BTU/hr

 Maximum
 waste  feedrates,
 Ibs/hr

 Minimum combus-
 tion gas exit
 teaperature ,  * P
 Maxlmua  combus -
 tion  gas teaperature
 upsec liait,  T

 Maximum  volu-
 n«cric flow
 rat«, acfa (v«c)

 Haximua  combus-
 tion  zone pressure

 rotationml sp««d,
Minimum combus-
tion gas 0~ concen-
tric ion. wt basis
Maxioua cocbus-
tion gas CO
concentration,
wet basis

Kaxivua coabus-
tion gas CO
concentration upset
lialt. wet basis
                                    TABLE 111-3

                               Incinerator Train II
                               Operating Parameters
 Kiln
 No. 2

   120
12,000
 1.500
  1,500



    N.A.



Atmospheric


     3


    N.A.
    N.A.
   N.A.
Rotary
Reactor No.  2

       33.5
    12,000
     1,200
                     1,200
                      N.A.
                Negative relative
                to  seal pressure
                      N.A.
                      N.A.
      N.A.
                                     Afterburner No. 2

                                              N.A.



                                              8,000



                                              1,800
                              1,800
                             60,000
                          Atmospheric
                                             N.A.
                              5.0%
                     
-------
                                       K-85
PERMIT NO. HV-50089-001

NAME:  Rollins Environmental Service*  (TX)
                    CONTINUATION SHEET 50 0? l;s
                                   TABLE III-2

                               Incinerator Train I
                              Operating Parameters
Maximum
heat input,
MM BTU/hr
Kiln
V9*J,
80
Rot*ry
Reactor No. 1
3$
Loddby
Liquid* Burner
100
Afterburner «1
N.A.
Maximun
waste feedrate,
Ibs/hr

Minimum combus-
tion gas exit
temperature, *F

Minimum
combustion gas
temperature upset
limit, *F

Maximum
volumetric flow
rate, acfm (wet)

Maximum
combustion
zone pressure

rotational speed,
                    13,200
                     1,400
                     1,400
12,000
 1,200
 1,200
5,230
 N.A.
 N.A.
                                                                        4,950
                                                                        1,600
                                                                        1,600
                      N.A.
 N.A
N.A.
                                                                      57,250
                  Atmospheric    Negative relative    Atmospheric    Atmospheric
                                 to seal pressure
                         3 (MX)
Minimus               N.A.
combustion gas 0.
concentration,
wet basis

Maximum               N.A.
combustion gas CO
concentration,
wet basis

Maximal               N.A.
combustion gas CO
concentration upset
limit, wet basis
                                  N.A.
                    N.A.
                    N.A.
                                  N.A.
                    N.A.
                   N.A.
                   5.0%
         (1-hr rolling avg)
                   3.0%
            (instantaneous)

                    100
                                  H.A.
                    N.A.
                    500

-------
                                       K-86
          LOUISIANA OCPAROENT OF  ENVIRONMENTAL  QUALITY
          OFFICE Of SOLID AND HAZARDOUS  WASTE
          HAZARDOUS MSTE MVIflON
          POST OFFICE ICX »307
          BATON ROUSE, LOjfKtANA   70804
                           TRANSMITTAL   SLIP
   ADDRESSEE:


   ADDRESS :
!!  PHONE:
I!  PAGES TO FOLLOW:  	
ii                           -
!!  DATE SENT:      3 —/V ~
                      FO* ASSISTANCE (504) 342- 	
                      >•••••••••»*••••••••>••••••••••••«••«•••••••«•••••••••••••••*••••
   b$/87

-------
                                       '  "                                      ou.
                                  K  87                           suvtcr TO
                (3).    However,   any  evidence  of  noncompllanee  with  these
                performance  standards   may  be  grounds   for  revocation,
                modlTTc'atton  or   reissuance  of  this  permit  pursuant  to  LAC
                33.-V.323.                                                   7/
                                                                     x^"~
                                                                    X
           (5)   The Permittee shall not incinerate wastes which are /radioactive,
                F020,  P021,  F022,  F023,  F026,   F027  (dioxin   listed   wastes),
                explosives (unless  rendered  safe  for burning through dilution, etc.
                and  approved  for burning by  the  administrative  'or   PCBs  in
                concentrations greater  than 30 ppm.  Wastes containing  PCB's in
                concentrations greater than 50 ppm  shall not be incinerated unless
                a TSCA permit has been obtained for the incinerator.

           (6)   Any  hazardous  waste,  or  blend  thereof,  which  can  not  be
                homogenized or destratified by agitation or recirculation  must  be
                direct  burned in the  incinerator  complex only under the  following
                conditionst

                (a)   Containerized liquids must be either directly educted Into the
                     afterburner or fed to the kiln after the addition of absorbent
                     material if  necessary because  of volatilization and/or  BTU
                     content.

  '              (b)   Bulk  liquids must be directly burned  through the Loddby
                     Auxiliary feed system  or through the kiln sludge line.

                (c)   The feed rate must be adjusted such that phase change would
                     not result in  upset of the  incinerator operating conditions.

                (d)   The waste analysis plan  shall  include  approved test methods
                     used, if other than those specified in SW-846,  for establishing
                     the  conditions  and  limits  for  characterization  as  to
                     homogenity,   fcapabllity   of stratifying  or  separating  into
                     phases under nonflow or static  conditions.

           (7)   The  Permittee  shall inspect and,  if  necessary,  analyze  each
                hazardous waste shipment received from off-site at the facility to
                determine whether it matches the identify of the  waste  specified
                on the  accompanying  manifest or shipping paper.

2.    Existing Rotary Kiln. LODDBY. Afterburner  Incinerator Complex

     a)    Operating Conditions

         (1)    All feed to  this incinerator, vents and any  auxiliary fuels shall be
                tested, measured,  and recorded as required by LAC 33:VJ529 and
                the Waste Analysis Plan, (Attachment 1).  •
                                    36


-------
            : 3 - ! 5 -' a 4 03:45
                             K-88               DRAfT
                                                SUBJECT TO REVISION
    (2)    The  maximum waste feed rate to the incinerator complex shall be
          as follows:

                                                     POUNDS PER HOUR

          la)    Waste D- Thermalox waste water             9,498
          (b)    Waste to the afterburner                      462
          (c)    Hazardous waste feed to be Loddby          21,732
                 and kiln and afterburner

    (3)    The  maximum  heat  release  for the  incinerator complex  (kiln,
          LODDBY, and afterburner) stall be 95,600,000 BTU/HR, including
          any vent gases and auxiliary fueL

    (4)    All waste  feeds shall  contain a  combined' total of no  more  than
          2619 Ib/hr of total chlorine.

    (5)    All waste feed shall contain a combined total of no more than 67.5
          Ib/hr bromine.

    (6)    All waste feeds  shall contain a combined- total of no more than 39,7
          Ib/hr of flourine.      ,                                       T

    (7)    All waste feeds shall contain a combined total of no more than 2$
          Ib/hr of iodine.

    (8)    The  atomized liquid  feeds shall contain no more  than 543 Ib/hr of
          astu

    (9)    The  viscosity of the hazardous waste  feed shall be maintained by
          preheat  and  steam/air  pressure to  insure proper  atomization
          through the burner nozzles.

          The  Permittee shall not incinerate any listed waste (Table l-LAC
          33tV. Chapters 31 or 49) in concentrations greater than 100  ppm
          with a  heat of  combustion  less than that of carbon tetrachloridc
          (.24  Koal/gr. or 432 BTU/lb).

   (11)    The  incinerator shall operate at steady state  within  permitted
          combustion temperatures and  air flow  prior to introduction of
          hazardous  waste.  No fuel except natural gas, commercial fuel oil
          or waste derived  fuels  specifically approved by  LDEQ for the
          Permittee  shall be used in the start-up  of  the incinerator.

b)    Process Conditions

    (1)    The  minimum  temperature of  the  combustion gases exiting the
          afterburner shall be 1013°C U856«F).  All hazardous waste feed*
          shall be cut-off immediately if  this temperature  falls  below tht
          valve.  The minimum temperature of the combustion gases exiting
          the  rotary  kiln  shall be 8S6OC  i627Of.  when burning hazardous
          waste  or  prior to  the introduction of  hazardous  waste, all

                              37

-------
         32 ".4. ".990 08 '•
                                        K-89
          UN2T£D STATES  ENVJKOKHBCTAL  MOTtCTlON AC»CY,  KfiGIOW VI
                           1445 Ross Avt.  tt Fountain Place
                               DillftS, TX   752C1-2733
                           ILE REQUEST AND COVER
                             PLEASE REMOVE ALL STAPLES
                                                        CONFIRMATION
                                                        NUMBER
             S C-6. 7-g 3~
OMI SEKT
                VI Or MOCS TO MCUIDC IMS COV1H SMf IT
                  INFORMATION WR ttUWNQ PAC8IMIU MtSSAOIS
 PAKATAX KV3000
                                       FTS:   255-2142           FTS:   255-2140
                                       CCW:  (214) 655-2142      COW:  (214) 655-2140
PACE      OF
                                               FACES

-------
K-90

-------
                                      K-91
POWIT HO. HV-50128-000

NAME:  BASF Corporation

[H.A.2.]

               Waste Description
              CONTINUATION SHETT 3 of 42
     TWC Vaste Class
                                                             Hazard
               j. Hexanediol (HDO) Lights       IH                I
               k. Butyl Acrylate (BA) Residue   I
               1. Ethylhexyl Acrylate (2-ZHA)
                    Residue                     1
               a. Hexamdiol (HDO) Heavies      I

     B.   Facility Unite end Functions Authorized:

          The permittee is authorized to operate the following facility units
          for storage and processing subject to the limitations contained
          herein.  No land disposal is authorized by this permit.  Processing is
          limited to combustion of wastes for energy recovery and/or disposal.
          All waste management activities are to be confined to authorized
          facility units.  References hereinafter in this perait to "TVC Perait
          Unit No. II.B.	.• shall be to the facility units listed belerw:

          1.   Incinerator with waste heat boiler (IN701), identified in the
               Notice of Registration (NOR) as Facility No. 19, for processing
               of wastes described by Provisior. II.A.Z.a. and II.^A^2^e. -*..
               atxiaua heat release rate 100 Billion BTUs per hour - peraic
               application subaittal dated June 3. 1985;

          2.   Incinerator (Caustic Vashwater Incinerator), identified in the
               NOR as Facility No. 20, for processing of wastes described by
               Provisions II.A.2.b..f.. and h.. aaxiaua heat release rate 24
               Billion BTUs per hour • perait application subaittal dated June
               3. 1983;

          3.   Tank (D7841), closed, maxiaua capacity 13,000 gallons,  carbon
               steel, above-grade, identified c.s tank D999 in che application
               for storage of the waste authorized in Provision H.A.2.b.. y.
               apd h, • permit application subnittal dated June 3, 1985; and

          4.   Incinerator with waste heat boiler (IN4702), identified in the
               NOR as Facility No. 4, for processing of wastes described by
               Prevlgiem* II.A.2.a., d. and II,, A..2. t.-a.. aaxiaua heat release
               rate 30 million BTUs per hour - perait aaendaent subaittal dated
               May 13, 1985.  The processing of waste described by Provision
               I^.A.^.d.. Acrylic Acid Residue, is subject to the requirements
               of Provision DC.F.I.  The processing of waste described by
               Prevision IT.A.2.1.. 2-Ethylhexyl Acrylate Residue, is subject to
               the requirements of Prevision* III.F.2. and 3.

