Fact Sheet Modification to the Resource Conservation and Recovery Act (RCRA) Hazardous Waste Management Permit for Aristech Chemical Corporation (owner) and Sunoco Inc. R&M (operator) Haverhill Ohio. EPA Id Number: Ohd 005 108 477


United States	Waste, Pesticides and Toxics Division	Illinois, Indiana,

Environmental Protection	77 West Jackson Blvd.	Michigan, Minnesota,

Agency, Region 5	Chicago, Illinois 60604	Ohio, Wisconsin

c/EPA

April 2006

FACT SHEET

Modification to the Resource Conservation and Recovery Act (RCRA)
Hazardous Waste Management Permit for Aristech Chemical
Corporation (Owner) and Sunoco, Inc. R&M (Operator)

Haverhill, Ohio.

EPA ID Number: OHD 005 108 477

Introduction

The U.S. Environmental Protection Agency
(U.S. EPA) and the Ohio Environmental
Protection Agency (OEPA) have prepared this
fact sheet to inform the public of the process
involved in issuing a modified Resource
Conservation and Recovery Act (RCRA)
Hazardous Waste Management Permit.

The Solid Waste Disposal Act was amended by
RCRA in 1976, further amended by the
Hazardous and Solid Waste Amendments
(HSWA) of 1984. Hazardous Waste and
Consolidated Permit Regulations were
promulgated on May 19, 1980.

On June 30, 1989, the State of Ohio received
final authorization pursuant to Section 3006 of
RCRA, 42 USC § 6920, and 40 CFR Part 271,
to administer the pre-HSWA RCRA hazardous
waste program. However, the State of Ohio has
not yet been authorized to administer certain
HSWA regulations, such as the Boilers and
Industrial Furnaces regulations, commonly
known as the BIF Rule.

On October 21, 2004, the U.S. EPA issued a
federal RCRA permit to Aristech Chemical

Corporation (Owner) and Sunoco, Inc.

(Operator) for the BIF units at the facility
located in Haverhill, Ohio. The Owner and
Operator will be referred to as Aristech/Sunoco
or Permittees.

The OEPA adopted the BIF Rule on August 31,
2004. The OEPA regulates BIF facilities using
Permit-By-Rule.

The BIFs are currently operating under RCRA
permit conditions. On May 20, 2005,
Aristech/Sunoco proposed a Class 3 permit
modification to the RCRA permit in accordance
with 40 CFR § 270.42, allowing the Permittees
to modify Boiler UC for burning heavy and light
hydrocarbon wastes concurrently, thus
streamlining waste burning and steam
production from the existing boilers. The OEPA
received Class 3 permit modification request on
November 30, 2005.

The U.S. EPA and OEPA have reviewed the
proposal including a revised trial burn plan and
determined that the permit modification request
met the requirements of 40 CFR § 270.42 and
OEPA's Permit-By-Rule requirements.

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Background

Aristech Chemical Corporation ("Aristech")
owns a multiple-product integrated chemical
manufacturing facility in Haverhill, Ohio. The
Haverhill plant is located in southern Ohio along
the Ohio River bordering Kentucky. Chemical
production began in 1962 by the Oxo Chemical
Company, which was purchased by United
States Steel Corporation (USSC) in 1965.

USSC formed its US S Chemicals Division in
1966, making the Haverhill facility a major part
of its industrial chemicals business. In 1986,
Aristech succeeded to the ownership of the
Haverhill plant. In May 1995, the ownership of
Aristech was transferred to Mitsubishi
Corporation. Sunoco, Inc. acquired all of the
stock of Aristech from Mitsubishi on January 1,
2001. Aristech continues to exist as a wholly
owned subsidiary of Sunoco, and continues to
own the land and appurtenances at the facility.
The name of the plant was changed to Sunoco
Chemicals - Haverhill. On February 27, 2002,
Sunoco, Inc. (R&M) became the operator of the
facility.

