PRELIMINARY REVIEW/VISUAL SITE
INSPECTION REPORT
Southwestern Portland Cement Company -
Quarry Plant
Fairborn, Ohio
EPA I.D. No. OHD981195779
for:
Mr Bernie Orenstein
U.S. Environmental Protection
Agency
Region V
230 South Dearborn Street
Chicago, IL 60604
Prepared by:
A.T. Kearney, Inc.
222 South Riverside Plaza
Chicago, IL 60606
EPA Contract No. 68-W9-0040
Work Assignment No. R05-05-06
April, 1990
Table of Contents
PAGE
I. Executive
Summary.................................. 1
II. Introduction....................................... 4
III. General
Description................................ 5
A.
Facility Description........................... 5
B. Process
Description............................ 5
C. Waste Generation and Management................ 8
D.
Regulatory History............................. 12
D.1
RCRA..................................... 12
D.2
Air Quality.............................. 13
E.
Environmental Setting.......................... 14
E.1.
Location and Surrounding Land Use....... 15
E.2.
Climate and Meteorology................. 15
E.3
Topography and Surface Drainage......... 16
E.4
Soils and Geology....................... 16
E.5
Groundwater............................. 20
E.6
Release Pathways........................ 21
E.7
Receptors............................... 21
IV. Solid Waste Management Units (SWMUs) and Areas
of Concern
(AOCs).................................. 23
SWMU 1 - HWF Truck Unloading Area............ 26
SWMU 2 - HWF Filtrate Shed................... 29 SWMU 3 - HWF Storage Tank No. 1 and
Ancillary Piping................... 31
SWMUs 4,5,6 - HWF Storage Tank Nos.
2,3, and 4......................... 34
SWMU 7 - Outdoor Clay Storage Conveyor
and Ancillary Equipment............ 36
SWMU 8 - Burner Bldg/Kiln Floor.............. 38
SWMU 9 - Cement Kiln......................... 39
SWMU 10 - Roura Hoppers (3
each).............. 41
SWMU 11 - Dumpsters (3
each).................. 43
SWMU 12 - Safety-Kleen Units (2
each)......... 44
SWMU 13 - HWF Sample Storage
Cabinet.......... 45
SWMU 14 -
Landfill............................ 47
SWMU 15 - Stormwater
Retention Impoundment/
Silt Fence and Collection Ditches.. 49
SWMU 16 - Waste Tire Staging
Area............. 51
SWMU 17 - Alkali Bypass
Baghouse.............. 52
AOC A - Quarry Garage Diesel Fuel
Tanks (2
each)...................... 54
Table of Contents, (Cont'd)
V. Summary of Suggested Further
Actions............... 55
VI. References......................................... 57
ATTACHMENTS:
A. Photograph
Log
B. Field
Log
List of Figures
Page
III-1 General
Vicinity Map of the Southwestern
Portland
Cement Company (SPCC)-Quarry Plant... 6
III-2 The
SPCC Quarry Plant Facility Layout Map..... 7
III-3 Wind
Rose for Fairborn Area................... 17
III-4 SPCC
Runoff Drainage Ditches.................. 18
IV-1 SWMU and AOC Map of the SPCC Quarry Plant..... 25
List
of Tables
Page
I-1 Current
Permitting of SWMUs and AOCs
Identified
at the SPCC Quarry Plant............ 2
III-1 List
of Part A Permit Wastes................... 10
III-2 Specifications
for Hazardous Waste Fuel (HWF).. 11
IV-1 Directory
of Photos by SWMUs and AOCs.......... 24
IV-2 History of HWF Releases from Truck
Unloading
Area (SWMU 1)........................ 27
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 o F
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).
The
topographic relief of the plant complex area is typical of what used to be
uplands. However, quarrying operations
have altered the facility which is currently relatively flat at elevation 940
feet, except for product storage structure embankments. At this elevation, the site is not within
the 100 year flood plain for the area. Surface drainage on the property is to
either Beaver Creek or Ludlow Creek.
