I. EXECUTIVE SUMMARY

A RCRA Facility Assessment was conducted at the Southwestern Portland Cement Company Quarry Plant (SPCC) facility, Greene County, near Fairborn, Ohio (EPA I.D. No. OHD981195779), to determine the need for corrective action. A Preliminary Review (PR) of files pertaining to the facility was performed in January 1990. This was followed by a Visual Site Inspection (VSI) of the facility on February 12, 1990. This document constitutes the PR/VSI Report for the facility.

The SPCC facility is a dry process, preheater kiln, clinker-producing plant with an annual production capacity of over 600,000 tons of cement clinker. When this clinker is milled, the final product is commonly called Portland cement. The facility consists of a total of 9 manufacturing and ancillary buildings, 4 material handling areas, and one process water holding pond. The SPCC facility began operations in August 1974. The actual affected area under permit is for approximately 183 acres (Reference 57). Prior to the commencement of operations at the facility, quarrying operations had occurred since the early 1950's.

Seventeen solid waste management units (SWMUs) and one area of concern (AOCs) were identified and examined, and the potential for the release of hazardous wastes or constituents from each unit to the environment was assessed. Table I-1 presents a list of these SWMUs and AOCs. Complete unit descriptions are given in Section IV. The locations of the SWMUs and AOCs are presented in Section IV in Figure IV-1.

Of the seventeen SWMUs, one was determined to have high potential for release to soil/groundwater and surface water, and one was determined to have a low to moderate potential for generation of subsurface gases. The remainder were determined to have low or no potential for release to the environment. The one area of concern, AOC A, was found to have a high potential for release to soil and surface water, an unknown potential for release to groundwater and low potential to air and subsurface gas.

The Stormwater Retention Impoundment/Silt Fence and Collection Ditches (SWMU 15) was determined to have a high potential for the release of hazardous wastes or constituents to both surface water and groundwater, based on the observation of releases at the time of the VSI. The Landfill (SWMU 14) was determined to have a low to moderate potential for generation of subsurface gas based on the wastes that had been landfilled. A RCRA sampling visit is suggested for both of these units.

In the case of the Landfill, this is recommended due to the age of the unit and difficultly in determining what wastes may have been managed. The Stormwater Retention Impoundment/Silt Fence collects the runoff from the whole SPCC site and therefore may contain hazardous constituents from the coal pile leachate and HWF areas. Discharge to Ludlow Creek, a Warm Water Habitat Stream (References 43 and 47) from

Table I-1

Current Permitting of SWMUs and AOCs Identified at the

SPCC Quarry Plant

Current

Permitting

No. Description RCRA Air

SWMUs:

1. HWF Truck Unloading Area No No

2. HWF Filtrate Shed No No

3. HWF Storage Tank No. 1 and Yes No

Ancillary Piping

4. HWF Storage Tank No. 2 Yes No

5. HWF Storage Tank No. 3 Yes No

6. HWF Storage Tank No. 4 Yes No

7. Outdoor Clay Storage Conveyor No Yes

and Ancillary Equipment

8. Burner Bldg/Kiln Floor No No

9. Cement Kiln No Yes

10. Roura Hoppers (3 each) No No

11. Dumpsters (3 each) No No

12. Safety-Kleen Units (2 each) No No

13. HWF Sample Storage Cabinet No No

14. Landfill No No

15. Stormwater Retention Impoundment/ No No

Silt Fence and Collection Ditches

16. Waste Tire Staging Area No No

17. Alkali Bypass Baghouse No Yes

AOCs:

A. Quarry Garage Diesel Fuel No No

Tanks (2 each)

the Stormwater Retention Impoundment/ Silt Fence and Collection Ditches (SWMU 15) was documented at the time of the VSI. Therefore, temporary runon and runoff controls for the coal pile storage area and increased impoundment capacity may be warranted to prevent discharge to adjacent surface waters. Sampling of this unit's sediments in the retention impoundment itself and in the streams it discharges are also suggested.

The integrity of the Area Of Concern "A" could not be determined during the VSI due to the in-ground and below-ground location of the unit. No testing has been done on the tanks and there have been no reports of releases from either system. However, due to the age of the units, 33 years, a determination and documentation of the integrity of the unit is suggested.

II. INTRODUCTION

The 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA authorize the Environmental Protection Agency (EPA) to require corrective action for releases of hazardous waste or hazardous constituents from solid waste management units (SWMUs) and other areas of concern (AOCs) at all operating, closed, or closing RCRA facilities. The intent of this authority is to address previously unregulated releases to air, surface water, soil, and groundwater, and from the generation of subsurface gas. The first phase of the corrective action program as established by EPA is performance of a RCRA Facility Assessment (RFA). The RFA includes a Preliminary Review (PR) of available and relevant documents, a Visual Site Inspection (VSI), and, if appropriate, a Sampling Visit (SV).

This report summarizes the results of the PR and VSI phases of the RFA for the Southwestern Portland Cement Company Quarry Plant (SPCC) in Fairborn, Ohio. The findings in the report are based on a review of the file materials maintained at EPA Region V, and at the Ohio EPA including RCRA, Air, NPDES, CERCLA, non-RCRA Solid Waste, Enforcement, and Groundwater files, and a Visual Site Inspection (VSI) conducted on February 12, 1990.

Section III discusses the facility location and surrounding land use, history of ownership, process description, waste management operations, regulatory history, environmental setting, and potential receptors. The discussion of the facility's environmental setting includes climate and meteorology, flood plain and surface waters, soils and geology, and groundwater. A description of the SWMUs at the facility, including conclusions regarding the release potentials for each unit are discussed in Section IV. Suggestions for further actions are given in Section V. References used to prepare this report are listed in Section VI. The VSI Summary and Photograph Log are included as Attachments A and B, respectively.

III. GENERAL DESCRIPTION

A. FACILITY HISTORY AND DESCRIPTION

The SPCC Plant is contained on approximately 588 acres located in Bath and Xenia Townships, Greene County, Ohio, Sections 12 and 6, Township 3, Range 7, and bounded by State Route 235 to the east, Dayton-Yellow Springs Road to the North, Linebaugh Road to the west and section lines to the south. Actual affected area within these bounds is approximately 183 acres (Reference 57). Figure III-1 presents the vicinity map of the facility. The coordinates of the facility are N 39 degrees 46 minutes 37 seconds latitude, W 83 degrees 57 minutes 59 seconds longitude.

The land used by the facility was purchased from local farmers in the 1940's and 1950's by the SPCC. Prior to this purchase, the land was rural and was used intermittently as farmland and pastures. In the early 1950's, the SPCC began surface mining operations, which continue at this time. In 1972, the SPCC began the construction of a facility with a the dry process cement clinker producing system. Production of clinker was begun in 1974. The SPCC currently owns and operates the quarry and the cement clinker facility. (Reference 42)

The facility employs 40 people in its operations. The facility consists of a total of 9 manufacturing and ancillary buildings, 4 material handling areas, and one process water holding pond as shown in the facility layout map in Figure III-2. The manufacturing buildings include the burner building, the rotary kiln, the alkali bypass system, the preheater tower, and three baghouses. The material handling areas include the quarrying, storage, milling, and transport of clay, limestone, and coal, raw materials for the process, and a storage area for the produced clinker. Ancillary buildings and areas include the HWF unloading and storage area, maintenance buildings, a storage building for the HWF samples, and the rail car facilities for the transporting of the produced clinker. (Reference 42)

B. PROCESS DESCRIPTION

The SPCC facility began manufacturing the clinker used to make hydraulic portland cements in 1974. The raw materials for the process includes limestone, the primary raw material, which is extracted from nearby open quarry pits, and argillaceous material (clay and shale) and small amounts of silica and iron scale. The raw materials are crushed and transported by conveyors to the raw mill. The raw mill grinds the materials to the consistency of face powder, which is the raw mix for the kiln. The raw mix is checked every five minutes by an X-ray analyzer for 11 different compounds. This data is relayed to a computer which automaticlly changes proportioning of raw materials to assure a constant end product. The pulverized materials are pumped to the top of the 225 foot high preheater tower. Passing through the preheater, the feed mixes with hot exhaust gases from the kiln and rises in temperature to approximately 1500 ^oF before entering the kiln. The kiln is 220 ft long and 15 feet in diameter. Fuels, primarily powdered coal, are fed continuously into the kiln to heat the material to 2700 ^oF which is very close to their melting point and converts the mixture to clinker. The kiln is sloped at about 1/2 inch per foot and turns at about 100 revolutions an hour. The kiln is protected by over 56,000 fire bricks which protect its shell. The hot clinker drips onto a moving perforated grate (reciprocating grate cooler) where it is cooled to 250 ^o F by air blowing up between the hot pieces of clinker. The clinker is moved from the cooler by drag conveyors to elevators to a belt conveyor which places clinker in the clinker storage structure. Clinker is reclaimed from storage by belt conveyors for shipment to grinding facilities located at the Main Plant located in Fairborn (Reference 42). The air emissions exhaust streams from these processes are filtered through three baghouses, which manage kiln dust, alkali dust (SWMU 17), and clinker dust.