     C.   Authorization to operate this facility is contingent upon maintenance
          of financial assurance pursuant to Provision IV.A.Land financial
          liability requirements pursuant to Provision III.A.8.  Authorization
          to begin operation of new facility components is contingent upon
u
                                               /n

-------
                     L   s^Gf >

                                       K-92


PBWIT HO. HW-50128-000                           COBTINUATIOR SHKT  2  of 42

NAME:  BASF Corporation

I.    St»e and Lo/filEiflfl o^ Site

     A.   The industrial solid waste management facility is located on  a  401-
          acr* tract of land in Brazoria County.  The site is in the  drainage
          area of Segment 1201 of the Brazos River Basin, North Latitude
          29*00'00". West Longitude 95*24'00".

     B.   The legal description of the site submitted in the application  for
          Permit No. HW-50128 is hereby mad* a part of this permit as "Attach-
          ment A.*

II.   Facilities find Operations Authorized

     A.   Wastes Authorized:

          The permittee is authorized to manage the hazardous and non-hazardous
          industrial solid wastes listed in the Part B permit application dated
          June 3, 1985 and revisions dated July 17, 1985, and November  19. 1985,
          hereinafter referred to as the permit application submittals, and the
          Part B permit amendment application submittal dated Kay 15, 1985 and
          amendment revisions dated August 7, 1985, Hay 17, 1988, and January
          28, 1989, hereinafter referred to as the permit amendment submittals,
          described herein, subject to the limitations provided herein.

          Wastes authorized for storage and processing are limited to those
          generated on-site at this facility.  Hazardous wastes authorized to be
          managed under this permit are limited as follows:

          1.   The hazardous wastes must be in the Hazard Code Groups (as
               prescribed by U.S. Environmental Protection Agency regulations in
               effect upon date of permit approval) indicated below:

                     Ignitable (I)          	 Acute Hazardous Waste (H)
                     Toxic 
-------
                      V
                                        K-93


PERMIT 90. HW.50128-000                           COWTIWJATIOR  SHEET  8  of  42

NAME:  BASF Corporation

IIII.C.J

          2.   Maintenance and operation of the Caustic tfashwater  Incinerator  as
               specified in Provisions ITT .1.1. -5. will be regarded as
               compliance with the parforaance  standards of Title  40  CFR Part
               264.343.a.-d.

          3.   The permittee shall maintain and operate IMA702  so  that, when
               operated in accordance vith Provision* IT.C.I.-10.  and Pravisions
               IX..D.1. -10.. and saapled according to the requirements of
               Provisions IX.F. ^-4^. the unit vill meet the performance
               standards specified in Provisions IX.B.I.-4.

     0.   Incinerator  IN701 Operating Requirements:

          1.   The permittee shall feed wastes  described by Provision*  II.A.2.a.
               and ft.  co the IN701 incinerator  only under the following
               conditions:

               a.   The temperature of the combustion gas between  the furnace
                    and the boiler entrance shall be maintained at a  minimum
                    160S*F at all times and shall be monitored  and recorded
                    continuously.  When any two of the three sensors  in the
                    combustion chamber detect minimum temperature  specified
                    above, the shut-off valve must automatically activate,
                    thereby closing off the waste feed lines.   If  any two  of the
                    three sensors read more than 140*F apart, they must be
                    immediately checked to determine which is in error.

               b.   The maximum volumetric flowrate shall not exceed  208,800
                    actual cubic feet per minute (acfm).  Volumetric  flowrate
                    shall be monitored and recorded continuously,  except as
                    specified in Provision III.0.4.

               c.   Combustion gas concentration of carbon monoxide (CO)
                    measured in the outlet of the waste heat boiler shall  not
                    exceed 100 ppm, dry basis at any time.  The CO concentration
                    shall be monitored and recorded continuously.

               d.   The waste feed rates to the incinerator are independent of
                    one another and may not exceed the following values:

                                                       Feed Rate
                                   fted                 flbs/hrJ

                              Acrylic Acid Water        13,590
                              Off-Gas                   89,226
                              Acrylic Acid Residue         600
                              Vacuum Vent/Off-Gas         8,370
                              Witrogen Vent/Off-Gas        900
                                             -C-

-------
       03-1-:  1990 2£:~-2
                      v
                                      K-94


PERMIT NO. HW-50128-000                           COWTUIUATIOW SHEET 9 of  42

NAME:  BASF Corporation

(II1.0.1.J

               •.   The permittee shall control fugitive emission* by
                    maintaining • totally sealed combustion zone.  Pressure in
                    the combustion zone may not exceed 16.1 psia for more  thin
                    ten consecutive second*.  Pressure in the combustion zone
                    oust be monitored and recorded on a continuous basis.

               f.   The total feed rate, including the hazardous and
                    non-hazardous waste feed rate, preheated air, and auxiliary
                    fuel to the incinerator is limited to a maximum of 100
                    aillion BTU/hr heat input.

               g.   During start-up and shutdown of the furnace, those wastes
                    described by Provision II.A.2.a.  and d.  vust not be
                    introduced into the furnace unless the furnace is operating
                    within the conditions specified in Provision III.D.I.a.
                    through iii-D-i.f.

               h.   Ash content of the waste feed shall not exceed 100 ppm by
                    weight.

               i.   The viscosity of the waste feed residue  described in
                    Provision II.A.2.d. shall not exceed 350 Standard Saybolt
                    Units (SSU).

          2.    The permittee shall maintain and operate a waste feed cut-off
               system for the IN701 Incinerator.  This system must automatically
               cut off those wastes described by Provisions  II.A.2.a. and d.
               under any of the following conditions:

               a.   When the operating conditions deviate from those specified
                    in Provision III.D.I.a.-e.: or

               b.   Upon:

                    (1)  Loss of primary combustion air;

                    (2)  Power outage;

                    (3)  Shutdown of the primary mover;

                    (4)  Loss of any atomizing medium for hazardous waste
                         burners; or

                    (3)  Loss of flame at the burner.

-------
                                       K-95

PERMIT NO. HW.50128-000                           COKTIJIUATIOK  SHUT  11  of 42

MAKE:  BASF Corporation

[III.D.J

          11.  The permittee shall kacp a written operating racord aa described
               in 40 CF8. Part 264.73.  In addition to the specific requirements
               of this paragraph, tha  p«raictaa ahall al»o racord:

               a.   All occasions whan tha operating parameters specified  in
                    Proviaion III.P.I, are exceeded and/or the automatic waste
                    feed cut-off is activated; and

               b.   All occasions when waste feed is cut off pursuant to Pro-
                    vision III.D.2. or III.D.3.

               At a minimum, the permittee shall record:

                    (1)  The date and  time of the incident; and

                    (2)  The reason for waste feed cut-off and, if applicable,
                         tha  concentrations triggering cut-off.

          12.  The pemittee shall perform tha following:

               a.   The incinerator and associated equipment (pumps, valves,
                    conveyors, pipes,  etc.) oust be subjected to thorough visual
                    inspection, at least daily, for leaka, spills, fugitive
                    emissions, and signs of tampering; and

               b.   The emergency waste feed cut-off system and associated
                    alarms must be tested at least weekly to verify operability.

          13.  Only natural gas may be used as an auxiliary fuel.

     E.   Caustic tfashvater Incinerator Operational Requirements:

          1.   The Caustic Washwatar Incinerator described in Provision II.B.2.
               is exempt from all requirements of 40 Coda of Federal Regulations
               (CFR) 264 Subpart 0 with the exceptions of 40 CFR 264.341 (waste
               analysis) and 40 CFR 264.351 (closure), pursuant to 40 CFR
               264.340
-------
                                      K-96


PERMIT HO. HV-30128-000                           CORTIHUATION SHIFT 32 of 41

HAKE:  BASF Corporation

[IX.B.J

          3.   The unit shall not emit particulate matter in excess of 0.08
               grain per dry standard cubic foot when corrected for the amount
               of oxygen in the etack (a* in accordance vith the formula
               specified in 40 CFR Part 264.343 (c).

          4.   Compliance vith the operating conditions specified in Provision
               IX.C.I.-10.  of this permit will be regarded as compliance vith
               the above performance standards.  However,  any evidence that
               compliance with the operating conditions or other permit
               conditions is insufficient to ensure compliance vith the above
               performance standards may be "information"  Justifying
               modification, revocation, or reissuance of  the permit pursuant to
               40 CFR Part 270.41.

     C.   Incinerator IN4702 Area Operating Conditions:

          The permittee shall cease operation when changes in waste feed,
          incinerator design, or operating conditions exceed limits designated
          in this permit.  The permittee shall feed hazardous wastes to the
          incinerator unit only under the following conditions:

          1.   The incinerator is not in start-up or  shut-down mode.

          2.   Incinerator operating instructions shall be posted so as to be
               iroediately available to incinerator operators.

          3.   The temperature of the combustion gas  measured in the furnace
               shall be maintained at a minimus of the following temperatures:

               	Waste Teed           Hourly average      Instantaneous

               Feeds including               1005'C              950'C
               Acrylic acid residue

               Feeds excluding               958*C               936'C
               Acrylic acid residue

          4.   The maximum volumetric flow rate through the system shall not
               exceed 38.844 actual cubic feet per minute  at 529 *F and 16.5
               psia as measured at the exhaust duct after  the economizer and
               before the entrance of the stack.

          5.   The combustion gas concentration of carbon  monoxide (CO) measured
               in the exhaust duct after the economizer and before the gas
               stream enters the exhaust gas stack shall not exceed 100 ppm(v),
               for acre than 6 minutes in any 60-minute period,  and shall not
               exceed 500 ppm(v) for any instantaneous value.
                                                  /O

-------
                                       K-97
PERMIT NO. HV-30128-OOO

HAKE:  BASF Corporation

[IX.D.4.)
COFTIHUATIOW SHZBT 35 of 41
                         1.6 Hexanediol Light*
                         1,6 Hexanadiol Heavies
                         Butyl Acrylate Ether
                         Acrylic Acid Residue
                         Butyl Acrylate Residue
                         2-Ethylhexyl Acrylate Residue
                         Acid Water
          400 Ib/hr
          400 Ib/hr
          123 Ib/hr
          935 Ib/hr
         1339 Ib/hr
         1307 Ib/hr
       11,080 Ib/hr
          5.   The feed rat* of «ny combination of two or more individual waste
               streams listed in Provision D.4. fed to the incinerator shall not
               exceed 10,772 pounds per hour at any time.