Most of the plant complex runoff is to Ludlow Creek. Drainage from the western portion of the
plant which includes runoff from the outdoor clay and limestone storage areas,
drains to Beaver Creek. Both Creeks drain
to the Little Miami River. Ludlow Creek
is an intermittent stream with stormwater runoff and springs from the plant and
adjacent properties augmenting its flow.
This stream flows through plant property from northeast to southeast at
a distance of approximately 1500 feet from the plant complex. The plant uses a system of ditches to manage
stormwater as shown in Figure III-4 (Reference 1). The collection ditches converge to a Stormwater Retention
Impoundment/Silt Fence (SWMU 15). At
the time of the VSI, SPCC Quarry Plant stormwater runoff was heavily augmenting
Ludlow Creek (Reference 43).
E.4. Soils and Geology
Available
U.S. Department of Agriculture - Soil Conservation soil survey maps indicated
that the predominant soil association in the
area of the SPCC Quarry Plant complex is the Milton-Miamian
Association. The Milton-Miamian
Association is characterized by having underlying limestone bedrock (Reference
44).
Milton Series - The
Milton series consists of well drained, moderately deep soils that formed in
glacial till deposited during the Wisconsin age glaciation. Limestone bedrock is at a depth of 20 to 40
inches. The orientation of the major
soil areas are generally northeast to southwest orientations due to the
advances and retreats of Wisconsin age glaciation. A typical Milton series profile has a 6-inch thick dark grayish
brown and brown silt loam on the surface, underlain by an upper 13-inch subsoil
of brown silty clay loam, and the lower part by 11-inches of brown clay
loam. Light gray limestone bedrock is
at a depth of 30 inches. The Milton
soils have moderate permeability and water capacity in the subsoil, but the
underlying limestone bedrock is fractured and water moves rapidly through it
(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.
VI. REFERENCES
1. Part B Permit Application - Southwestern Portland Cement Company (SPCC), January 9, 1990.
2. Letter from OEPA to SPCC. Re: Hazardous Waste Management, November 24, 1989.
3. Letter from EPA SWDO to SPCC. Re: Compliance Letter, May 17, 1989.
4. Letter from SPCC to OEPA. Re: Attachment A in Letter dated February 3, 1989, February 17, 1989.
5. Letter from SPCC to USEPA. Re: Part A Application OHD 981 195 779, February 16, 1989.
6. Letter from OEPA to SPCC. Re: Acknowledge Receipt of Part B, February 3, 1989.
7. Letter from OEPA to SPCC. Re: Compliance with Hazardous Waste Inspection, November 29, 1988.
8. Letter from SPCC to OEPA. Re: Part B Permit, November 16, 1988.
9. Letter from OEPA to SPCC. Re: Hazardous Waste Inspection, November 1, 1988.
10. Letter from Wright State University to OEPA. Re: Request to view SPCC files and Sample Submission Report, July 12, 1988.
11. Letter from OEPA to SPCC. Re: Use of Still Bottoms as SDF, January 12, 1988.
12. Letter from SPCC to USEPA. Re: Revision to Part A, December 1, 1987.
13. State of Ohio Inter-Office Communication from DSHWM to DAPC. Re: Use of Still Bottoms as HWF, November 20, 1987.
14. Letter from SPCC to OEPA. Re: Revision to Part A, November 18, 1987.
15. Letter from OEPA to SPCC. Re: Receipt of Request for modification to PTI, November 13, 1987.
16. State of Ohio Inter-Office Communication from DAPC to DWHWM. Re: Use of Still Bottoms as HWF, November, 10, 1987.
17. Letter from SPCC to RAPCA. Re: Use of Still Bottoms as HWF, November 4, 1987.
18. Letter from SPCC to SHWMU. Re: Inspection Items, November 4, 1987.
19. Letter from SPCC to SHWMU. Re: Copy of Daily Inspection Log, November 4, 1987.
20. Letter from OEPA to SPCC. Re: Inspection Deficiencies/ Violations, October 22, 1987.
21. Inspection Checklist. Re: RCRA Land Restriction F-Solvent Generator, October 15, 1987.
22. Letter from OEPA to SPCC. Re: Compliance of SPCC to Ohio's and USEPA's Hazardous Waste Rules and Regulations, September 16, 1987.
