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Tonawanda New York Community Air
Quality Study and Evaluation of the
Tonawanda Coke Facility
Community Update
April 2011
TIMELINE
• April 2009
EPA and DEC conduct inspection/evaluation
at the Tonawanda Coke Corporation (TCC)
• June 2009
DEC conducts a public meeting to release their
findings from the Tonawanda Community Air
Quality Study to the community and describes
actions that have and will be taken to reduce
emissions of hazardous air pollutants in the
community. EPA and DEC conduct hazardous
waste inspection at TCC.
• July 2009
TCC representatives meet with EPA to
review future testing criteria/protocols for
stack tests and fugitive emission testing for
benzene (DIAL TEST).
• September 2009
EPA and DEC conduct hazardous waste
sampling inspection at TCC
• October 2009
DEC publishes the Tonawanda Community
Air Quality Study which is now posted on the
Department's website:
http: www. dec, ny. gov/chemical/5 9464. html
• December 2009
US Attorney's Office for the Western District
of NY leads federal investigators on raid at
TCC.
Civil enforcement actions issued to TCC for:
-Resource Conservation & Recovery Act-
Cited two violations related to coal piles and
tanks.
-Clean Water Act-Cited numerous operation
and maintenance violations.
• January 2010
Civil enforcement actions issued to TCC
cited for numerous Clean Air Act violations
and ordered TCC to submit appropriate test
protocols.
• April 2010
Administrative Order issued pursuant to the
Clean Air Act requiring analysis of two
incidents that occurred at the facility and
assessment of the facility.
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) and the New York State
Department of Environmental Conservation (DEC) are very active in your
community and we wanted to take a moment to let you know what we are
doing. First, EPA and DEC funded a study of air quality in your area and
second, the agencies are engaged in numerous assessments of the Tonawanda
Coke Corporation's (TCC) compliance with federal and state environmental
laws and regulations. This is an update of activities at the facility.
EPA and DEC Evaluation
As a result of the air quality study and because of concerns expressed by the
community, EPA and DEC are conducting a full multi-faceted evaluation of
the facility to determine its compliance with federal and state laws and
regulations.
Recent Actions
EPA recently issued two new orders to TCC outlining further requirements
and updated deadlines for coming into compliance with hazardous waste and
clean water laws. A second order related to hazardous waste violations
provides TCC with additional time to excavate and remove coal tar sludge on-
site and to ship associated contaminated soils and debris off-site for disposal.
A second order related to clean water violations provides additional time for
TCC to comply with cyanide limits in its water permit that will allow TCC the
ability to comply with certain limits and modify its operations.
Clean Air Act
EPA's enforcement of multiple violations of the Clean Air Act is proceeding
and the investigation is ongoing.
Update: As a result of the Differential Absorption Light Detection and
Ranging (DIAL) testing that occurred in May 2010, and a follow-up to the
facility inspection in October 2010, EPA has concluded that the facility's by-
product area is a significant source of fugitive benzene emissions. EPA
directed TCC to hire an independent engineering firm to evaluate the
processes within the by-products area to determine what equipment needs
repair/replacement to minimize these emissions. The results of this evaluation
and a schedule for work completion is currently being negotiated with TCC.
Clean Water Act
EPA issued a Water Administrative Order in January 2011 for TCC to
www.epa.gov/region02/capp/tonawanda.html
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Community Update
April 2011
Tonawanda New York Community Air Quality Study and Evaluation of the Tonawanda Coke Facility
Page 2
comply with cyanide limits in its industrial user permit (for discharges to the Tonawanda
Wastewater Treatment Plant) by December 2011. The Order also requires upgrades to
the coal pile runoff treatment system and full compliance with all effluent limits at coal
pile runoff and control of suspended solids by August 2011.
Update: The company continues to make progress to address its water violations. TCC
has submitted an Engineering Plan for improving its treatment of coal pile runoff and the
plan was approved by DEC and EPA. TCC also submitted a plan for achieving full
compliance with its cyanide limits for December 2011. TCC has already amended its
best management practices plan and installed a flow meter for process wastewater and
conducted an audit to identify any cross connections to ensure that process wastewater is
only discharged in accordance with its permit and not to the Niagara River. EPA
continues to monitor TCC's progress.
Resource Conservation and Recovery Act (RCRA)
EPA issued a second RCRA Administrative Order in March 2011 related to hazardous
waste violations that provides TCC with additional time to excavate and recycle coal
tar sludge on-site and to ship associated contaminated soil and debris off-site for
disposal.
Update: Some important progress has been made to address hazardous waste
violations. TCC no longer mixes its coal tar sludge on coal piles but places it now on
an impervious pad. To date, they have excavated and recycled 28 million pounds of
residual tar-like material. The work to excavate and remove this material continues
with 30 million pounds estimated remaining. More than 2 million pounds of hazardous
wastes generated by the removal of four tanks and excavation of contaminated soil and
debris have been shipped off-site to permitted treatment, storage, and disposal
facilities, and another 2 million pounds is estimated to be generated and shipped by the
project conclusion. This work is being conducted under DEC oversight.
• May 2010
DIAL Testing completed at TCC
• July 2010
A community presentation was
conducted on July 7, 2010 regarding
the observed reductions in ambient
benzene concentrations from July
2008 through March 2010.
• August 2010
-Second Administrative Order
issued to TCC to comply with its
Clean Water Act permit.
-First Resource Conservation and
Recovery Act (RCRA) order to
excavate and recycle coal tar sludge
and ship contaminated soil and
debris.
• September 2010
New air pollution testing (DIAL)at
TCC shows that the facility is a
significant source of benzene.
• January 2011
-Clean Water Act order to comply
with cyanide limits in water permit
and modify operations.
• March 2011
Second Resource Conservation and
Recovery Act (RCRA) order to
excavate and recycle coal tar sludge
and ship contaminated soil and
debris.
FOR MORE INFORMATION
* Public participation is essential
to the success of EPA's community
involvement program. If you have
any questions regarding EPA's
activities in Tonawanda, please
contact: Mike Basile, EPA Public
Affairs Specialist, Western New
York Public Information Office,
716-551-4410 or email to
For copies of recent
ONGOING EVALUATION
The DEC continues to operate two air quality monitoring stations that were part of
the original community study. In addition, a continuous benzene monitor has been
installed at one site to assess the impacts of the benzene reduction measures that have
been implemented to date by the TCC at the direction of the DEC and EPA. A
community presentation was conducted on July 7, 2010 by the DEC and EPA.
Information on the enforcement actions taken at TCC and observed reductions in
ambient benzene concentrations from July 2008 through March 2010 were presented to
the community. The DEC has conducted a comprehensive analysis of the post
community study benzene air measurements at two locations for the purpose of
evaluating the impact of the continuing benzene reduction actions that are occurring at
TCC. The evaluation of the benzene air concentrations at the two monitoring sites
indicates there have been significant reductions in the ambient concentrations of
benzene at both locations since July 2008.
EPA letters to TCC, please visit: http://www.epa.gov/region02/capp/tonawanda.html
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www.epa.gov/region02/capp/tonawanda.html
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