The cement kiln is periodically shut down for maintenance and replacement of the fire bricks which lines its shell. In order to restart the kiln, fuel oil from a storage tank located north of the kiln is used to restart the burner furnace in the burner building.

The facility uses water from the Process Water Holding Pond for contact cooling to stabilize temperatures of the raw materials in the preheater tower, and for non-contact cooling in the water/glycol plant coolant system and the air conditioning systems in the burner building and the laboratory. The glycol used for the plant coolant systems is stored in a 10,000 gallon steel underground tank. This system contains an anti-freeze solution of a 50-50 mix of deionized water and ethylene glycol. The tank was installed in 1974 during plant construction. On September 28, 1988, a puncture near the top of this tank was discovered and repaired. The coolant that had leaked along with the clay contaminated with the coolant was burned in the kiln. The incident was reported to the Ohio EPA.

There are two underground 7,800 gallon steel tanks for diesel fuel at the Quarry Garage. The tanks were installed in 1957 and are registered with the Ohio EPA. Two aboveground diesel fuel tanks near the waste tire conveyors were identified at the time of the VSI for filling facility equipment. Temporary clay berms were constructed around each of these tanks at the time of the VSI.

The maintenance building is used to store critical repair parts such as the kiln and raw mill reducers, I.D. fan motors, an coal mill and raw mill roll assemblies. In the brick storage area of the maintenance building refractory related materials such as brick, low cement castable, stainless steel needles, shims, kiln forms, and brick laying equipment (table and ring) are stored. In the lubrication room of the maintenance building, new oil needed for plant equipment lubrication/operation is stored. Grease drums, 55 gallon oil drums and filters for all systems are maintained. Empty drums are returned to the vendors for credit. Two parts washers containing Safety-Kleen solvents are used inthis area.

In the shop building, the maintenance office, bathroom facilities, work areas, spare parts bins, tool boxes, and the HWF supply cabinet are maintained. The HWF cabinet contains spark resistant tools, respirators, and other safety equipment ( boots, rubber suits, rubber gloves, etc.).

The quarry garage houses the foreman's office, the clocking station for the hourly work force, and space for one 1/2 ton vehicle. Vehicle fluids such as engine lubricating oils and hydraulic oils are stored in the garage for topping off vehicle reservoirs as required. Vehicle fluid changes are not performed and the garage is not equipped for vehicle maintenance and repair.

In 1986 the facility began burning Hazardous Waste Fuels (HWF) along with coal in its kiln. The hazardous waste fuels (HWF) burned at the facility are derived from waste spent solvents generated by the automotive, painting, coating, pharmaceutical, and ink industries. In addition, oils used in various lubrication applications and other select combustible wastes are burned (Reference 1). HWFs managed at SPCC are supplied by commercial contractors. SPCC does not blend HWFs at their facility. HWFs have been primarily supplied by CWM Resource Recovery of West Carrollton, Ohio, (originally Solvent Resource Recovery (SRR)). In September 1989, Petro-Chem Processing of Detroit began delivering fuel to SPCC. Recently, SPCC has received a truckload from CECOS International of Cincinnati, Ohio. The HWF are burned with coal to provide the energy required for the clinker-producing process.

The HWF is delivered to the facility in truck tankers and unloaded at the HWF Truck Unloading Area (SWMU 1), filtered at the HWF Filtrate Shed (SWMU 2), and stored in one of four HWF Storage Tanks (SWMUs 3, 4, 5, and 6). The HWF is fed to the Burner Building/Kiln Floor (SWMU 8) via aboveground pipelines and mixed with the coal from the Outdoor Coal Storage Area in the burner building furnace.

Each truck tanker load of HWF is sampled and the samples are stored in the HWF Sample Storage Area (SWMU 13). Each sample is tested in the facility's laboratory to check the composition of the fuel delivered. The laboratory is also used for analyzing samples of the raw materials and the product "clinker".

Since startup of HWF facilites some on-site remediation measures have been necessary to minimize expansion in the lines and drippage. Pump seals that use centrifugal force to seal (Allis-Chalmers double dynamic seals) were installed to eliminate drippage. Special seals for agitators developed by Henry Sturn Co. have been installed on all HWF storage tanks. All gaskets are now teflon stainless steel that are impervious to solvents. Pressure relief valves in HWF inlet piping were installed to eliminate breakage due to expansion.

In 1989, the facility began burning waste tires in its kiln. The tires are used as both a fuel, due to their petrochemical content, and a raw material, due to their steel content. The tires are fed into the kiln by belt conveyors.

C. WASTE GENERATION AND MANAGEMENT

A variety of both hazardous and nonhazardous wastes are generated and stored at the facility. Hazardous wastes which SPCC is permitted to manage include HWFs derived from F001, F002, F003, F005, D001 and K and U wastes listed in Table III-3 (Reference 12). Nonhazardous wastes include municipal wastes, plant sewage, landfill wastes, spent Safety-kleen solvents, alkali bypass dust, and metal scrap and trimmings.

The SPCC facility sets a minimum heat content specification for the HWF accepted, at 8000 BTUs/lb. The specifications for the hazardous waste fuels burned at the facility are given in Table III-2 (Reference 42). The State air permit for the kiln stipulates that the kiln will use fuel with a minimum heat content of 10,000 BTUs/lb. The facilty achieves the 10,000 BTU minimum by mixing the HWF with coal. The coal has a sufficiently high enough heat content to insure that the 10,000 BTU minimum requirement in the air permit is achieved if HWFs are lower. However, the average BTU/lb content of HWF for 1990 was 103,614 BTUs/lb (Reference 58).

The hazardous wastes listed in Table III-3 are stored in the four 30,000 gallon tanks (SWMUs 3,4,5,and 6). The facility has been increasing the quantity of HWF burned in the burner/kiln since its initial use in 1986. Presently, the facility burns less than 356,000 gallons of HWF per month. An annual summary of the quantities of HWF received is as follows (Reference 42):

Quantity

Year (Gallons)

1986 1,672,857

1987 1,316,912

1988 3,641,685

1989 4,266,842

The remaining hazardous wastes are generated from spills, filtrate, and drips which accumulate from these storage tanks. The filtrate located in the HWF Filtrate Shed (SWMU 2) is periodically removed and placed in the Roura Hoppers (SWMU 10) along with dust from the kiln. The filtrate includes materials such as dirt, iron particles, glass particles, and hardened paint. The solid waste fuel is then placed in the Outdoor Clay Storage Conveyor (SWMU 7) and reprocessed through the kiln. Typically, no more than 200 pounds of filtrate are generated per month. Spills which may occur as the HWF is being unloaded, are either cleaned up with kiln dust which is placed in the Roura hoppers (SWMU 10) or pumped into one of the HWF tanks (SWMUs 3, 4, 5, and 6). HWF sample bottles which are stored in the HWF Sample Storage Cabinet (SWMU 13) including the 8-oz glass containers are also reprocessed into the kiln for heat recovery.