23. Letter from OEPA-SHWMU to SPCC. Re: Corrections to Violations, January 6, 1987.
24. Part A Permit Application - Southwestern Portland Cement Company, October 30, 1986.
25. Part A Permit Application - Southwestern Portland Cement Company, August 25, 1986.
26. USEPA-Region V Review of Part A Permit, May 15, 1986.
27. Letter from SPCC to USEPA-Region V. Re: Part A Permit Application, May 13, 1986.
28. Letter from SPCC to USEPA-Region V. Re: Renotification to identify waste-as-fuel activity, January 27, 1986.
29. Letter from USEPA-Technical Programs Section to OEPA. Re: New Definition of Solid Waste, October 4, 1985.
30. Letter from Vorys, Sater, Seymour and Pease to OEPA-SHWMU. Re: Air Permit to Install, July 12, 1985.
31. Letter from OEPA to SPCC. Re: Permit to Install, July 5, 1985.
32. Letter from OEPA to SPCC. Re: Applicability of Ohio hazardous waste laws and regulations to the proposed burning of hazardous waste fuels by SPCC, June 28, 1985.
33. State of Ohio Inter-Office Communication from DWHWM to Attorney. Re: LTV Steel/Hukill and Southwestern Portland Cases, June 19, 1985.
34. Letter from Solvent Resource Recovery, Inc to OEPA, Re: Solvent Derived Fuel Program, February 28, 1985.
35. Letter from RAPCA to OEPA, Re: SPCC PTI Application No. 08-446, August 27, 1982.
36. Letter SPCC to RAPCA, Re: Permit to Install Application, August 20, 1982.
37. Letter from Systech Corporation to RAPCA, Re: Issuance of Preliminary Staff Determination: Application No. 08-446, July 16, 1982.
38. Letter from Xenia Township Board of Trustees to RAPCA, Re: Request for Public Hearing on Air Pollution Concerns, July 15, 1982.
39. Letter from OEPA to Solvent Resource Recovery, Re: Follow up Inspection of Previous Inspections Violations, July 7, 1982.
40. Letter from Smith & Schnacke to Systech Corporation, Re: Applicability of state and federal regulations for still bottoms and spent solvents, February 4, 1982.
41. Soil and Foundation Report - Partial Submission for Southwestern Portland Cement Co. by SITE Engineers September 13, 1972
42. Letter to USEPA-Region V from SPCC. Re: Written Responses to " Additional Information Needs and Items for Review During VSI", February 12, 1990.
43. VSI Field Log. February 12, 1990.
44. Soil Survey of Greene County, Ohio, U.S. Department of Agriculture, 1974.
45. Telephone Log to Dr. Schmidt of Wright University from Lili M. Scheider (A.T. Kearney), February 16, 1990.
46. Facsimile Letter to A. T. Kearney from Harold O'Connell (OEPA). Re: PR/VSI Information on Landfill adjacent to Crusher Bldg., February 23, 1990, Received Facsimile on February 26, 1990.
47. Telephone Log to Chris Yoder of Ohio EPA from Lili M. Scheider (A.T. Kearney), February 28,1990.
48. Letter to Mitch Baer (A.T. Kearney) from Ted Stute (SPCC). Re: Jeffrey Waytrols permit, February 15, 1990.
49. Letter to Mitch Baer (A.T.Kearney) from David Constans of Resource Recovery Operations. Re: Visual Site Inspection, SPCC OHD981195779, February 19, 1990.
50. Facsimile Letter to A.T. Kearney from Harold O'Connell (OEPA). Re: PR/VSI Information on Air Permits; Compliance Status, February 26, 1990, Received Facsimile on February 26, 1990.