          6.   The total feed rate of Butyl Acrylate Residue and 2-Ethylhexyl
               Aerylate Residue when combined is no greater than 1955 lb*/hr.

          7.   The feed rate of 1,6 Hexanediol Lights and 1,6 Hexanediol Heavies
               when combined shall not exceed 400 Ibs/hr.

          8.   The feed rate of POHC to the incinerator shall not exceed 519.1
               pound* per hour.

          9.   The total ash content of wastes fed to the incinerator shall not
               exceed 44.2 pounds per hour.

          10.  The combined heat of combustion and heat content of all streams
               fed to the incinerator system shall not exceed 676 million BTU
               per hour for any 5 second period.

          11.  Auxiliary fuel shall be either sveet natural gas containing not
               more than 1.5 grains of hydrogen sulfide per 100 cubic feet and
               not more than 30 grains of total sulfur per 100 cubic feet,
               liquified petroltua gas, diesel oil, or No. 2 fuel oil.  All
               diesel oil or Re. 2 fuel oil shall be first run refinery grade
               and shall not consist of a blend containing waste oils or
               solvents.  Us* of any other auxiliary fuel will require prior
               approval of the Executive Director of the Texas Air Control
               Board. The permittee shall determine the lover heating value and
               total sulfur content of any auxiliary fuel used in the
               incinerator.

     E.    Other Incinerator Area Monitoring, Testing and Inspection Requirement*
          for IH4702:

          1.   Combustion temperature, total vsste feed rate, total stack
               volumetric flow (combustion gas velocity), oxygen concentration,
               and carbon monoxide concentration shall be monitored and recorded
               on a continuous basis.
                                                 /o

-------
      -:~ i-i. 1?9C D6:5-1

                                      K-98


PEWIT HO. HW-50128-000                           COHTIWJAnCW SHUT  34  of 41

NAME:  BASF Corporation

[XX.C.10.]

               g.    High CO concentration in the stack gas of greater than 100
                    ppm (v) for more than 6 minutes in any $0-sdnute  period,  or
                    an instantaneous reading of 500 ppm (v).

               h.    High fuel gas pressure after regulator greater  than  30 psig

               i.    Forced draft fan failure.

               j.    Loss of name.

               k.    Loss of draft in the combustion chamber producing a
                    reading of greater or equal to zero inches of water  for 1
                    minute.

               1.    Instrument air failure.

               m.    Flow meter failure.

               n.    Pow«r outage.

     D.   Limitations on Wastes Incinerated in IK4702:

          1.   The total organically bound chloride content of the  total waste
               feed shall not exceed 5283 ppa(v).

          2.   The hazardous waste feeds to the incinerator shall not contain
               greater than 100 ppa of organic hazardous constituents listed  in
               40 CFR Part 261, Appendix vm, having an individual heat of
               combustion less than 8053 BTU/lb (formaldehyde).

          3.   The total average heat value of the waste material and natural
               gas fired in the incinerator shall not be less than  the
               following:

                                                  BTU/lb of waste material
                              Waste Feed             fad to Incinerator

                         Acid water only                4,800 BTU/lb

                         Feeds including               37.000 BTU/lb
                         acrylic acid residue

                         Feeds excluding               53,300 BTU/lb
                         acrylic acid residue

          4.   The feed rate of the individual vaste streams to  the incinerator
               shall net exceed the following at any time:

-------
                                     K-99

REGION VII


3/5/90  5:10  -  Joe Galbraith (913) 551 7051, left message


3/6/90  4:30  -  Joe Galbraith

1.    Aptus, Coffeville, KS
            application under review
            at least 1 year from operating permit
            at least 1 1/2 years from operating
            was PCB
            62 MBtu/hr RK
            capacity in application (TB plan)
                   10,000 Ib/hr sludge/solids max
            hopes  to burn dioxins and furans

2.    Industrial Service, Corp., Kansas City, MO
            big question
            application under review
            many deficiencies
            much public opposition
            could  at best be operational in  two years
            RK   40 MBtu/hr
            primarily LI
            no dioxins/furans
            no more than 2000 Ib/hr S/S

 3     Safe-Tech, Chamois, MO
            very doubtful
            weak application submitted
            state  opposes
            proposal  is to convert municipal RK combuster  for hazardous waste
            at least  two years away

 4     Waste-Tech,  Kimball, NE
            fluidized bed
            <  5000 Ib/hr  - s/solids not  likely
            have "good  faith" state permit
            plan to construct this year
            at least  1  year  from operation

 :     Ash Grove Cement, Chanute, KS
                        Louisville, NE
            12 cement kilns  in  region
            not approved  for hazardous waste
            hasn't been demonstrated  as  "recycling"
            contact considers use  of  cement  in  roads/bridges  to  be  land
            disposal
            must meet PArt  268  standards
             liquids > 5000  Btu/lb  OK  (enforcement policy 1983)
             solids not  addressed  in  enforcement  policy of 1983
             some  may  be burning  solids,  will come down to enforcement decision
             s/s  must  at least be > 5000  Btu/lb,  but  that may not be enough

-------
                                    K-100

            HQ has not addressed cement kiln policy.  (Attended meeting in
            December)
            If sprayed like liquids -  OK
            "cold end" entry not demonstrated
            State officials have witnessed Ash Grove's system and given
            tentative  approval (6 Ib charges to middle of kiln)
            will change with Boiler/Furnace Regulations

6.     National Industrial Env. Services,  KS
            no application submitted

7     Other Cement Kilns in Region VII

            Systech/Lafarge
            Monach Cement
            River Cement, Restus,  MO
            Continental Cement (claims to be able to  burn 280 tons/day)
            Dundee Cement

8.     Atlas Environmental Services
            preliminary design stage
            RK for D003 explosives
    *       Region will not allow open detonation
            commercial for explosives  - possibly from around country
            capacity unknown
            could be on-line in 1992
3/9/90  1:00  -   Joe Galbraith (913)  551-7051

            left message to call
            out  today
3/12/90  -   Joe Galbraith (Resion VII)  returned call

1.     Aptus,  Coffeeville,  KS
            10,000 Ib/hr is permitted sludge/solid maximum
            5000-6000 Ib/hr is  more realistic

2.     Safetech, Chamois, MO
            withdrew permit application on Friday

3     Ash Grove Cement,  KS
            John Ramsey  (913)  296-1610  of KS State Office  is  familiar

-------
                                    K-101

3/14/90  John Ramsey.  KS State (913) 296-1610

1.     Ash Grove Cement
            met yesterday
            connected with Cadence,  Michigan City, IWD,  who markets fuel to
            Ash Grove (12 blenders)
            currently IS storage
            have recently added many codes to application, arguing that
            derived from rule results  in excessive coding of fuels
            have submitted WAP

      On Ash Grove/Cadence Process:
            6 gal drums fed half way along 300 ft wet-process kiln
            induction draft prohibits  leakage from seal
            last summer (1989) process operating at 1 of 2 kilns
            rotation and drop rate is  less than 3 or 4 RPM
            has demonstrated fuel value (stopped dropping, had to increase
            primary fuel)
            wet kilns better than dry  (longer)
            Both KS kilns are wet process
            believes NE kiln is wet process also

      KS has 4 other cement kilns

2.     Heartland Cement, Independence,  KS
            recently permitted
            under construction
            dry process kiln
            will inject powderized solids

3.     Lefarge, Ferdonia, KS
            Systech operates waste system
            currently grind and slurry solids for injection
            Also have pyrolizor:
                  holds 12 drums
                  drums heated, vapors ducted to kiln
                  residues may be burned
                  permitted for nonhazardous solid waste, trying for hazardous
                  waste permit

4.     Monarch Cement,  Bonner Springs,  KS

            wants to burn powderized K061

5     Lone Star Cement Co., Edwardsville, KS

            not burning hazardous wastes
            no notification of plans to burn hazardous fuels

-------
                                     K-102
REGION VIII
3/6/90  4:10
           Nina Churchman (303) 293-1500
      Aptus, Tooele UT (Westinghouse)
            permit under public notice
            should go final in April
            sure thing
            construction begun
            expected on-line 2nd 4th 1991
            fully commercial
            plans  to burn dioxins/furans and PCBs
            capacity:  RK   120 MBtu/hr
                            51, 000 tons/yr max
            from TB Plan
                  solids (0-9000 Btu/lb)
                  sludge (0-9000 Btu/lb)
                  liquid (12,700 Btu/lb)
                  aqueous (0-400 Btu/lb)
                                          16,000 Ib/hr
                                           4,000 Ib/hr
                                          10,178 Ib/hr
                                           3,000 Ib/hr
6.
USPCI, Tooele, UT
      county already burns nerve gas from military base
      in NOD cycle phase
      plans To burn dioxins/furans/PCBs
      from applications (TB plan) (5 specified)

      aqueous wastes    (0-6.25 MMBtu)     13,000-27,000 Ib/hr
      pumpable sludges  (0-2.4 MMBtu)     0-4000 Ib/hr
      solids            (0-2.4 MMBtu)     0-4000 Ib/hr
      <75,000 TPY solids,  < 55,000 TPY sludge/solids

CoWest/CISCO, UT
      not sited
      very doubtful
      no application submitted

Rollins, Lynndyl, UT
      site abandoned
      application on hold
      not active
      not likely before 1993

Combustion Technology
      no application submitted
      not before end of 1992

Aptus, Salt Lake City, UT
      no info, probably not real

-------
                               K-103
BFI/CECOS, Last Chance, CO
      just talk
      not by 1992

ENSCO,  Grouse Creek,  UT
-canceled project

-------
                                     K-104

REGION IX  - (General (415) 556-6322)


3/5/90  ":05 pm  -   Larry Bowerman (415) 744-1471

1.     Omega Chemical Corp.,  Whittier, CA
            no application
            dead project

2.     ENSCO, Phoenix,  AZ
            new commercial site
            Part B  submitted
            state expects to permit within 1 to 6 months
            facility will consist of 3 mobile units
            Total:   (Exists    TSCA permit)
                  100 MBTu/hr
                  50,000 TPY  Max (L+S+S)
            could be available 1991

3     CA Thermal Treatment,  Vernon,  CA
            proposed greenfield site
            permitted 1988
            under appeal
            RK  42  MBTU/hr
            22,500  TPY  Max
            liquids only + pumpable sludges only
            not constructed
            1991 at earliest

4.     CWM, Kettleman Hills,  CA
            proposed greenfield RK
            50 MBtu/hr
            33,000  TPY  Max  (application)
            some application deficiencies
            could be permitted 1990
            could be on-line 1992 at earliest