Municipal wastes include paper, cardboard, and typical office wastes, spent grease cartridges, and oil filters. Municipal wastes are stored in dumpsters (SWMU 11) located around the facility. Spent grease cartridges and oil filters are generated from the maintenance building/lubrication room. A commercial disposal firm removes the

Table III-1

List of Part A Permit Wastes

D - Wastes F - Wastes

D001 F001

D005 F002

D006 F003

D007 F004

D008 F005

K - Wastes U - Wastes

K022 U001

K048 U002

K049 U003

K052 U019

K085 U031

K086 U037

K095 U038

K096 U211

Table III-2

Specifications for Hazardous Waste Fuels (HWFs)

Heat Content 8,000 BTU per pound minimum

Sulfur 3 Percent Maximum

Halogens 5 Percent Maximum

Organic Acids and Bases Extractable pH between

4 and 11

Metals:

Arsenic 3000 ppm Maximum

Cadmium 3000 ppm Maximum

Nickel 3000 ppm Maximum

Zinc 3000 ppm Maximum

Chromium 3000 ppm Maximum

Barium 3000 ppm Maximum

Lead 4000 ppm Maximum

PCB Less than 50 ppm

Benzene Less than 0.5 percent

by weight

wastes from the dumpsters for disposal at the Tremont City Landfill. The three four-cubic yard dumpsters are emptied once a week. (Reference 42 and 43)

Plant sewage is collected in two interconnected 2,000 gallon concrete underground tanks. The contents of these tanks are periodically pumped and disposed at the local POTW.

The Landfill (SWMU 14) managed during four years from 1974 and 1978, scrap cement clinker, wood, fiberboard, paper shipping containers, used tires, rubber belting, construction and demolition materials and scrap metal. In addition, kiln dust slurry was applied for fugitive dust control. Currently, only materials from construction and demolition operations and sediment which accumulates in the Stormwater Retention Impoundment\Silt Fence (SWMU 15) are placed in the landfill (Reference 42).

Spent Safety-Kleen Corp. solvents are generated from the two units (SWMU 12) located around the maintenance building for degreasing tools. Safety-Kleen Corporation periodically removes the spent solvent and recharges these units.

Alkali bypass dust is collected in the Alkali Bypass Baghouse (SWMU 17) from which it is sold commercially to an independent corporation which markets the dust as a replacement for burned lime in coal mine acid water drainage treatment plants, to solidify sludge impoundments, and for soil stabilization in bases for construction projects such as highways. The remaining dusts collected in the kiln and clinker baghouses are recycled back into the process. They are transported in Roura Hoppers (SWMU 10) to the Outdoor Clay Storage Conveyor (SWMU 7) and reprocessed into the Cement Kiln (SWMU 9) (Reference 43).

Metal scrap such as conduit and small pieces of metal from trimming fitted pieces are generated in the Shop Building. Scrap metal is sold and hauled away by metal dealers.

According to plant personnel, the chief chemist will, through his knowledge of the process that generated the waste, determine if the waste is restricted from disposal in a landfill and note such in his lab HWF operating file (Reference 42).

D. Regulatory History

The Southwestern Portland Cement Company has been subject to both regulation for control of air releases, and management of hazardous waste. Currently, SPCC is not regulated under NPDES, TSCA, or CERCLA based on the file review. The RCRA file obtained from the OEPA and Region offices begin in 1982 and document regulatory activity through January 1990. Air files document regulatory activity from 1973 to 1989.

D.1 RCRA

At the present time, the act of burning for energy recovery is exempt from regulation. However, activities that take place prior to or after burning are regulated. To qualify as legitimate heat recovery, wastes must have a heating value of more than 5000 btu/lb. The history of RCRA regulatory compliance at SPCC as derived from the file material is summarized below:

In December 1981, Southwestern Portland Cement Company submitted an application for an air discharge permit to install storage tanks and equipment for burning waste organic solvents in its cement kiln. On July 5, 1985, Ohio EPA issued Permit-to-Install (PTI) number 08-775 to Southwestern. On this same day, USEPA Region V and Ohio EPA, Division of Solid and Hazardous Waste Management received Southwestern's Part A permit application for a hazardous waste permit for 130,000 gallons of storage capacity for USEPA hazardous waste numbers F001, F003, and F005. By letter of October 4, 1985, Region V advised that Southwestern's waste-as-fuel activity was such that burning and storage of such fuels was currently unregulated. The Part A permit application was subsequently returned to Southwestern on November 8, 1985.

At the time the Permit-to-Install (PTI) was issued, hazardous waste requirements (59 CFR 49168) were in effect that prohibited the use of F002 still bottoms and D001 characteristic wastes without a hazardous waste incineration permit. Ohio rules adopted January 30, 1986, contained similar language (Reference 17). Southwestern, as a result, neither received nor burned F002 still bottoms or D001 characteristic wastes while operating under this PTI.

However, on November 29, 1985, the USEPA published its final ruling for Burning of Waste Fuel and Used Oil Fuel in Boilers and Industrial Furnaces at 50 FR 49164. These regulations removed exemptions so that transportation, storage and other controls apply to all waste-as-fuel activities. In addition exemptions for D001 and F002 wastes were removed under this ruling. SPCC requested clarification of the revised rulings. In conformance with the final ruling Southwestern renotified Region V of waste-as-fuel activity on January 28, 1986 and resubmitted a Part A permit application on May 13, 1986 for USEPA hazardous waste number D001, F001, F002, F003, and F005. The OEPA granted SPCC permission to burn these listed wastes as fuel. On December 1, 1987, the Part A was revised and resubmitted for the USEPA hazardous waste numbers listed in Table III-3 to the USEPA Region V and Ohio EPA to itemize individual components contained within hazardous waste fuel ingreater specificity than the characteristic and non-specific source numbers appearing in the original submission. The new Part A permit submitted in January, 1990 includes additional source numbers which SPCC would like to be permitted for which are expected to meet the minimum BTU/lb criterion mentioned previously. Storage facilities for an additional 172,800 gallons of solid HWFs and Hazardous waste rail car unloading facilities are proposed for construction. Visual inspection of these proposed facilities was not performed because they had not been constructed at the time of the VSI.

The files documented several inspections for compliance with hazardous waste management regulations and land disposal requirements. The hazardous waste management regulations inspections each noted a number of violations, though all were administrative or record-keeping violations. The land disposal requirements inspections indicated that the facility is in compliance with the land disposal requirements found at 40 CFR Part 268 (Reference 3). Southwestern's regulatory history is summarized below.

D.2 Air Pollution Controls

The documented record for regulatory activity concerning control of air releases is substantial. Because the facility uses a dry process as opposed to a wet process, air pollution control equipment is required throughout the process. Currently, seven separate permits-to-operate (PTO) have been issued for various processing units. The PTOs cover particulate matter (dust) control equipment, baghouses for the rock and coal crushers, conveyors, clinker load out, and blending operations at the facility and the baghouses for the kiln, the alkali bypass, and clinker cooler units. One of the units, the Clinker Storage Area, is awaiting permit renewal. Because the raw materials are normally dry and powdery, fugitive emissions have been an on-going problem at this area. To solve this problem, facility representatives have submitted a timetable for constructing silos to replace the existing clinker storage structure.

The most recent PTO for the kiln (October 1987, No 08-1411) stipulates a 4 lb/hr limit on Hydrogen Chloride (HCl) emissions (Reference 46). This standard is a result of the USEPA proposed regulations of May 7, 1987 which set national emission standards for toxic organics, heavy metals, and hydrogen chloride (HCl). The facility is currently contesting this standard in an appeal to Ohio's Environmental Board of Review (EBR).

Stack testing, conducted in 1986 under Ohio EPA oversight to demonstrate compliance with permit conditions, produced average destruction efficiency (DRE) of 99.997 percent for principal organic hazardous constituents (POCH'S). This was based on use of perchloroethylene (tetrachloroethylene), an extremely hard to burn compound, as a surrogate.

According to Ohio EPA staff, the SPCC facility has not been issued any citations for violations of their air permits (Reference 53).