Facility Description

Steam needed for the manufacturing processes is
generated from six (6) on-site package boilers
and a thermal oxidizer. Four of the 6 boilers
burn hazardous waste generated on-site as a
supplemental fuel to natural gas.

The Haverhill facility generates two (2) distinct
types of hazardous waste fuels, namely light
hydrocarbons (LHC) and heavy hydrocarbons
(HHC). LHC fuel exhibits the RCRA
characteristics of ignitability (D001) and toxicity
for benzene (DO 18) and methyl ethyl ketone
(D035). LHC also includes waste oil which is
not regulated under RCRA. HHC fuel consists
of listed hazardous waste (K022), characteristic
wastes (DO 18), and wastes not regulated under
RCRA.

The hazardous waste burning boilers are
designated as UA, UB, UC and UE and are

subject to 40 CFR Part 266, Subpart H:
Hazardous Waste Burned in Boilers and
Industrial Furnaces, commonly referred to as the
BIF Rule.

The hazardous waste fuels (LHC and HHC) are
stored in on-site storage tanks. Samples are
taken for analysis of constituents including the
regulated metals. LHC and HHC fuels are
pumped from the tanks to the boiler burners,
atomized, and burned in the boilers. There are
vent controls for these tanks.

Basis for Decision to Issue the Modified
RCRA Permit

The permittees have processed the Class 3
permit modification request in accordance with
40 CFR§ 270.42. The modified Boiler UC must
meet the requirements of applicable BIF Rule.
In addition, the modified permit must be
protective of human health and the environment.

Tentative Decision:

Subject to public notice and comment under 40
CFR § 124.10, and under the authority of the
Resource Conservation and Recovery Act as
amended by the Hazardous and Solid Waste
Amendments of 1984 ("HSWA"), the U.S. EPA
proposes to issue a modified RCRA permit to
the Permittees for the operations of the BIF
facility in Haverhill, Ohio. The term of this
modified permit is no more than ten years from
the effective date of the permit.

Procedures for Reaching a Final Permit
Decision:

This draft RCRA hazardous waste permit is
based on the administrative record, which
consists of this fact sheet, the permit
modification request and other data the facility
owner/operator has submitted, and other relevant
material that the U.S. EPA has assembled. A
copy of the permit modification request and
draft modified permit is available locally for
viewing at the Portsmouth Public Library,

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Wheelersburg Branch, 666 Center Street,
Portsmouth, OH 45694. Copies of the draft
permit and fact sheet are also available from the
U.S. EPA at the address given below. The
official administrative record supporting the
U.S. EPA's tentative decision is maintained at
the U.S. EPA's Regional office at the address
listed below.

Comments on this proposed action may be
submitted to the addresses listed below, not later
than	.

After the close of the public comment period,
the U.S. EPA will review and consider all
comments received before making a final permit
decision. The U.S. EPA will also prepare and
send to all commenters a document responding
to significant comments received during the
public comment period. Those who submitted
written comments during the official comment
period or made a statement at the hearing will be
notified of any final decision. Within 30 days of
a final decision, any person who submitted
written comments or made a statement at the
hearing may petition the U.S. EPA's
Environmental Appeals Board to review the
decision.

Comments, requests for information, and
requests for copies of the draft permit and fact
sheet should be made to:

Ohio Environmental Protection Agency
122 S. Front Street
Columbus, OH 43216-1049
(614) 644-3846

A copy of the draft permit can be found on the
U.S. EPA web site at:

htto: //www .epa. gov/re g5 rcra/wptdiv/permits/
index.htm

A copy of the draft permit can be found on the
Ohio EPA web site at:

http: //www .epa. state. oh .us/dhwm/permitpublicc
omment.html

Mr. Wen Huang, P.E.

Waste Management Branch (DW-8J)
Waste, Pesticides, and Toxics Division
U.S. Environmental Protection Agency,
Region 5

77 West Jackson Boulevard
Chicago, Illinois 60604-3590
312-886-6191

or

Ms. Pam McCoy

Division of Hazardous Waste

Management

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