5     Disposal Control,  Caselton, NV
            no application submitted
            very preliminary

6     Environmental Technologies, Las Vegas, NV
            never heard of

7     Omega Recylcing,  Mendota, CA
            no application
            not sited

8.     Stauffer Chemical (now Rhone -Poulenc), Martinez, CA
            submitted application
            some deficiencies
            under review
            possibly permit  proposal by end of 1990
            upgrade of sulfuric acid regeneration omit
            250 MBtu/hr

-------
                                     K-105

            210,000 tons/r (rated)
            will limit to 140,000 TPY (tentative agreement)
            liquids only

9     ENSCO, Mobile/Phoenix (Marcicopa) ,  AZ
            same as 2

10    AM Waste
            never heard of

11.    National Cement, Lebeck, CA
            cement kiln
            not currentLy RCRA
            will burn liquids only
            50 MBtu/hr
            51,000 TPY

12.    American Environmental Management,  Rancho Cordova,  CA
            no application
            no info
            PCB only

13.    Basil, NV
            never heard of

14    Burnzall, NV
            never heard of

15.    IT - Vinehill (In Martinez)
            closed

16    Koppleman, NV
            never heard of
    *       NV doesn't want a hazardous  waste incinerator

17    Poly-Garb Inc , NV
            never heard of

18.    Sol Pro, Lillyblad, NV
            dead or dormant

19.    United Agro.  NV
            never heard of

20.    ET Tech   ' NV
            never heard of

21.    WFU Equipment, NV
            never heard of

-------
                                    K-106

22.    Wolfskill,  CA
            dead or dormant project
            nothing heard in 4-5 years

23.    Shell Oil,  Martinez,  CA
            on-site only
            liquids + sludges
            4 units:
            one RM17  (liquids)  unit
                  short-term 10-30 tons/month
                             35-140 ton/yr

            three carbon monoxide boilers
            each:
                        liquids,  some  sludges (e.g.
                        10  gal/min maximum

24    Chevron,  Richmond,  CA
            pesticide incinerator
            on-site only
            liquids only
            100 TPY
                                    DAF float)
3/6/90  5:40
Larry Bowerman,  left message
3/7/90  5:45
Larry Bowerman
            will ask Nahid Zoueshtiagh to get back to me next week when she
            returns regarding CWM,  Kettleman Hills,  CA
            (23)  shell oil RM17's  burn liquids only
            (9)   will ask Jim Burkamp to check into ENSCO,  Phoenix, AZ
                  capacity breakout
            (3)   CA Thermal Treatment
                        Russ Beckman wrote permit
                        liquids only  RK
3/12/90  1:25
 Nahid Zoveshtiagh (Region IX permit writer) (415) 744-1471
            spoke to Larry Bowerman
            he will have permit writers for CWM,  Kettleman Hills, and ENSCO,
            Phoenix,  find capacities and get back to me

-------
                                     K-107

4/26/90  1:45  Larrv Bowerman, Region IX

1     Omega Energy, Maricopa, CA
            Is a fuel burner  (CAD981577661)

2     Chem Waste Management,  Kettleman Hills, CA
            Proposed expansion to existing facility
            RiC

3     Sol Pro LillyBlad, NV
            No application received
            May not be  dead project

-------
                                     K-108

REGION X


3/2/90  5:40  -   Cathv Massimino (206) 442-4153

            on travel for 2 weeks
            Carrie Sikoiski,  Chief,  will call back


3/5/90  7:35 pm  -  Margaret Small (206) 442-2804

1.     ENSCO, AK
            never heard of

2.     Environmental Security Corp.,  Grant County, WA
            commercial
            much opposition
            application submitted,  responding to NODs
            will burn sludge/solids

3     Environmental Control,  WA
            no information

4     Colman Metals,  OR
            PCBs only

5.     Penberthy Electromelt
            no application submitted
            small subpart X thermal  treatment facility
            accepts organic wastes
            currently operating
            capacity unknown

6.     Rackelshaus (Now ECOS)
            application submitted
            call state office (206)  459-6316),  Tom Eaton
            will resubmit this summer
            2-4 years away
            34,000 TPY  RK (from Environmental  Impact Statement)
            call Tim Norred (438-7019

7     Special Resource,  WA
            never heard of

8.     Rabanco, WA
            34,000 TPY
            make cement blocks
            1992 at earliest


3/7 -'90  -   Tom Easton (WA State) (206) 459-6316, left message

-------
                                    K-109

EPA HEADQUARTERS

3/19/90  11:30  -   Dwight Hluscick returned call

      (working on Industrial Boiler and Furnace rules)

            proposed reg shouldn't adversely affect Ash Grove
            no insurmountable applicability problems for other kilns
            for dry process kilns
                  demonstrated for pre-calculator dry process kiln
                  possible for pre-heater dry process kilns
                  possible for dry process only kilns
            other kilns trying Ash Grove Process
                  maybe South Bend (name uncertain)
                  Southeastern Portland
            Ash Grove contact is Eric Hansen
            kilns rotate at around 2 RPMs
            kilns don't generally shut down for periodic maintenance because
            of startup problems
            more common for 1 long down time if market slumps
            some kilns fire directly from trucks
            requirements for storage permit is usually > 10 days but vary's by
            state
            rule will limit stack emissions, not Btu/lb
            kilns will require permit which limits conditions based on volumes
            of product/fuel feed

-------
                                     K-110

                        COMBUSTION CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS  TO SUPPORT LDRs

                                   PHONE LOG
Caller:  Gary Light
Name of Contact:  Dana Doerfler,  CWM

Phone Number    :  (618) 271-2804

Title           :

Location        :  Sauget,  IL

Date            :  4/4/90

Purpose of Call:  Determine sludge/solid incineration capacity of CWM's
                  Sauget,  IL facility
Report on Discussion:
            Three units can each burn about 500 Ib/hr sludges and solids.
            Fourth unit,  a RK, can burn about 2000 Ib/hr of high Btu wastes
            sludges and solids and 10,000-15,000 Ib/hr of low Btu wastes (like
            soil).  Usually burn 10,000 Ib/hr on average.
            Facility operates 24 hours per day, 7 days a week.
Any Followup Planned:   None.

-------
                                     K-lll

                        COMBUSTION CAPACITY FOLLOWUP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs

                                   PHONE LOG
Caller:   Gary Light
Name of Contact:  Steve Enger, CWM

Phone Number    :  (312) 646-5700

Title           :  Technical Manager

Location        :  Chicago, IL

Date            :  4/4/90

Purpose of Call:  Determine sludge/solid capacity of CWM's Chicago,  IL
                  incinerator

Report on Discussion:

            Btu is limiting factor, permit allows up to 30 million Btu/hr,
            which can all be non-liquids, fed at no more than 3 million Btu
            per charge
            At  20,000 Btu/lb, max feed is 1500 Ib/hr.
            Most sludges and solids average 6000-7000 Btu/lb.
            Soils can be fed at even higher rate.
            Entire capacity could be used for RCRA sludges and solids.

Any Followup Planned:  None

-------
                                     K-112

                        COMBUSTION CAPACITY FOLLOWUP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs

                                   PHONE LOG
Caller:  Gary Light
Name of Contact:  Rusty Dunn, Rollins Environmental Services

Phone Number    :  (703) 930-2420

Title           :  Environmental Manager

Location        :  Deer Park, TX

Date            ;  4/15/90

Purpose of Call:  Clarify sludge/solid incineration capacity and grinding
                  capacity prior to stabilization.

Report on Discussion:

            Second Rotary Reactor won't be available for 2 more years.  It  is
            not constructed.
            Rotary kilns typically burn 50 to 70X sludges and solids,
            operating at permit limits.
            Can burn as much as 100X sludge/solids for some low Btu wastes.
            Permit did not reduce capacity, no reason why TSDR maximum
            capacity estimates would have changed.
            Currently designing a new stabilization facility that will include
            grinding.  Could be available in 6 months.

Any Follovup Planned:  None.

-------
                                     K-113

                        COMBUSTION CAPACITY FOLLOWUP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs

                                   PHONE LOG
Caller:  Gary Light
Name of Contact:  Bill Ziegler, American Nukem  (ThermalKEM)

Phone Number    :  (803) 329-9690

Title           :

Location        :  Rock Hill, SC

Date            :  4/23/90

Purpose of Call:  Clarify comment on EPA underestimating ThermalKEM's capacity
                  by a factor of 10.

Report on Discussion:

            TSDR was submitted prior to trial burn which raised maximum heat
            release from 19 to 42 mbtu/hr.
            Facility can burn 80-85X solids in  its modified fixed hearth unit.
            No mass feed rate limits in permit, only thermal rating.
            Normally burn sludge/solid/liquid blends ranging from 5000 to 8000
            Btu/lb.
            Operate 24 hours, 365 days, at 85X.
            Have modified kiln to increase solids capacity:
                  Added oxygen enrichment system.
                  Added ram feed system.
                  Now transfer wastes from steel drums to fiber packs.
                  Have added new APC equipment.
            Changes allowed increase in permitted ash content.

Any Followup Planned:  None.

-------
                                    K-114

                      FUEL BLENDING CAPACITY FOLLOWUP ON
                       PUBLIC COMMENTS TO SUPPORT LDRs

                                   PHONE LOG

Caller:   Gary Light	

Name of Contact:   Norman  Foster,  Petro-Chem Processing

Phone Number   :   (313)  824-5832

Title          :

Location       :   Detroit,  Michigan

Date           :   4/3/90

Purpose of Call:   Obtain  description of fuel blending practices.