E. Environmental Setting

E.1. Location and Surrounding Land Use

The SPCC Quarry Plant is located southwest of the intersection of State Route 235 and Dayton-Yellow Springs Road (Section 12, Town 3, Range 7) in the Bath Township, Greene County, Ohio, approximately three and one-half miles south southeast of Fairborn, Ohio and five miles east of Dayton, Ohio. The coordinates of the facility are N 39 degrees 46 minutes 37 seconds latitude, W 83 degrees 57 minutes 59 seconds longitude. The facility occupies 250 acres in a rural setting. An active quarry has occupied parts of the facility's grounds since the early 1950's. The present facility was built in 1974. Before the quarry was opened in the early 1950's, the area was intermittently used for farmland. The facility is presently surrounded by rural land which has been used intermittently as farmland. Ludlow Creek flows along the southeastern corner of the facility. The facility is located 1 mile from the closest town, Byron, and the closest residences are 1/2 mile from the property line. (References 42 and 43)

E.2. Climate and Meteorology

Dayton, Ohio is the closest weather station to the SPCC facility. The climate of this area is a humid, temperate, continental type, characterized by moderate extremes of heat and cold, wetness and dryness. The average annual temperature is 52.3 degrees F. Summers are moderately warm and humid with an average daily temperature in July of 75.1 degrees F. The highest temperature of 102 degrees F. was recorded in July 1939. (Reference 54)

Winters are cold, with temperatures below zero recorded almost every year. The average daily temperature in January is 28.3 degrees F. The lowest temperature of -21 degrees F. was reached in December 1935. (Reference 54)

Annual precipitation in the Dayton area averages slightly over 36 inches and is evenly received during the year. Snowfall averages slightly over 28 inches each year with heavy accumulations during January. (Reference 54)

The average date in the spring of the last occurrence of frost is April 19 and the average date of the first occurrence of frost is October 26. The area is influenced by cold polar air masses during the winter and hot humid air masses from the Gulf of Mexico during the summer. The area can be affected by severe weather conditions such as hurricanes, thunderstorms, and tornados. Of the three conditions, the most frequently experienced condition is summertime thunderstorms (Reference 54).

The predominate wind direction is from the south to southwest quadrant and wind speeds average 10 miles per hour. A wind rose for the Dayton, Ohio area is given in Figure III-3. (Reference 54)

E.3. Topography and Surface Drainage

The Southwestern Portland Cement Company (SPCC) Quarry Plant is located in the western part of Greene County, Ohio which shows more prominent relief than the eastern part. The soils are generally gently sloping to steep. Little Miami River, the main river in the county, and Mad River, which cuts through the northwest corner, flow southwestward to drain this part of the county. These rivers and their tributaries are deeply entrenched in glacial drift. This is particularly true of Little Miami River because its downcutting has produced limestone gorges and deeply cut tributaries. Such dissection by the streams in this part of the county has contributed to removal of water from the land, resulting in the formation of a relatively higher percentage of soils that are well drained or moderately well drained (References 44 and 49). The elevation of the present valley floors range from 800 to 850 feet above sea level. Elevations in the uplands range from 950 to 1000 feet (Reference 44).

Site specific information from a soiil and foundation report prepared by Site Engineers in September, 1972 (Reference 41) verifies the above stratigraphy. The report describes the site conditions prior to construction of the cement operations. The cement operations were situated on a quarry floor except for some thin earth fills used for site grading and outdoor storage structure embankments. The results of test borings taken on the quarry floor and of the stockpile soils are summarized below. Test borings were drilled to a depth of 20-35 ft for quarry floor samples.

The site is in an area of nearly flaat lying Silurian and Ordovician rocks. The geologic profile at the quarry site is about 2 ft of Dayton limestone below soil overburden, then about 30 feet of Brassfield limestone, and finally a very thick bed of Richmond shale. The Dayton and about 20 to 25 feet of the Brassfield limestone have been removed by the quarrying operations, leaving about 10 feet of the Brassfield limestone on the quarry bottom. Test borings verified this profile with the exception that a 1 to 4 foot zone of transitional dolomitic limestone was found between the Brassfield and Richmond formations. The lithology and physical characteristics of the samples taken in the quarry are as follows:

Brassfield Limestone - Pinkish-white, crystalline, hard, compact, massive limestone with solution pits and small cavities, slightly weathered and highly fractured; at places porous.

Dolomitic Limestone (Transitional) - Gray, medium hard, compact, dense, some small solution pits, pockets and partings of shale, slightly to moderately weathered with some small solution pits and moderately fractured.

Richmond Shale (Calcareous) - Gray to bluish-gray, silty, medium hard, softer at depth, compact, intercalations of limestone, slightly weathered and moderately to sparsely jointed.

The Brassfield limestone varied in tthickness from 5 1/2 to 13 feet but was generally between 9 to 11 feet thick. It was generally highly fractured and jointed with the greatest amount of fracturing found in the 2 to 3 foot surface. The middle zones were more competent while the lower zone were accompanied by rapid movement in the core barrel. The lower zone of seams and fracturing indicated the presence of solution cavities and geological strain discontinuities at the limestone-shale interface.

The transitional stratum varied in tthickness from 1 to 4 feet but was generally between 2 and 2 1/2 feet thick. The limestone changes to gray in color and becomes more dolomitic in character with some shale partings. Generally it is moderately fractured and jointed, mostly along the weaker shale parkings.

The depth to the Richmond shale straatum varied from 9 to 15 feet but was generally between 11 to 13 feet below the ground surface. This rock is a silty shale with thin intercalations of limestone. Its hardness depends on its degree of calcareous cementation. The upper 5 to 15 feet is silty and is well bonded by calcareous cementation. The upper zone of this formation is quite competent and does not have the appearance of a true shale. Fractures and jointing is much less prevalent than in the overlying limestone strata. Most fractures are horizontal and occur at the shaley partings. Thin clay seams were noted in a few borings in the upper part of the shale and are apparently not continuous over the site.

E.5. Groundwater

The geologic units of the Fairborn aarea may be divided into two groups on the basis of their influence on the occurrence and movement of ground water: Ordovician and Silurian consolidated rocks consisting of limestone, dolomite, and shale; and unconsolidated deposits consisting of Pleistocene glacial and Recent alluvial deposits. The stratrigraphy at SPCC consists of about ten feet of Brassfield Limestone followed by Richmond Shale. The Brassfield Limestone is apparently the most important consolidated-rock aquifer in the area (Reference 56). Water occurs along bedding planes and in fracture openings. Openings enlarged by solution are the principal conduits through which water moves to wells. Wells generally yield 5-15 gpm after penetrating rock to a depth of 25 feet. An important spring horizon is reference to be found at the base of the system between the Brassfield limestone and the Richmond shale. The Richmond Shale is generally not water yielding. Few wells yield more than 1 gpm and many go dry. The uppermost few feet of the formation usually contains water-bearing openings. This corresponds with the transitional section described in the Soils and Geology section (Reference 56). In addition, the location of a spring at the southeast corner adjacent to Ludlow Creek would appear to characterize this type of formation.

Site-specific hydrogeology is summarrized from the soil and foundation report prepared by Site Engineers in September, 1972 (Reference 41). Groundwater level was measured upon completion of all borings. The data represent groundwater levels for the period observed from July 19 to August 1, 1972. The groundwater level varied from 7 to 12 feet below the ground surface but generally were at 9 to 10 feet depths. These depths corresponded with the base of the first stratum or Brassfield Limestone.

E.6. Release Pathways

Release Pathways for all environmenttal medial are summarized as follows:

Potential for Release to Soil/Groundwater - If hazardous wastes or constituents were landfilled or spilled onto unprotected soils, the potential for release to groundwater is high due to the removal of the natural protective covering from quarrying and the relatively open and jointed nature of the rock and shallow water table. The potential of the HWF's managed at the facility coming into contact with unprotected ground is generally dependent on the integrity of the SWMU's. The potential of HWF's releasing to soil/ groundwater is low due to the release controls installed at the facility for containment of HWFs. If an accidental spill were occur on unprotected ground, management of the spill would be difficult, given that the ditches are unlined on top of limestone and would therefore likely seep into the ground. Based on EP Toxicity and TCLP tests there is no potential for leaching heavy metals from kiln dust. Due to the uncertain nature of the

Surface Water - Conveyance of stormwater runoff from the Stormwater Retention Impoundment/Silt Fence (SWMU 15) by collection ditches to Ludlow Creek occurred at the time of the VSI. Generally, retention/management of stormwater runoff is inadequate at the site. Leachate from the Outdoor Coal Storage Area (AOC E) and the Clinker Storage Area discharge to Ludlow Creek either through groundwater or as runoff when the existing capacity of the impoundment is exceeded, as was the case at the VSI.

Air - The potential for release to air is low duue to the facility's current air pollution control program.

Subsurface Gas Generation - HWF facilities have a low potential for the generation of subsurface gases due to the dilute concentrations of organic constituents and aboveground construction. The Landfill (SWMU 14) has a low to moderate potential for generation of subsurface gases based on the organic content of wastes managed.

E.7.> Receptors

The facility is located in a mixed-uuse area dominantly farming with some residential areas. There are several houses within a mile radius of the SPCC Quarry Plant. No schools, restaurants, or churches are known to be within a one-mile radius of the facility. Ludlow Creek is classified as a Warm Water Habitat and therefore is a receptor (Reference 47). Chemical and biological criteria of the Ohio NPDES program are required to be met for the use classification it has been given (Reference 47).

In Greene County, the larger towns aand cities are served by public water supplies. The water supplies for these systems is mostly from wells that penetrate aquifers formed in deep pre-glacial valleys that are filled with coarse textural glacial drift. Pumping is concentrated at Dayton, Middleton, Hamilton, and Venice and is relatively light elsewhere (Reference 56). Some springs in the area provide water for livestock. Few streams provide water for domestic consumption (Reference 44). Water in recharged by the percolation of precipitation to the water table, by the induced infiltration of surface water from the streams, and by subsurface flow from buried valley walls. The potential yield of the aquifer is governed primarily by the amount of recharge received from streamflow.

A potable drinking water well is loccated on-site adjacent to the Stormwater Retention Impoundment/Silt Fence (SWMU 15).

IV. SOLID WASTE MANAGEMENT UNITS (SWMUs) AND AREAS OF CONCERN (AOCs)

This section presents detailed descrriptions and release assessments of each solid waste management unit identified during the PR and VSI. The descriptions encompass physical and functional characteristics, dates of operation, wastes managed and release controls. The release assessments encompass history of releases and conclusions regarding the release potential to soil/groundwater, surface water, air, and the potential to generate subsurface gas. Table IV-1 lists Solid Waste Management Units (SWMUs) and Areas of Concern (AOC) and their corresponding photo numbers taken at the time of the VSI. The locations of the SWMUs and AOCs are presented in Figure IV-1.

Table IV-1

Directory of Photos by SWMUs and AOCs

No. SWMU Description Photo

1. HWF Truck Unloading Area 16,17,18,24

2. HWF Filtrate Shed 18,22

3. HWF Storage Tank No. 1 21

and Ancillary Piping

4. HWF Storage Tank No. 2 19,20

5. HWF Storage Tank No. 3 19,20

6. HWF Storage Tank No. 4 19,20,23

7. Outdoor Clay Storage Conveyor 28

and Ancillary Equipment

8. Burner Bldg/Kiln Floor 10,14

9. Cement Kiln 10,32

10. Roura Hoppers (3 ea.) 17,24

11. Dumpsters (3 ea.) 13,29

12. Safety-Kleen Units (2 ea.) 25

13. HWF Sample Storage Cabinet 35

14. Landfill None

15. Stormwater Retention Impoundment/ 6,7,8

Silt Fence and Collection Ditches

16. Waste Tire Staging Area 34

17. Alkali Bypass Baghouse 11,32

Letter Areas of Concern

A. Quarry Garage Diesel Fuel Tanks (2 each) 1

SWMU 1 HWF Truck Unloading Area (Photos 16,17,18,24)

Unit Description: This unit is located next to the HWF Storage Tanks (SWMUs 3, 4, 5, and 6) and is used for the transfer of the HWF from truck tankers to the storage tanks. It consists of a concrete pad 13.5 feet width by 78 feet long, tapered towards the center and covered by a roof. The pad is 8 inches thick consisting of Type K reinforced concrete and was observed to be in good condition at the time of the VSI. An average of three truckloads of liquid hazardous waste fuels is unloaded each day. The average truckload contains 5400 gallons of fuel. The hazardous waste fuels are pumped through a filtering system (SWMU 2) into one of the four HWF storage tanks. Samples of each truckload of hazardous waste fuels are taken and stored in SWMU 13. During the VSI a tanker truck was being unloaded. The HWF tanks are equipped with a vapor recovery system which returns the displaced vapors in the tank being loaded into the truck tanker.

Dates of operation: This unit has been in operation since 1986.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42).

Release Controls: This unit is tapered from both sides to a 2 inch depth at the centerline. Spilled materials are absorbed with kiln dust stored in covered cans and the collected material is placed in the Roura hoppers (SWMU 10). The unloading process is observed by at least two people and fittings are checked before unloading proceeds. The HWF tanks are equipped with vapor recovery systems which return the displaced vapor from the tank being loaded to the tanker being unloaded.

History of Releases: Spills of hazardous waste fuels from this unit are summarized in Table IV-2 (Reference 42). None of the spills resulted in contamination of the surrounding soil, drainage ditches, or water ways. All of the spilled material was collected using kiln dust and placed in a Roura hopper.

Conclusions: Soil/Groundwater - The potential for release to the soil and groundwater is low due to the design and construction of the concrete slab in this unit which forms a containment area and the unloading procedures used.

Table IV-2

History of HWF Releases

from Truck Unloading Area (SWMU 1)

Volume

Date (gallons) Cause of Spill

-----------------------------------------------------------

9/20/86 75 The truck pump suction fitting and pressure fitting were reversed when assembled by the truckline.

11/18/86 20 Fuel filter plugged causing hose to burst.

11/20/89 10 Truck driver removed hose from tanker with lines open to fill tanks.

12/08/89 1 While an employee was replacing a 3 inch gate valve, heavy sludge in line dripped into a bucket. Some of this material spilled on the floor.

Surface Water - The potential for release to surface water is low due to the design and construction of the concrete slab in this unit which forms a containment area and the unloading procedures used.

Air - The potential for release to the air is loow due to the vapor recovery system utilized during the unloading process.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the unit above ground.

References: 1,42,43

SWMU 2 HWF Filtrate Shed and Ancillary Equipment (Photos 18,22)

Description: The Hazardous Waste Fuel (HWF) Filtrate Shed and Ancillary Equipment is adjacent and contiguous to the HWF Truck Unloading Area (SWMU 1). The filtrate shed houses the filter and collection system piping which supply the four HWF Storage Tanks (SWMUs 3,4,5 and 6). Liquid waste solvents from an off-site supplier is pumped through the filter system to remove particulates which can clog process piping. The pumping rate through the filter is 200 gpm.

The filtrate collection system is reportedly disassembled about once a month based on current delivery schedules and solids content of HWF. If truck deliveries are found to have high solids contents, they are rejected. Filtrate material is emptied into 5 gallon aluminum pails filled with kiln dust, an adsorbent. These pails are then picked up by plant vehicles and disposed of by putting them on the feed shelf of the Cement Kiln (SWMU 9).

The filter and ancillary equipment appeared in good condition at the time of the VSI.

Dates of Operation: This unit has been operation since 1986.

Wastes Managed: The filtrate shed manages hazardous waste fuels containing any of wastes listed in Table III-3 (Reference 42). Particulates which are retained onto the filter from the HWF include iron, particles, paint particles, broken glass, and soil. Under current delivery schedules, no more than 200 lbs of filtrate material is generated in a month.

Release Controls: Five gallon pails are placed within 20 gallon aluminum trash cans under the two pressure relief valves. This double containment is placed to contain excessive leakage which could occur if a delivery with excessively high particulate content were received. The shed rests on a concrete floor.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release because the filter piping is above ground and situated on a concrete pad which acts as barrier to the soil and/or groundwater.

Surface Water - There is low potential for release to surface water due to the distance from surface water.