Report on Discussion:

1.     80% of sludges handled in container  process system (GPS)
            Drums drained in N2 environment
            Sludge/solid  residue  "liquified" through sheading and blending
            Good for paint residues but not  polymer  residues,  cartridges,  or
            wrags
            Wastes generally meet 5000 btu/lb if organic and contain less  than
            30-40% water
            no dewatering performed

2     Other 20% sludge/solids handled  in Cadence system
            solids removed from drum,  shreaded,  blended, and placed in 6-
            gallon drums  with typically more then 8000 btu/lb

3     Any problems with K048-52?
            Permit doesn't currently allow K048-52
            API sludge might be less than  5000 btu/lb,  but Phase  II regs would
            eliminate this problem
            API sludge could be dewatered  using a centrifuge to meet btu
            requirements

4     Other kilns are "blowing" solids into  kilns like coal dust  mixtures.

5     Capacity?
            More equipment being  added later this year
            No current capacity problems
            Kilns can take about  60 Ib/minute
            CPS can handle 40 drums/hr
            liquids/solid system  about 30  drums/hr
            Capacity by  end of year should reach 100 drums/hr

-------
                                    K-115

      Polymers are example of high btu solid chat can be suspended in liquid
      form.  Can suspend up to 50% solids if particle size is  small enough.
            1 gallon of liquid equal about 7 1/2 Ibs + 50% solids
            Resulting blend can be aspirated to kiln
            Very fine particles result in fuel with consistency of milk shake
            Must have mixing at kiln and there may be settling problems during
            transport.
Any Follovmp Planned:

-------
                                     K-116

                   LIST OF ABBREVIATIONS USED IN PHONE LOGS

AB    :      After Burner
APCE  :      Air Pollution Control Equipment
D/F   :      Dioxins/Furans
DO    :      Department of
IS    :      Interim Status
LI    :      Liquid Injection (unit)
MGPY  :      Million Gallons per Year
NOD   :      Notice of Deficiency (in permit application)
RAF   :      Reuse as Fuel (Facility)
RK    :      Rotary Kiln
RPM   :      Rounds per Minute
RRK   :      Rotary Reactor Kiln
S/S/L :      Sludges/Solids/Liquids
TB    :      Trial Burn
TPY   :      Tons per Year
UIW   :      Underground Injection Well
WWT   :      Wastewater Treatment

-------
       APPENDIX L




MISCELLANEOUS PHONE LOGS

-------
     sr4,
                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, O.C. 20460
                                                              OFFICE OF
                                                     SOLID WASTE AND EMERGENCY
                          5 /990
MEMORANDUM


SUBJECT:  Status of Facilities  Treating  Energetic Chemical Wastes

FROM:     Benigna Carroll,  Environmental Scientist
          Land Disposal Branch
          Waste Management  Division

TO:       The Administrative  Record
     On March 29,  1990, I spoke with Chester Oszman, Environmental
Engineer,  U.S.  EPA,  OSWER,  Alternative  Technology  and  Support
Section, Permits  and  State Program  Division.   He  said currently
there  are  more than  175  facilities seeking  permits  (subpart  X
applications under RCRA) of which  he estimates 150 facilities  are
seeking to treat energetic chemical wastes.  Many of these interim
status  facilities currently  are  treating  these  wastes  by open
burning/open detonation  (OB/OD).

     Mr. Oszman said final permit decisions  are due by November 8,
1992 (Sec. 3005C  RCRA).
                                  L-l

-------
    i sn.
                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON, D.C. 204«0
                      •} ,-) i
                                                             0"'CE OF
                                                     SOLID WASTE AND
MEMORANDUM


SUBJECT:  Telephone  Conversation with Charles A. Marvin, Vice
          President,  The  Refractories Institute, Pittsburgh,  PA
          (412-281-6787)

FROM:     Benigna Carroll,  Environmental  S
          Land Disposal Branch
          Waste Management  Division

TO:       The Administrative  Record
     On Tuesday,  April  24, 1990,  I  spoke with Mr. Marvin  on  the
characteristics and amounts of used hazardous waste chrome refinery
bricks.

     Mr. Marvin said  he had no direct  information  on  the amounts
of chrome  refractory  wastes.   However, from his experience as  a
ceramic engineer  and  from  general  discussions  with  members  of  the
Institute he estimated  approximately 12,500 tons  annually of  used
chrome refractory bricks (and shapes) are hazardous (by EPA's  TCLP
test)  and are  currently land disposed.   He  said  this  was based  o
the following:

          130,000  tons  of new  chrome  bricks  (and  shapes)   are
          manufactured  each year.

          90  - 95% of  the new  bricks  (and  shapes)  go  into  old
          furnaces.   Thus,  117  - 123.5  tons  of used  bricks  are
          generated each year.

          Chrome  brick  varies  in  chrome  (chromite  with  some
          chromic oxide) from 5 to 50%  by weight.  Thus,  some used
          brick would  not  be hazardous  by the  EPA  test.   Some
          chrome  brick  is  also  recycled.

          The  Glass  Packaging   Institute,  which  represents   a
          fraction of chrome brick users,  estimates  that 2,500 tons
          of hazardous  chrome refractory brick is annually

                                                 i
                                L-2

-------
          disposed  of  in  landfills.    Given  this  estimate, Mr.
          Marvin considered the chrome brick user groups/industries
          as follows and  thereby  arrived  at his  estimate for the
          total amount  of hazardous chrome refractory brick needing
          alternative treatment capacity:


   Group/Industry           Tons*	Comments	

GPI                         2,500        Packaging glass companies

Other Glass & Fiber         5,000        Architectural  glass and
glass                                    fiberglass  not part of
                                         GPI.  These facilities
                                         could generate 2 to 3
                                         times the amount of wastes
                                         GPI member  facilities
                                         generate.

Steel Industry              5,000        Largest user of refrac-
                                         tories.   Most  not hazar-
                                         dous by EPA toxics  test.

Cement Industry                0         Industry grinds up  used
(kilns)                                   refractories and incor-
                                         porates them into the
                                         cement.
                           ======
     TOTAL ESTIMATE        12,500        Amount needing alternative
                                         treatment capacity.


*Amount  of chrome refractory brick (shape) which is  hazardous and
landfi1led.
Mr.  Marvin  added,  that  from  his  discussions,   waste  treatment
companies required bricks (and shapes) to be ground to a  1/2  inch
fineness  before  they  would  accept  the  waste.    He  said   most
generators who currently land  dispose  these  bricks (and shapes)  do
not have grinding capabilities.
                                L-3

-------
                     BERYLLIUM WASTE CAPACITY FOLLOWUP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs
                                   PHONE LOG


Caller:           Scott Reed

Name of Contact:  Mr. Richard Davis, Brush Wellman, Inc.

Phone Number:     (216) 443-1000

Title:            Manager, Environmental Affairs

Location:         Cleveland, Ohio

Date:             4/26/90


Purpose of Call:  P015 (Beryllium) Recovery.


Report on Discussion:
      Mr. Davis discussed generation of P015 Beryllium waste.  Beryllium ore
is refined to various concentrations of beryllium, depending upon the end use
To refine beryllium to these concentrations, the metal is pulverized into a
powder and then resolidified using "vacuum hot pressing techniques"   In the
event of a spill of this powder (which would be a P015 waste),  the
contaminated portion would be reintroduced to the refining system.  Beryllium
waste can also be present in the wastewater treatment sludge.  Mr. Davis
indicated that Brush Wellman recovered this beryllium waste through acid
leaching and solvent extraction technologies.  Mr. Davis indicated that the
national volume of this waste was quite low, due to the economic value of the
metal, and that Brush Wellman would accept any beryllium waste for recovery
purposes.
Any Followup Planned:   No followup planned.
                                     L-4

-------
                      P AND U WASTE CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS TO  SUPPORT  LDRs
                                  PHONE LOG


Caller:            Scott Reed

Name of Contact:   Mr.  Rick Stalzer,  BP Chemicals

Phone Number:      (216) 586-5311

Title:            Manager of Environmental Affairs

Location:         Illinois

Date:             3/26/90
Purpose of Call:   Determination Of Actual P And U Volumes At BP America
                  Facilities.
Report on Discussion:


      Mr. Stalzer disagreed with EPA's methodology of adjusting P and U waste
volumes to 100,000 gallons at the point of generation for purposes of the
capacity analysis.  However, BP Chemicals was unable to provide any hard data
to contradict EPA's assumptions.  Mr.  Stalzer reported that when a spill
occurred, as much of the material as possible was recovered, while
unrecoverable waste was washed down a separate system with water for disposal
via deepwell.  Mr. Stalzer indicated that the addition of water in cleaning up
these spills greatly increased the P and U volume due to the mixture rule.
Mr  Stalzer also reported that lawyers for BP America and EPA were currently
working to determine whether these wastes qualified for the mixture rule
exception under RCRA Section 261.3(a)(2)(iv).
Any Follovup Planned:   No followup planned.
                                     L-5

-------
                      P AND U WASTE  CAPACITY  FOLLOWUP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs
                                   PHONE LOG


Caller:           Scott Reed

Name of Contact:  Mr. Gary Rowen, Hoechst Celanese Corporation

Phone Number:     (201) 231-4134

Title:            Director, Environmental Affairs

Location:

Date:             3/21/90
Purpose of Call:  Discussion of  P And U Volumes Requiring Alternative
                  Treatment At Hoechst Celanese Facilities.
Report on Discussion:
      Discussed Hoechst Celanese's  concerns regarding the mixture rule
exception under RCRA Section  261.3(a)(2)(iv).  Mr. Rowen indicated that
Hoechst Celanese was concerned  that EPA  was reinterpreting the mixture rule
exception, disallowing deepwell  injection facilities from qualifying for the
de minimis exemption.  Mr. Rowen  reported, as in  their comment letter, that
currently 600 million gallons of  de minimis losses were deepwell injected
under the exemption, and  that if  EPA reinterpreted this section of the
regulations, this volume  would  require alternative treatment.
Any Follup Planned:     Discussed  this  issue with Randy Hill, EPA Office of
                        General  Counsel.   EPA  is clarifying when the mixture
                        rule  exception  applies, and  is not reinterpreting  the
                        exception  itself.  Hoechst Celanese remains exempt.

                                     L-6

-------
                      P AND U WASTE CAPACITY FOLLOtfUP ON
                        PUBLIC  COMMENTS  TO  SUPPORT  LDRs
                                   PHONE  LOG


Caller:            Scott Reed

Name of Contact:  Dr.  John Schneller III, American Cyanamid Company

Phone Number:     (504) 431-9511

Title:            General Manager,  Services

Location:          Westwego,  LA

Date:             3/21/90
Purpose of Call:   Determination Of Actual -P And U Volumes At American
                  Cyanamid.
Report on Discussion:


      Discussion with Dr.  Schneller verified that the volume of P and U wastes
prior to aggregation with storm water runoff and washwaters was 3.3 million
gallons.  This volume represented a mixture of P and U waste along with water
used to clean up the spill.   Volume generated is unclear.  This volume is part
of a waste stream that is not considered hazardous waste since it qualifies
for the mixture rule exception under RCRA Section 261.3(a)(2)(iv).   This
volume will not require alternative treatment for the Third Third land
disposal restrictions.
Any Followup Planned:   No followup planned.
                                      L-7

-------
                      D003 TREATMENT CAPACITY FOLLOWTJP ON
                        PUBLIC COMMENTS TO SUPPORT LDRs
                                   PHONE LOG
Caller:

Name of Contact:

Phone Number:

Title:

Location:

Date :
Scott Reed

Mr. Richard Fortuna, Hazardous Waste Treatment Council

(202) 783-0870

Executive Director

1440 New York Ave., N.W., Washington D.C.

4/19/90
Purpose of Call:  Treatment  Capacity  For D003  (Reactive Cyanide) Waste,
Report on Discussion:
      EPA received a comment  from HWTC disagreeing with the proposed national
capacity variance for deepwell-injected D003  (reactive cyanide) wastes.  HWTC
stated that it had identified 400 million gallons of available treatment
capacity.  No information regarding  this capacity was provided.  Attempted to
contact HWTC to discuss  this  capacity on 4/19/90, however Mr. Fortuna was out
for the day and did not  return  my call.  Was  also informed that no one else was
available to discuss comments on the Third Third rule.
Any Follup Planned:
      No followup planned unless HWTC returns phonecall.
      Comment provided insufficient data for evaluation.
                                    L-8