Air - There is low potential for release to air due to the small volume of waste exposed to the air at any point in time.

Subsurface Gas - Thhere is low potential for the generation of subsurface gas due to the location of the unit above ground and over a concrete pad.

References: 1,42,43

SWMU 3 HWF Storage Tank No. 1 and Ancillary Piping (Photo 21)

Unit Description: This unit consists of one 30,000 gallon steel tank and the piping that transfers the HWF to the burner building (SWMU 8). The aboveground piping to the burner building can be fed by either this tank or one of the other three tanks used to store HWFs (SWMUs 4, 5, and 6). This unit is located approximately 100 yards northeast of the kiln (SWMU 9). The tank used to store the HWF received from the truck tankers unloaded in SWMU 1, is located in a clay containment berm. The tank is 12 feet in diameter and 35 feet high.

The tank, surrounding containment area, and release controls were observed to be in good condition at the time of the VSI. This tank is a RCRA regulated unit. No leaks were observed at the time of the VSI.

Dates of operation: This unit has been in operation since 1986.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42).

Release Controls: The containment area is an inverted frustrum of a pyramid 6.5 feet high by 43 feet at the top. The walls are clay with a 50 mil polyvinyl chloride (PVC) barrier on top of the clay with 6-inch crushed rock over the PVC. The bottom of the containment area is made of 8-inch thick concrete with a 10-inch thick circular concrete slab directly under the tank.

Expansion controlled Type K concrete is used throughout the structure to prevent cracks and leakage through the concrete.

The slab under the tank has 3-inch deep by 2-inch wide grooves cast in the concrete radially at 45-degree angles. These grooves afford a method of inspecting the condition of the tank bottom.

An ultrasound transducer is installed in this tank. The transducer is set to alarm at two stages during fill operations: one when liquid is 5 feet from the top of the tank and when liquid is 1.5 feet from the top of the tank.

There is a transducer installed in the containment area with a setpoint of 6 inches at which an alarm is sounded.

The tank is equipped with a pressure-relief valving and any liquid released through these valves are collected in 30-gallon containers and the collected material is pumped into one of the other three HWF tanks.

The tank is equipped with an agitator to maintain a homogeneous mixture in the tank. Located under the agitator is a 5-gallon bucket with a lid to capture any material which might leak from the seals of the agitator. Any material collected is pumped back into one of the HWF tanks as soon as possible.

The tank is equipped with a vapor-recovery system to pump displaced vapors from the tanks into a tanker being unloaded.

The tank is equipped with fuel flow meters to indicate the quantity of fuel being loaded into the tank.

Spilled liquids are either pumped back into this tank or one of the other three HWF tanks or cleaned up using kiln dust stored in closed containers located in the truck unloading area (SWMU 1). The solid waste fuels are then stored in the Roura hoppers (SWMU 10) and reprocessed in the kiln for heat recovery.

History of Releases: There have been two releases from this unit. On 2/6/88 the tank ran over and 40 gallons of HWF were spilled. On 11/26/89, 1 - 2 gallons were spilled when a gasket split in the tank coupling to the HWF filter system (SWMU 2). On both occasions, the spilled HWF liquid was contained within the containment area surrounding the tank and did not reach the soil. The liquid was cleaned up using kiln dust as an absorbent and the dust was processed in the kiln.

Conclusions: Soil/Groundwater -The potential for release from the tank to the soil and groundwater is low due to units location on a concrete containment structure within the containment area. The potential for release from the aboveground piping to the soil is low due to the design and construction of the piping.

Surface Water -The potential for release from the tank to surface water is low due to containment of spills in the concrete containment structure within the containment area. The potential for release from the aboveground piping to the surface water is low due to the design and construction of the piping.

Air -The potential for release from the tank to the air is low due to the release controls installed, specifically the vapor recovery system. The potential for release from the aboveground piping to the air is low due to the design and construction of the piping.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the unit and the piping above ground and inside a concrete containment structure.

References:1,42,43

SWMUs 4,5, and 6 HWF Storage Tank Nos 2, 3, and 4 (Photos 19,20,23)

Unit Description: These units consist of three 30,000 gallon tanks and the associated piping that transfers the HWF to the coupler on the exit side of HWF Storage Tank No. 1 (SWMU 3). These units are immediately adjacent to SWMU 3. The three tanks, used to store the HWF received at the facility, are located in 50 foot diameter by 3' 3" high concrete containment area. Each tank is 12 feet in diameter and 35 feet high set on concrete.

The tanks, surrounding containment area, and release controls appeared to be in good condition at the time of the VSI. The three tanks are connected to HWF Storage Tank No. 1 (SWMU 1) by aboveground piping. The three tanks are RCRA regulated units.

Dates of operation: This unit has been in operation since March 1988. Tank life expectancy is 15 years each.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42).

Release Controls: All tank release controls are similar to Storage Tank No. 1 (SWMU 3) except for the containment area which is a different design. Stainless steel water stops are used in the joint between the concrete floor and the wall of the containment area.

History of Releases: There have been two releases from the tanks in this unit. On 4/18/88, 20 gallons of spent solvents were spilled when Tank No. 2 overflowed. On 12/27/89, 50 gallons of spent solvents were spilled from Tank No. 3 when a seal on the tank split open. On both occasions the HWF spill was contained within the secondary concrete containment area and did not reach the soil. The liquid was cleaned up with kiln dust which was processed in the kiln.

Conclusions: Soil/Groundwater -The potential for release to the soil and groundwater from the tanks and the piping is low due to units location on a concrete containment structure.

Surface Water -The potential for release to surface water from the tanks and the piping is low due to containment of spills in the concrete containment structure.

Air -The potential for release to the air from the tanks and the piping is low due to the release controls installed, specifically the vapor recovery system.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the units and associated piping above ground and inside a concrete containment structure.

References: 1,42,43

SWMU 7 Outdoor Clay Storage Conveyor and Ancillary Equipment (Photo 28)

Unit Description: This unit is comprised of all conveyors and ancillary equipment which feed from the Outdoor Clay Storage Area prior to the Cement Kiln (SWMU 9). The units are primarily used for conveyance of the raw materials to cement kiln. However, occasionally it is reported that these conveyance systems handle the solid waste fuels from the Roura Hoppers (SWMU 10). The solid waste fuels are dumped through Grizzlies (open grates) by front-end loaders where the material filters through to the clay conveyor system. All of these conveyor systems are above-ground and have rain covers. The material is transferred by conveyor to the clay crusher, a raw mill and finally the cement kiln.

Dates of operation: This unit has been in operation since facility start up in 1974. Use of this facility for conveyance of the Roura Hoppers solid waste fuels is unknown. Since HWF facilities were permitted in 1986, this unit could have handled HWF materials since that time.

Wastes Managed: This unit has the potential to manage any of the liquid hazardous fuel materials burned at the facility listed in Table III-3 (Reference 42).

Release Controls: Conveyors are covered. Dust collecting vent lines are also located along the conveyor system. Current air permits require the use of a baghouse to reduce particulate matter emissions from the conveyor.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - The potential for release to the soil and groundwater is low due to units location on a covered conveyor.

Surface Water -The potential for release to surface water is low due to units location on a covered conveyor and distance to surface water.

Air -The potential for release to the air is low due to units location being covered and because release of emissions to the air is regulated by the State air permit.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the unit above ground.

References: 1,42,43

SWMU 8 Burner Building/Kiln Floor (Photos 10,14)

Unit Description: This unit comprises the control flow panel and HWF injection line located on the kiln floor of the Burner Building. HWF is pumped from the HWF Storage Tank Nos 1,2,3 and 4 (SWMUs 3,4,5 and 6) to the kiln burner floor. Air pressure of up to 100 psi is used to inject the fuel through an aspirating nozzle into the Cement Kiln (SWMU 9). The flow control equipment/ valving is enclosed in a locked glass panel. The fuel lance is self-contained and concentric with the coal pipe where both coal and the HWF is injected simultaneously into the kiln. The HWF piping from the control panel to the coal pipe is a flexible, stainless steel line approximately 2" in diameter. The process rate is 12 to 14 gallons per minute.