-------
Caller:

Name of Contact:

Title:

Location:

Date :

Pupose  of Call:
CAPACITY FOLLOW? ON PUBLIC COMMENTS
          TO  SUPPORT  IDRs

              PHONE  LOG

   Amanda Mondragon

   Guy V.  Johnson

   Senior Counsel,  Environment Group

   Dupont:   Wilmington,  Delaware

   April 27,  1990

   To determine  the  quantity of high-organic barium land
   disposed  at the  Dupont facility.
Report on Discussion:
   Dupont's  research facility generated approximately
   1000  pounds  (120  gallons)  of high-organic  barium in
   1989.   Unless  research demands  change dramatically, it
   is  unlikely  that  the  volume of  high-organic barium
   generated will increase in the  near  future.
                                      L-9

-------
Caller:

Name of Contact:

Title:

Location:

Date:

Pupose of Call:



Report on Discussion:
CAPACITY FOLLOWUP ON PUBLIC COMMENTS
           TO  SUPPORT LDRs

              PHONE  LOG

   Amanda Mondragon

   Kim Boudreaux

   Unknown

   Ethyl Corporation:  Baton Rouge, LA

   April 2, 1990

   To determine the quantity of high-organic barium land
   disposed at Ethyl Corporation.
   Ethyl Corporation landfilled approximately 30 tons
   (7,200 gallons) of high-organic barium in 1989.  Ethyl
   Corporation sent their high organic-barium waste to
   the Preoria landfill in Preoria, Illinoius (EPA I.D
   ILD000805812).
                                     L-10

-------
                CHROMIUM REFRACTORY BRICK CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS  TO  SUPPORT  LDRs

                                   PHONE LOG

Caller:  Gary Light	

Name of Contact:  Arline Sheehan

Phone Number    :  (202) 467-7000

Title           :

Location        :  Washington, D.C.

Date            :  4/19/90

Purpose of Call:  To clarify required capacity for chromium-refractory bricks.

Report on Discussion:

1.    What fraction of the 9,000 to 10,000 tons of chromium brick generated
      annually are land-disposed?
            Something less than 25X of the reported volume was landfilled,
            (speaking only of the container glass industry).
            Many other industries (e.g.  cement kilns,  incinerators) also
            generated the brick.

2.    Does GPI's estimate include the volume reportedly generated by Owens
      Corning Fiberglass (OCF)?
            Estimate intended to cover the entire container glass industry,
            but would not cover volumes generated by other types of glass
            manufacturers (e.g., flat glass manufacturers).
            A representative of Ovens Brockvay, a unit of Owens Illinois, was
            one of 6 glass industry representatives who contributed to the
            generation estimates.

3     Why does OCF's comment indicate that each furnace overhaul produces 50
      tons of chromium refractory brick, when GPI's reported that 300 tons are
      generated per furnace overhaul?
            Six industry experts concurred on the 300 ton estimate, and
            perhaps OCF does not produce container glass.

4.    Who is the chromium refractory brick recycler in Magadore, Ohio?
            Universal Materials Incorporated, (216) 628-2692.

5     What portion chromium refractory bricks contain high  levels of
      phosphorous or silicates?
            Not sure, thought none contained phosphorous.
            Also not sure of silicate levels, but guessed that all of the
            refractory bricks might contain significant  levels of silicates.
            Suggested that I refer to the recently submitted analytical  data
            which she thought contains  constituent analyses for the brick.

Any Followup Planned:  None


                                L-ll

-------
                     CADMIUM BATTERY CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS TO SUPPORT LDRs
                                   PHONE LOG
Caller:   Gary Light
Name of Contact:  Mike Margolis, Kinsbursky Brothers

Phone Number    :  (714) 738-8516

Title           :

Location        :  California

Date            :  3/28/90

Purpose of Call:  Obtain description and capacity estimates of cadmium battery
                  recovery process


Report on Discussion:

      •     Kinsbursky does not have thermal recovery, but breaks and draws
            batteries and sells nickel and cadmium plates to primary metals
            producers.

      •     INMETCO,  in Elwood City, PA has thermal process for Ni/Cd
            batteries

      •     Kinsbursky is fully permitted to process 80,000 Ib/month and can
            readily expand.

      •     Other Recyclers:


Any Followup Planned:

      None
                                     L-12

-------
                     CADMIUM BATTERY CAPACITY FOLLOUUP'ON
                       PUBLIC COMMENTS TO  SUPPORT  LDRs
                                  PHONE LOG
Caller:   Gary LiEht
Name of Contact:   Mike Margolis,  Kinsbursky Brothers

Phone Number   :   (714)  738-8516

Title          :

Location       :

Date           :   3/28/90

Purpose of Call:   Obtain names of companies that buy cadmium battery parts


Report on Discussion:

The following companies buy Ni/C  battery parts:

      1.    Big River  Zinc, IL, buys cadmium plates
      2.    Inmetco,  PA,  may also buy cadmium plates
      3.    INCO,  Ontario,  CA buys nickel plates.
      4.    Glen Brook,  Rittle, OR buys nickel plates.
      5.    Contact also mentioned the following lead acid battery processors
            •     GNB, Los  Angeles,  CA
            •     RSR, Qinmetco,  Los Angeles, CA
            •     Comirco,  Trail, British Columbia
            •     GNB  and RSR, Dallas, TX
            •     St.  Josephs, Jefferson City, MO
            •     Exide Battery,  Muncie, IN and Reading, PA
            •     RSR  in Indianapolis IN and NY
            •     Sanders lead, AL


Any Followup Planned:

      None
                                      L-13

-------
                     CADMIUM BATTERY CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS TO SUPPORT LDRs

                                   PHONE LOG
Caller:  Gary Light
Name of Contact:  Guy Lucie, Big River Zinc

Phone Number    :  (618)  274-5000

Title           :
Location        :

Date            :

Purpose of Call:
Sauget, IL

4/5/90

Determine Big River Zinc's capacity for recovery cadmium
from batteries
Report on Discussion:
            Big River Zinc does thermally recover cadmium from large
            industrial NI/Col batteries, but possible not from small ones.
            Cadmium plates are received from intermediary battery processors
            and Big River Zinc does not accept intact batteries or Nickel
            plates.
            Big River is not permitted to break batteries.
            Believes most breakers are in Europe and Far East where batteries
            are broken and the cadmium plates are shipped back to U.S.
            SAB Nife, a Swedish company that produces batteries in Greenville,
            NC accepts its own batteries after they are worn out.  These
            batteries are then sent to Sweden for recycling.
            SAB contact is Bo Norling at (919) 830-1600.
            Big River Zinc produces 3 million pounds per year of cadmium
            oxides for batteries and plastic stabilization.
            Big River has capacity to process 1 to 1 1/2 million pounds of
            cadmium plates per year.
            Kinsbursky is the only breaker in the U.S.  that Mr. Lucie is aware
            of.
Any Follovup Planned:  None
                                      L-14

-------
                     CADMIUM BATTERY CAPACITY FOLLOWUP ON
                        PUBLIC  COMMENTS  TO SUPPORT LDRs

                                   PHONE LOG

Caller:  Gary Light	

Name of Contact:  Thomas Janeck, Horsehead Resources

Phone Number    :  (412) 774-1020

Title           :

Location        :  Pennsylvania

Date            :  4/27/90

Purpose of Call:  Identify cadmium battery recovery technology

Report on Discussion:

            HRD does not recover Cd from batteries or battery parts.
            Do recover cadmium from EAF dust and zinc concentrates  (zinc
            lead,  and cadmium are recovered).
            Primary product is zinc.

Any Followup Planned:  None
                                     L-15

-------
Date:

Caller:

Contact:

Title:

Company:

Location:

Number:

Purpose:
  GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
               THIRD THIRD RULE COMMENTS

4/24/90

Gary Light

Donald Stone

Regional Environmental Manager

GSX

Columbia, SC

803-798-2993
      To determine whether stabilization facilities have grinding capacity.

Report:

      No grinding capacity, but pug mill used in stabilization process reduces
particle size and totally encapsulates wastes.  Two screw conveyors that
overlap mix and push waste through shafts.  Believes they have probably
stabilized lead slag and matte.  Suggested calling Larry Johnson at 803-452-
5003 for technical and specific operating information.   Maximum permitted
capacity is 135,000 tons per year.
                                     L-16

-------
Date:

Caller:

Contact:

Title:

Company:

Location:

Number:
  GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
               THIRD THIRD RULE  COMMENTS

4/24/90

Gary Light

Richard Hill
US PC I
713-775-7800
Purpose:

      To determine whether stabilization facilities have grinding capacity.

Report:

      No grinding capacity at present,  but class 1, 2,  and 3 mod system would
allow modification without major permitting modification process.   Pug mills
haven't worked well, a rock crusher/grinder (such as a jaw crusher)  is
required.  USPCI has explored grinding with a smelter who wasn't interested in
arranging for grinding additions.  Bruce Boggs in Atlanta office has
researched grinding technologies (404-424-1900).
                                  L-17

-------
  GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
               THIRD THIRD RULE COMMENTS
4/24/90

Gary Light

Gina Hartwell
Dace:

Caller:

Contact:

Title:

Company:

Location:

Number:

Purpose:

      To deternine whether stabilization facilities have grinding capacity

Report:

      Currently no grinding capacity.  Should talk to Gene Mathews,  not
currently available.  Left message for Mr. Mathews to call.
Peoria Disposal

Peoria, IL

309-688-0760
                         L-18

-------
              GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
                           THIRD  THIRD  RULE COMMENTS

Dace:       4/24/90

Caller:     Gary Light

Contact:    Mark Ecsedy

Title:

Company:    Environmental Waste Resources

Location:   CT

Number:     203-755-2283

Purpose:

      To determine whether stabilization facilities have grinding capacity

Report:

      No shredding or grinding prior to stabilization.
                                    L-19

-------
              GRINDING AND STABILIZATION  CAPACITY FOLLOWUP CALLS
                           THIRD THIRD RULE COMMENTS

Date:       4/24/90

Caller:     Gary Light

Contact:    Tim Welsh

Title:

Company:    Frontier Chemical Waste Processes, Inc.

Location:

Number:     716-285-2581

Purpose:

      To determine whether stabilization  facilities  have grinding capacity

Report:

      Only stabilization is for D001, grinding is used for fuel blending.
                                    L-20

-------
              GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
                          THIRD THIRD RULE COMMENTS

Dace:       4/25/90

Caller:     Gary Light

Contact:     Rusty Dunn

Title:      Environmental Manager

Company:     Rollins Environmental  Services

Location:   Baton Rouge,  LA

Number:     504-778-3549

Purpose:

      To determine whether stabilization facilities have grinding capacity.

Report:

      Rollins does not currently have grinding capacity for wastes destined
for stabilization.  A new stabilization  process is being developed that will
include a shaker screen,  grinder,  and pug mill to mix wastes with pozzolonic
stabilizing agents.  This process  will come  on line in September or October of
this year.
                                    L-21

-------
Date :

Caller:

Contact:

Title:
  GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
               THIRD THIRD RULE COMMENTS

4/25/90

Gary Light

Mike Joseph
Company:    Erieway, Incorporated

Location:   Ohio
Number:
Purpose:
216-439-1257
      To determine whether stabilization facilities have grinding capacity

Report:

      Erieway received RCRA permit in January, 1990.  Conditions require
eliminating waste pile and reconstructing stabilization area.  Stabilization
area will be closed for reconstruction.  No grinding capacity now,  except for
a small shredder.  New process is being designed for 8 to 20 tons/hour
(different units).  This process will include grinding, and could be on-line
by the end of 1991.
                                    L-22

-------
                         Chromium Refractory Brick Capacity Followup On
                                Public Comments to Support LDRs
Caller:  Gary Light

Name of Contact:      Russ Bleakney and John Onuska, INMETCO

Phone Number: 412-758-2210

Location:              Ellicot City, PA

Date:                 April  20, 1990

Purpose of Call:To obtain description and capacity data for INMETCO's chromium brick recovery
               process.

Report on Discussion:

THE PROCESS

       Mr.  Bleakney described the system as a recovery process for iron, nickel, and chromium.
Chromium-bearing refractory bricks are crushed and fed to a rotary hearth kiln.  From the kiln they are
sent to a submerged electric arc furnace (EAF) where they are melted and high chromium  remelt alloy
"pigs"  These "pigs"  are then sold as scrap to stainless steel manufacturers.  The nonhazardous slag
byproduct is (primarily alumina) is sold as road-base aggregate.

CAPACITY

       Mr Bleakney estimated maximum crushing capacity at 40 tons per day or  1200  tons per month.
About 200 tons per  month are required for currently processed wastes.  Mr. Bleakney thought that the
EAF was the limiting process  of the system, with  about 1000 tons per month maximum and about 500
tons available capacity.  INMETCO currently processes about 20 tons of chromium refractory brick per
month on average.

SPECIAL RESTRICTIONS

       Phosphorous presents  a problem  because  it is  contained in product.  Product specifications
require less than 0.055 % phosphorous.   As a result, INMETCO generally accepts wastes with no more
than 0.1 % phosphorous (0.03 is ideal), but  high phosphorous wastes can be mixed with low to limit the
phosphorous content of the product.  The limit -is  a matter of economics  in that INMETCO would have
to charge more to accept high phosphorous  wastes.

       Economics also determine minimum chromium content requirements. The lower the chromium
content the higher the price to generators.   At 5% chromium or less, INMETCO's fee is generally
higher than landfill disposal.   Mr. Onuska pointed out that about 80% of the chromium can be
recovered  regardless of initial  concentration  (he added that  byproduct waste production is  about  three
times the volume input).  INMETCO currently abides by  a  self imposed  lower limit of 1.2% nickel
and/or chromium to justify legitimate recycling.

       Silica content also effects costs and  economic  feasibility.  For each pound of silica in the feed
stream, they must add a  pound of lime to maintain basicity.  INMETCO generally does not process
materials containing higher than 9% silica.  Surface cleaning can generally eliminate silica  problems

                                            L-23

-------
since most of the silica is contained in surface residue.

       There are many different types of refractory bricks used by glass industry (and others); Mr.
Onuska was  aware of about 12 types and many more trade names! In general, INMETCO processes
"chrome magnesite refractories".  Which  are defined as those:

       1. Contain more than 20% Cr2O3;
       2. Contain more than 2% MgO;
       3. Contain less than 60% A12O3;
       4. Contain less than 9% silica (SiO2);
       5. Contain less than 0.03% phosphorous (P2O5).

       "Porous  Chrome", and "Chrome  Oxide" bricks can be processed, but in general they are recycled
by brick manufacturers to make lower grade products (e.g. fuse chrome) because of their high chromium
content.  "Bonded chrome"  can be  processed  but at a high cost due to high phosphorous content.  Many
types of refractory bricks have not  been  tested.
                                              L-24

-------
                    LEAD SMELTING CAPACITY FOLLOWUP CALLS
                          THIRD THIRD RULE COMMENTS

Dace:        4/24/90

Caller:      Gary Light

Contact:     Michael  Sappington

Title:

Company:     Lake Engineering (completed  TSDR  Survey for Sanders Lead)

Location:    Atlanta,  GA

Number:      404-257-9634

Purpose:

      To determine capacity  impacts  if staging  piles  at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste  storage.  Also,  to clarify volumes and
management practices  for  slag and matte  from  secondary smelters.

Report:

      Mr.  Sappington  indicated that  Sanders had applied for an exemption from
the definition of solid waste for materials stored prior to recycling.   He was
not familiar with recent  activities  at Sanders,  and suggested I speak to Roy
Baggett,  Environmental  Coordinator for Sanders,  at 205-566-1563.

      Mr.  Sappington  said he was  familiar  with  GNB's  smelting operations in
Columbus,  GA;  Frisco, TX; and Los Angeles, CA.   The TX and CA facilities are
currently operating under IS,  and the GA facility is  fully permitted.  Contact
did not  know capacities exactly,  but said  that  GA produces 16,000 tons per
year of  product and probably processes 28,000 tons/yr of batteries and 4000 to
5000 tons/yr of other wastes.   Contact thought  that all GNB facilities are
operating at close to capacity since lead  prices are  high,  and that adding 5
to 10 percent would be  stretching.   Air  permit  is often binding constraint.

      Mr.  Sappington  indicated that  GNB  informally assumes their staging piles
are exempt in permit  application  as  in process  raw materials storage.  Many
states consider these materials to be wastes.
                                      L-25

-------
                     LEAD SMELTING CAPACITY FOLLOWUP CALLS
                           THIPJ) THIRD RULE COMMENTS

Dace:       4/24/90

Caller:     Gary Light

Contact:    Roy Baggett

Title:      Environmental Coordinator

Company:    Sanders Lead

Location:   Troy, AL

Number:     205-566-1563

Purpose:  To determine capacity  impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage.  Also, to clarify volumes and
management practices for slag and matte from secondary smelters.   Also to
verify that none of the D006 in  sanders' waste pile is actually cadmium
batteries.

Report:
D006 in WASTE PILE

      Mr. Baggett confirmed that none of the D006 reported in TSDR Survey was
from cadmium batteries.

STAGING PILE STATUS

      The staging pile is not exempt, but is permitted as hazardous waste
storage area (double liner, leachate collection and treatment system etc).

CAPACITY

      Last week Sanders cut 1109790 Ib/day of batteries on average.  Maximum
is 2,000,000 Ib/day.  Capacity is limited by acid generation discharge from WW
treatment system, and blast furnace capacity (about equal).  Each of four
units produces 80 tons per day of product operating at about 90X capacity
About 0.7 tons of product are produced per 1 ton of batteries, and plant
operates 365 days per year.  (80 tons/day/unit) x (4 units) / (0.7 tons
battery per ton product) x (365  days/yr) - 166,857  tons/yr currently
processed.   @ 90 X capacity, maximum capacity is 185,397;and available is
18,540 tons/yr.

SUVG and MATTE

Matte  is often recycled as pig iron replacement, but slag  is sent  to hazardous
landfill.  Slag contains 10 to 15X lead, and can be stabilized to  meet
characteristic; but must first be crushed.  Sanders expects  to have  onsite


                                L-26

-------
capacity to crush and stabilize all generated slag by May 8, 1990 (already
permitted)    Will not accept wastes commercially.
                                    L-27

-------
                     LEAD SMELTING  CAPACITY FOLLOWUP CALLS
                           THIRD  THIRD RULE COMMENTS

Date:       4/24/90

Caller:     Gary Light

Contact:    Gerald Dumas

Title:      Environmental Affairs Director

Company:    RSR Corporation

Location:   Indianapolis, IN; City of Industry, CA; an- Middletown, NY

Number:     214-631-6070

Purpose:

      To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal,  and/or these piles must meet
requirements for hazardous waste storage.

Report:
      RSR operates three secondary smelting, facilities: NYD030485288,
CAD066233966,  IND000199653.  Not in TSDR Data set because completed generator
survey?  Main input material is auto batteries (with some industrial and other
batteries) and other lead-bearing materials (e.g. battery manufacturing
wastes)

STAGING PILE STATUS

All  3 facilities have considered exemption.  NY has applied, and is still
waiting and IN has been denied because of other state litigation.  Believes
problem with exemption is that states were given opportunity with  little
guidance from EPA.  States are reluctant to act.  Wastes currently stored  in
piles,  too dense for tanks, could result in closure if prohibited by third
third.  NY and CA have similar storage facilities: concrete slabs with  run-
on/runoff collection and WWT.  Materials are stored in bins.  New  storage
building being designed for CA.  At IN facility, materials are stored in
building on concrete with collection system.   Currently not certain if  storage
in building satisfies storage requirements.  If so, NY and CA would build
enclosures; but not possible by May 8,  1990.    NY may still get permit  or
variance.  CA is under federal and state consent order and hasn't  filed for
variance.  Storage areas for intact batteries are currently IS.

CAPACITY

       Faxing  information
                                     L-28

-------
                    LEAD  SMELTING CAPACITY  FOLLOWUP CALLS
                          THIRD THIRD RULE  COMMENTS

Date:        4/24/90

Caller:      Gary Light

Contact:    Jeffrey Leed

Title:

Company:    Exide Corporation (General Battery)

Location:   Reading, PA; Dallas,  TX; andMuncie,  IN

Number:      215-378-0852

Purpose:

      To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage.  Also,  to clarify volumes and
management practices for slag and matte from secondary smelters.

Report:

      Exide operates 3 secondary lead smelting facilities not in TSDR:
PAD990753089, TXD068999622,  and IND000717959.   Contact believes generator
survey was submitted for PA and TX,  but IN was purchased and reconstructed
since 1987.  Each facility has a permitted or IS  storage area for spent
batteries or containers (used for intact batteries).

STAGING PILE STATUS

      PA facility is regulated under reuse permit, for which application was
submitted more than two years ago.   Waste pile area requires state DER permit
and may need RCRA permit.   Storage pile is specified in permit, not sure of
impact of third third.  Storage area has concrete surface with runoff
collection, is under roof, and is operated under negative pressure.

      For IN facility, variance is granted but interpretation is unclear.
Currently believe exemption only applies to batteries broken on site
(indigenous to process).  Off-site battery parts and other lead scrap not
exempt.   Storage area has been included in Part B application submitted  2/90.
Permit would regulate storage area as waste pile in building (includes truck
wheel washing)

      TX facility is currently under IS, Part B submitted 1986  (/).   Staging
pile  addressed as waste pile.   Are awaiting state action before applying for
variance.  Facility has been ordered to close by City of Dallas by 12/31/90
for noncompliance with  recent zoning changes.  Closure being appealed.