Dates of operation: This unit has been in operation since 1986.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42).

Release Controls: Flow control valving is enclosed in a glass panel which is padlocked. Fuel is bypassed back to the HWF Storage Tanks (SWMUs 3,4,5, and 6) if pressure buildup occurs in the lines.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - The potential for release to the soil and groundwater is low due to the unit being located in a building on the second floor.

Surface Water - The potential for release to surface water is low due to the unit being located in a building on the second floor and its distance to surface water.

Air - The potential for release to the air is low due to the release controls installed, specifically the pressure relief system which recycles fuel back to the HWF Storage Tanks (SWMUs 3,4,5 and 6).

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the unit above ground.

References: 1,42,43

SWMU 9 Cement Kiln (Photos 10,32)

Unit Description: This is a manufacturing unit where clinker is produced. The clinker is subsequently ground up to make Portland cement. The kiln is 15 feet in diameter and 220 feet long extending on a 4 degree incline from the preheater tower on its northwestern end to the burner building (SWMU 8) on its southeastern end. The preheated raw materials enter the kiln from the upper end and are heated by the HWF/coal mixture fired in the burner building furnace. The kiln is made of a steel shell with a 9-inch thick refractory lining made of bricks. The capacity of the kiln is 1,144,920 tons of raw material per year and produces 655,368 tons of clinker per year. Based on stack testing, the kiln has an average destruction and removal efficiency of 99.997 percent for the principal organic hazardous constituents. The kiln appeared to be in good condition during the VSI.

The dust produced in the kiln is filtered through a baghouse (SWMU 17).

Dates of operation: This unit has been in operation since August 29, 1974. Burning of HWF in the cement kiln began in 1986.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42) as well as waste tires.

Release Controls: The air permits from the Ohio EPA require the use of a baghouse (SWMU 17) to reduce particulate matter emissions and low sulfur coal to reduce SO₂ emissions from the kiln and burner. The baghouse appeared to be in good working condition during the VSI. There were no fugitive emissions from the baghouse and no dust surrounding the baghouse at the time of the VSI. Coal with a sulfur content to meet the SO₂ emissions limitation in the air permit is reportedly used in the kiln.

History of Releases: The waste air emissions from this unit include nitrogen oxides (NO, NO₂), sulfur dioxide (SO₂), and particulate matter. Air permits from the Ohio EPA limit the emissions of particulate matter, through the use of a baghouse to filter out this material (SWMU 17), and SO₂, through the use of low-sulfur coal in the burner.

Conclusions: Soil/Groundwater - The potential for release to the soil and groundwater is low due to the design and operation of the unit.

Surface Water -The potential for release to the soil and groundwater is low due to the design and operation of the unit.

Air - The release of emissions to the air is regulated by the State air permit.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the design and operation of the unit.

References: 1,42,43

SWMU 10 Roura Hoppers (3 units) - Photos 17,24

Description: There are three tilt dump Roura Hoppers located throughout the facility which serve as solid waste fuel dumpsters. Two are placed adjacent to the Truck Unloading Area (SWMU 1) and a third is placed near the Burner Building/Kiln Floor (SWMU 8). The Roura Hoppers are used to collect absorbent material (kiln dust) and HWF spills which could occur at SWMUs 1 and 8 mentioned above. They are used occasionally to store filtrate material generated from the HWF Filtrate Shed (SWMU 2). Typically, spills within the process area are absorbed onto kiln dust and then manually shoveled with spark-proof shovels into the Roura Hoppers. The solid waste fuels collected in the Roura Hoppers are transported to the Outdoor Clay Storage Conveyor and Ancillary Equipment (SWMU 7) for disposal into the Cement Kiln (SWMU 9).

The Roura Hoppers have hinged 16 gauge lids that are opened only when being filled or when emptied. They are one cubic yard in size and made of 1/8" thick Hot-rolled steel and measure 62" long, 39" high, and 39" wide. Each hopper is labeled with 3 inch letters "HAZARDOUS WASTE" and give the date filling commenced. The units were in good condition at the time of the VSI and were equipped with lids.

Dates of Operation: The start-up dates are unknown. The units are currently in operation. Since HWF facilities were permitted in 1986, this unit could have handled HWF materials since that time.

Wastes Managed: This unit manages solid waste fuels. Waste fuels containing any of the wastes listed in Table III-3 (Reference 42) can be potentially managed.

Release Controls: These units are reportedly inspected daily to assure that lids are kept closed.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release to the soil or groundwater because of above-ground design and covered construction.

Surface Water - There is low potential for release to surface water due to above-ground design and distance to surface water.

Air - There is low potential for release to air due because the waste fuel is absorbed onto kiln dust and because the unit is covered.

Subsurface Gas - There is low potential for generation of subsurface gas due to the unit being located above-ground.

References: 1,42,43

SWMU 11 Dumpsters (3 units) - Photos 13 and 29

Description: This unit consists of three dumpsters which are located as needed throughout the facility. The metal units are approximately 4 cubic yards and manage wastes which accumulate in building waste baskets. The contents of the dumpsters are collected once a week by a commercial hauler. The units were in good condition at the time of the VSI and were equipped with lids.

Dates of Operation: The start-up dates are unknown. The units are currently in operation.

Wastes Managed: These units reportedly do not manage hazardous wastes or constituents. In addition, no HWF sample bottles are disposed to these dumpsters.

Release Controls: No release controls were reported, however, the unit rests on wheels and therefore, allows for inspection of any leakage.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release to the soil or groundwater based on the inert nature of the wastes.

Surface Water - There is low potential for release to surface water due to the inert nature of the wastes and distance from surface water.

Air - There is low potential for release to air due to the wastes being non-volatile.

Subsurface Gas - The potential is low due to the above-ground design of the units.

References: 1,42,43

SWMU 12 Safety-Kleen Units (2 units) - Photo 25

Description: These units are parts cleaner stations consisting of a wash-sink and solvent storage drum. Two units are used; one inside and one outside of the lubrication room of the maintenance/storage building. These units are cleaned under contract with Safety-Kleen Corporation who utilize their own transportation equipment. The units are approximately 1.5 ft. W x 2 ft. L x 3.5 ft. H and are made of steel.

At the time of the VSI, the storage drum was not with the unit located inside of the building. The outside unit was not observed at the time of the VSI but is reported to be on a concrete pad (Reference 58).

Dates of Operation: The start-up dates are unknown. The units are currently in operation.

Wastes Managed: Safety-Kleen solvents. See Materials Safety Sheet on next page.

Release Controls: The contaminated solvent is collected in a drum located underneath the tray.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release to soil or groundwater for both units because the units are located on concrete floors.

Surface Water - There is low potential for release to surface water from both units because they are located on concrete floors and the distance to surface water.

Air - There is low potential for release to air due to the design for containment of solvents.

Subsurface Gas - The potential for generation of subsurface gas is low due to the units above-ground design.

References: 1,42,43

SWMU 13 HWF Sample Storage Cabinet (Photo 35)

Description: This unit is located adjacent to the laboratory. The sample storage cabinet is located within a cement walled shed ("dynamite shack") with approximate dimensions of 8 ft H x 8 ft L x 1 ft W. The storage cabinet is made of metal and is secured with a lock. One sample per truckload is put in 8 ounce bottles for storage. Each sample bottle is analyzed individually in the laboratory and then returned to the cabinet. During this procedure, a sample is only in the laboratory during the time the analysis is being made.

Samples are disposed of by incineration in the cement kiln (SWMU 9).

According to the facility, the cabinet can store up to 90-120 days worth of samples, however, the facility did not provide an estimate of the number of samples stored at any one time.

At the time of the VSI, a solvent smell was evident in the shed.

Dates of Operation: The start up date is unknown. Since HWF facilities were permitted in 1986, this unit could have handled HWF materials since that time.

Wastes Managed: Hazardous waste fuels containing any of the wastes listed in Table III-3 (Reference 42).

Release Controls: Samples stored in covered cabinet located inside an explosion-proof shed.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release to the soil or groundwater due to location of cabinet in sealed shed.

Surface Water - There is low potential for release to surface water due to location of cabinet in shed.

Air - There is low potential for release to air because the samples are stored in a metal cabinet inside a shed. Although a solvent smell was apparent at the time of the VSI, the total volume appeared to be low.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the location of the unit above ground and inside a shed.

References: 1,42,43

SWMU 14 Landfill (No Photo)

Description: The landfill is located along the eastern edge of the limestone crushing building. The dimensions of this unit were observed to be approximately 150 ft by 250 ft (Reference 46). Additional information provided by facility representatives identified the landfill as covering 6 acres (Reference 57). The landfill is currently active and is unlined. According to facility representatives, the dump has been used to dispose of nonhazardous solid waste. This unit was not identified as an existing unit until after the VSI was completed. Ohio EPA representative, Harold O'Connell, visited the unit on February 23, 1990 (Reference 46). His observations on the unit were as follows:

- The height of fill area above the surrounding grade was estimated as 30 ft.

- The surface consisted primarily of backfill, quarry overburden, and scrap cement clinker (product). Some tires noted at base of landfill.

- Runoff at base of landfill's eastern edge originates from two adjacent sources: 1) active quarry mining operations and 2) runoff collected from low lying areas along Dayton-Yellow Springs Road.

Dates of Operation: This unit has been in operation since 1974.

Wastes Managed: - 1974 (August) - 1978 (March): Kiln dust slurry (alkali bypass), wood, fiberboard, paper shipping containers for parts equipment and supplies, used tires from mining operations, rubber belting, scrap metal (primarily ferrous metal from plant repair), material from construction and demolition operations.

- 1974 (August) to Date: Construction and demolition operations. Sediment from the Stormwater Retention Impoundment/Silt Fence (SWMU 15).

The unit has not handled hazardous wastes or constituents based on results of an EP Toxicity Test and a TCLP on the cement kiln dust (Reference 42). In addition, the cement kiln dust can not be categorized as D002 (corrosive) because corrosivity only applies to liquid wastes as indicated by 40 CFR (261.21).

Release Controls: The landfill is periodically watered to reduce fugitive dust emissions. Personnel are on duty 24 hours a day at the plant to monitor any unauthorized entry or illegal dumping.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential of release to soil and groundwater from the landfill based on an EP Toxicity Test and TCLP on the cement kiln dust.

Surface Water - There is low potential of release to surface water from the landfill based on an EP Toxicity Test and TCLP on the cement kiln dust.

Air - There is low potential for release to the air due to release controls, specifically periodic watering and because much of the landfill has been covered.

Subsurface Gas - There is low to moderate potential for formation of subsurface gas due to the wastes being managed below ground.

References: 42,46

SWMU 15 Stormwater Retention Impoundment/Silt Fence and Collection Ditches (Photos 6,7,8)

Description: This unit is comprised of all stormwater collection ditches and an unlined stormwater retention impoundment/silt fence which manage runoff from the SPCC site. A silt fence retains stormwater runoff in the impoundment which covers an approximately 150 ft square area. Ditches from the SPCC collect stormwater runoff as shown in Figure III-4 and converge to this impoundment unit. In addition, collection ditches convey flow from the site and impoundment to Ludlow Creek (See Photo 7). When the impoundment fills up with sediment, the sediment is excavated and reused as fuel if possible. Otherwise, the sediment is put in the on-site landfill.

At the time of the VSI, this unit was discharging to Ludlow Creek. The discharge to Ludlow Creek was turbid. This type of turbidity is indicative of the presence of ferrous hydroxide precipitate, a product of acidic coal pile runoff.

Dates of Operation: Unknown

Wastes Managed: This unit manages coal pile, clinker pile, and on-site stormwater runoff for the SPCC plant. The sediment may contain trace amounts of volatiles if HWF spills were not contained as reported. In addition, the unit manages acidic runoff from the coal pile storage area.

Release Controls: None, the unit is unlined. Discharges are not currently regulated under a NPDES permit.

History of Releases: The unit was discharging turbid runoff water to Ludlow Creek at the time of the VSI. In addition, a yellow/orange colored leachate from the Outdoor Coal Pile Storage area was being collected in the impoundment.

Conclusions: Soil/Groundwater - The potential for release to soil and groundwater is high because the impoundment is not lined.

Surface Water - Release to surface water was observed during the VSI.

Air - Release to air is low due to the diluted concentrations of volatile constituents.

Subsurface Gas - The potential for the generation of subsurface gas is low due to the dilute concentrations of inorganic constituents managed in the impoundment.

References: 43

SWMU 16 Waste Tire Staging Area (Photo 34)

Description: This unit is located west of the scale house. Waste tires used for the kiln fuel are stored in covered transportation trailers and are moved from these trailers to the conveyor system which feeds them to the kiln. The tires are reportedly consumed within 90 days of receipt.

At the time of the VSI, all waste tires were in the covered transportation trailers.

Dates of Operation: Use of waste tires as fuel began in 1989.

Wastes Managed: This unit primarily manages defective waste tires from tire manufacturers. Occasionally, waste tires are received from local groups which SPCC has accepted as a public service to the community.

Release Controls: Waste tires are stored in covered transportation trailers.

History of Releases: No information on releases was reported or found in the file material.

Conclusions: Soil/Groundwater - There is low potential for release to the soil or groundwater due to the location of waste tires in the trucks and the inert nature of the waste tires.

Surface Water - There is low potential for release to surface water due to the location of waste tires in the trucks and the inert nature of the waste tires.

Air - There is low potential for release to air due to the inert nature of the waste tires.

Subsurface Gas - There is low potential for the generation of subsurface gas due to the inert nature of the waste tires.

References: 1,42,43

SWMU 17 Alkali Bypass Baghouse (Photos 11 and 32)

Description: This unit is an air pollution control device used to remove particulate matter (dust) from the air emissions stream of the bypass system located at the base of the preheater's sub-system. The baghouse consists of 10 fabric compartments within a metal structure measuring 65 feet long by 30 feet wide by 41 feet high. Its capacity is 80,000 ACFM at a temperature of 360 degrees F. This unit appeared to be in good working condition at the time of the VSI. The State has issued an air permit for the operation of this unit.

Dates of Operation: This unit has been in operation since August 29, 1974.

Wastes Managed: This unit manages to alkali dust removed from the air emissions waste stream at the base of the preheater tower before the raw materials are placed in the kiln. This unit does not manage any hazardous wastes or constituents.

Release Controls: This unit consists of 10 fabric compartments surrounded by a metal structure. Air emissions are vented to the atmosphere and are regulated by a State-issued air permit.

History of Releases: There are no reports of unregulated releases from this unit.

Conclusions: Soil/Groundwater - The potential for release to soil and groundwater is low due to the construction and location of the baghouse and due to the handling procedures for the collected dust.

Surface Water - The potential for release to surface water is low due to the construction and location of the baghouse and due to the handling procedures for the collected dust.

Air - The potential for release to the air is high because the air emission waste streams are vented to the atmosphere after being filtered. The emissions from the baghouse are regulated by a State air permit. The potential for releases of hazardous constituents to the air is low due to the high efficiency of the baghouses and the high average destruction and removal efficiency of the preheater for the principal organic hazardous constituents.

Subsurface Gas - The potential for the generation of subsurface gas is low due to the construction and location of the baghouse.

References: 1,42,43

AREAS OF CONCERN (AOCs)

The following is a discussion of AOC A which has been identified at the Southwestern Portland Cement Company Quarry Plant facility.

AOC A - Quarry Garage Diesel Fuel Tanks (2 each)

Description - This area of concern consists of two 7,8000 gallon steel underground diesel fuel storage tanks which are located outside the Quarry Garage Building on the west side. The tanks were installed in 1957. No known releases have occurred. These tanks are reportedly registered with the Ohio EPA according to federal regulations.

Conclusion - There is high potential for release to soiil and surface water due to spillage and staining that has already occurred at the pumps. The potential for release to groundwater can not be determined due to the below-ground construction and because the integrity of the tanks are unknown. The potential for release to air is low due to the underground construction of the tank. The potential for generation of subsurface gas is low due to the low inorganic content of the constituents stored.