                                      L-29

-------
L-30

-------
CAPACITY

PA facility data from generator survey (1986 data)

                              1986 volume processed (tons/yr)
      Batteries                     51,000
      Non-hazardous materials        5,200
      Hazardous wastes (offsite)     1,591

      typical feed rate to furnace: 3340 Ib/hr
      maximum feed rate to furnace: 3750 Ib/hr (i.e.,  89X utilized)

TX facility data from generator survey (1986 data)

                              1986 volume processed (tons/yr)
      Batteries                     26,000
      Non-hazardous materials        1,416
      Hazardous Wastes                 769

      typical and maximum feed rate to furnace:  11,667 Ib/hr (i.e. , 100X
      utilized)

IN Facility (estimated)

      Goal within 1 year to process 20,000 batteries per day (- 95,000
      tons/yr).  More capacity is technically possible.   Currently processing
      between 8000 and 10,000 batteries/day (i.e., SOX utilized).
                                      L-31

-------
SL\G AND MATTE

      Some slag greater than 2.5X lead.  Currently looking for ways to cycle
slag back to smelter.  If possible, this will reduce capacity.  PA facility
generates 8000 to 9000 tons to slag and matte per year, which is sent to an
out-of-state hazardous waste landfill.  No crushing or grinding capacity is
available on-site-- no room for baghouses, and grinding produces dust
problems.  Should use sane slag and matte ratios to determine generation at
other facilities.
                                      L-32

-------
                    LEAD SMELTING CAPACITY FOLLOWUP CALLS
                          THIRD THIRD RULE COMMENTS

Date:        4/24/90

Caller:      Gary Light

Contact:     Ken Pike

Title:

Company:     East Penn Manufacturing

Location:    PA

Number:      215-682-6361

Purpose:

      To determine capacity  impacts  if staging piles  at secondary lead
smelters are considered land disposal,  and/or these piles must meet
requirements for hazardous waste  storage.   Also,  to clarify volumes and
management practices for slag and matte  from  secondary smelters.

Report:


STAGING PILE STATUS

      Intact batteries stored on  ground,  but  very few are stored before
breaking.   Broken battery parts and  other materials stored in fully permitted
totally enclosed material storage area (with  runoff collection and WWT)

CAPACITY

      Second furnace added to single facility.   Currently operating at maximum
permitted capacity of 42,000 short tons/yr product.  ( equivalent to about 4
million batteries)   Could produce up to 60,000 tons/yr,  but would require
permit mod.
                                     L-33

-------
SLAG AND MATTfi

      Slag and matte currently  sent  to hazardous waste landfill in Michigan.
Has unsuccessfully tried many thermal recovery techniques for slag and matte.
Proposed recovery standard would  force facility to close.  Fixation is
possible.  About 20 to  25 tons/day of slag and matte generated 10 days out of
every 14 days.  Equivalent of 15  to  202 product output generated as slag and
matte, believed typical of industry  (using reverbetory furnace followed by
blast furnace).  Exception may  be RSR who replaced blast furnace with electric
arc furnace and generates slag  that  allegedly passes TCLP as nonhazardous.
Stabilization would require  grinding to less than 1/2 inch in diameter,
current crusher (previously  used  to  grind slag into cement aggregate for use
onsite) can't reach 1/2 inch diameter   Readily available equipment (roll
clone crusher) would have to replace existing jaw crusher.  Permit
modification would take about  18  months, and construction would take about 4
to 6 months.
                                       L-34

-------
                    LEAD SMELTING CAPACITY FOLLOWUP  CALLS
                          THIRD THIRD RULE COMMENTS

Date:        4/24/90

Caller:      Gary Light

Contact:     Glenn Hasse

Title:       Vice President

Company:     Schuylkill Metals

Location:    Baton Rouge,  LA  and MO

Number:      504-775-3040

Purpose:

      To determine capacity  impacts  if staging piles  at secondary lead
smelters are considered land disposal,  and/or these piles must meet
requirements for hazardous waste storage.   Also,  to clarify volumes and
management practices for  slag and matte  from  secondary smelters.

Report:

STAGING  PILE STATUS

      MO facility has  permitted waste pile.   LA facility is under IS, and
variance petition has  been  in process since 1986.   Problem is overburden of
state.   Variance was granted for battery parts only before 1986, trying now to
get variance redefined for current  operation.  Believes currently exempt by
variance but not certain.  State just called  in Part  B application.  MO
storage  area is about  the same as LA.  Would  like  national variance for waste
piles .

CAPACITY

      New furnace added to LA facility added  60,000 to 70,000 tons/yr of
capacity to estimates  in  TSDR Survey.  Currently 1002 utilized.
                                     L-35

-------
SLAG AND MftTTfr

     _MO generates about 30 tons/day and LA about 60 tons/day  (30 to 70X
landfilled).  Operates 7 days per week.  No grinding capacity in industry or
at^landfills.  Solidified "buttons" currently broken up with sledge hammers
prior to disposal.  Both facilities dispose of slag and matte in on-site
landfills.
                                      L-36

-------
STERLING CHEMICALS

February 14, 1990
Ms. Jo-Ann Bassie
Office of Solid Waste (OS-322)
U. S. Environmental Protection Agency
401 M Street S.W.
Washington,  DC 20460

Dear Ms. Bassie,

Thank you for speaking with me on January 30 regarding Sterling Chemicals
comments that were submitted on January 8, 1990.  I have enclosed excerpts of
these comments with the areas discussed with you highlighted. I trust that the
data provided will be carefully reviewed and used to justify the requested national
capacity variances (NCV).

My specific requests made in that conversation were:

1)     A NCV for underground injection of  D003a and D002 nonwastewater be
       granted,

2)     Resolution of the NCV/MTR problem  with D003a and D002 wastewaters,

3)     Once 2) is resolved, a NCV for D003a and D002 wastewaters,

4)     Careful review of the Sterling comments.

I believe that the need for each of the above requests are well documented in
Sterling Chemicals' comments. Please contact me at (409) 942-3129 if you require
clarification of the data.

Sincerely,
David W. Dunn, P.E.
Environmental Affairs Manager

/pm
Attachment

cc:    Francoise Brassiere - USEPA-ODW
       Bruce Kobelski - USEPA-ODW
       Mike Cook - USEPA-ODW

DWD005.1«
Sterna C^e^'Ca's nc                 L-37

-------
January 8, 1990
Page 15
Failing r •consideration  of the standard, Sterling Chemicals
requests  a  national  capacity  variance  fee  this  class- of
hasardous waste.   £44 discussion in &.A.3. above concerning
the questionable value of  a varianca*  f4hssv,aV AiHion gallon
vast*  straaa  for Starling  Chaaicalt  floos  would raquira
further traatmant to  »*at tJia  propOM«t BOAT standards,  and
tha Agancy  lists  only 2  Billion gallons p«r yaar of nation-
wida availabla capacity  (Tabla  III B.l.(c)).

Sterling Chemicals appreciates  the opportunity  to comment on
the proposed rule.
                         Very truly yours,
                         David W. Dunn,  P.E.
                         Environmental Affairs Manager
                         Sterling Chemicals,  Inc.
                          L-46

-------
                            APPENDIX M




ANALYSIS OF LARGE VOLUME UNDERGROUND INJECTED P AND U CODED WASTES

-------
                                  APPENDIX M
      ANALYSIS OF LARGE VOLUME UNDERGROUND INJECTED  P  AND  U  CODED WASTES


      In support of the Third Third final rule,  the  Agency conducted  a  special
analysis of certain large volume P and U coded waste streams reported as
deepwell injected in the TSDR Survey.   The purpose of  this analysis was to
gather additional data on the generation, characteristics, and current
management of these waste streams.   The Agency suspected that these streams,
as generated, were actually small volumes of hazardous wastes mixed with large
volumes of aqueous wastes,  therefore making the entire mixture hazardous.

      The following facility summaries document the  results  of the  analysis
for each of the contacted facilities.

      •     Aristech Chemical Corporation.  The facility contact stated that
            its P and U wastes are generated separately but  share a common
            collection system.  Furthermore,  he said that some of the P and U
            wastes are "off-spec" products but most  are spill residues.  As
            injected,  he said the wastes are composed of small amounts of P
            and U waste contaminated with large volumes of nonhazardous
            process wastewaters (the contact was unable to provide the
            percentage that was hazardous vs. nonhazardous).  In addition, as
            part of the facility's wastewater treatment system prior to the
            well, insoluble organics are removed and recycled or reused as
            fuel.  Finally, he said the facility was investigating whether the
            waste may qualify for a "de minimis" exemption.

      •     American Cvanamid.  The contact stated that as  injected  the stream
             is 99 percent water and only hazardous because  of the mixture
             rule.  She  also  said many of  the U codes may  qualify for the de
             minimis exemption, but  they  carried the codes to be safe.   She
             said the  waste is mainly  generated from storm water, minor spills,
             and backwashing the  well's  filters.
                                      M-l

-------
      •      Rubison Incorporated.   The  contact  stated that  the  P and U coded
            waste streams  are  mostly  water  as  injected (although he did not
            know the percentage)  and  that  the wastes  are  hazardous because of
            the mixture rule.   He  said  the  wastes  are generated by minor
            spills,  process  upsets, and as  scrubber water   He  said they do
            analyze the waste  prior to  injection and  the  concentration of P
            and U code constituents are typically  in  the  low part per million
            range.

      •      Calanese Chemical  Company.   Although this facility  refused to
            provide detailed information without a formal written request, the
            contact stated that their underground  injected  wastes consisted of
            very small portions of hazardous waste mixed  with large volumes of
            water

      •      Cecos International.   The facility  contact stated that this waste
            is rainwater drained from the  surface  of  an active  landfill (it is
            not leachate which has percolated  through a closed  landfill)   He
            said the stream  is virtually all rainwater and  the  concentration
            of the U coded constituents is  less than  50 parts per million.
            The waste is received from  offsite.

      In addition,  one CBI facility was contacted.  The facility contact
stated that the waste stream reported as injected  in  the  TSDR Survey was the
result of the cleanout of a  surface impoundment and consisted mainly of
rainwater.   He said they are still injecting wastes but that they are
exclusively mixture rule wastes consisting  mostly  of  water.

      Based on the information received from these facilities,  EPA believes
that the actual volume of P  and U wastes generated by these facilities is
significantly less than the  volume reported as  underground  injected.  The
Agency believes that 100,000 gallons  per year  is a reasonable upper estimate
of the volume of these P and U wastes that  are  generated  prior  to mixture with
other wastes.
                                     M-2

-------
        ecause  the  land  disposal  restrictions  apply  to wastes at the point of
    ration,  the Agency  believes'  that only  the originally generated P and U
        volumes should be used to estimate  required  capacity   Consequently,
     gency used 100,000 gallons per year per code as an upper estimate of the
required capacity for P and U wastes at these facilities.
                                      M-3

-------