51. Letter to Ms. Codina from Ted Stute (SPCC). Re: Return of Negatives from VSI, March 2, 1990.
52. Telephone Log to Ted Stute (SPCC) from Lili M. Scheider (A.T. Kearney). Re: Additional Information Needs, March 21, 1990.
53. Telephone Log to Harold O'Connell (OEPA) from Mitch Baer (A.T.Kearney). Re: Request for information on status of air permits and landfill, February 26, 1990.
54. Local Climatological Data - Annual summary with Comparative Data, Dayton, Ohio, 1988 NCC Ashville, N.C.
55. Part B Permit Application - Southwestern Portland Cement Company (SPCC), July, 1988.
56. Groundwater Resources of the Valley-Train Deposits in the Fairborn Area, Ohio, Dept. of Natural REsources, Technical Report 3.
57. Letter from Ted Stute (SPCC) to Lili M. Scheider. Re: Additional Information Request, March 23, 1990.
58. Telephone Log to Bob Calloway from Lili M. Scheider. Re: Additional Information Needs, March 26, 1990.
ATTACHMENT A
Photograph Log
ATTACHMENT B
Field Log
FIGURE I-1 General
Vicinity Map of the Southwestern Portland
Cement Company (SPCC)-Quarry Plant
(REFERENCE 1)
FIGURE II-2 The
SPCC Quarry Plant Facility Layout Map (REFERENCE 1)
FIGURE
III-1 Wind Rose for Fairborn
Area (REFERENCE 1)
FIGURE
III-2 SPCC Runoff Drainage
Ditches (REFERENCE 1)
FIGURE
III-3 Soil Survey Map, SPCC
Quarry Plant Area (REFERENCE 44)
FIGURE
III-4 Location of Drinking Water
Wells (REFERENCE 1)
FIGURE
IV-1 SWMU and AOC Map of the SPCC Quarry Plant
TABLE
II-1 Hazardous Waste Fuels
Managed at SPCC (REFERENCE 1)
TABLE
II-2 Specifications for
Hazardous Waste Fuels (REFERENCE 1)
TABLE
II-3 List of Air Pollution
Control Permits (REFERENCE 42)
LEGEND:
SWMUs
1. HWF Truck Unloading Area
2. HWF Filtrate Shed
3. HWF Storage Tank No. 1 and
Ancillary Piping
4. HWF Storage Tank No. 2
5. HWF Storage Tank No. 3
6. HWF Storage Tank No. 4
7. Outdoor Clay Storage Conveyor
8. Burner Bldg/Kiln Floor
9. Cement Kiln
10. Roura Hoppers
11. Dumpsters
12. Safety-Kleen Units
13. HWF Sample Storage Cabinet
14. Landfill
15. Stormwater Retention Impoundment\
Silt Fence and Collection Ditches
16. Waste Tire Staging Area
17. Alkali Bypass Baghouse
Areas of Concern
A. Quarry Garage Diesel Fuel Tanks
March 4, 1990
Ms. G. Kline
Midwest Research Institute
6 Skyline Place #414
5109 Leesburg Pike
Falls Church, Va. 22041
Reference: EPA Contract No. 68-W9-0040; Work Assignment No. R05-05-06; Southwestern Portland Cement Company, Fairborn, Ohio; EPA I.D. No. OHD 981195779; QC Review
Dear Ms. G. Kline:
Enclosed please find the proposed PR/VSI report for the above- referenced work assignment for your Quality Control (QC) review.
Approximately 15 SWMUs and 5 AOCs were identified at this facility. Additional information is forthcoming in some sections as noted by bolding in the report. SWMU No. 14, was not identified as an existing unit until after the VSI was completed. Subsequent information received from OEPA is referenced for this unit.
The facility asked that the photos be Confidential Business Information (CBI).
Please feel free to call me or Ann Anderson, the Kearney Team Work Assignment Manager (who can be reached at 312/648-0111), if you have any questions.
Sincerely,
Lili M. Scheider
cc: A. Anderson
M. Baer
S. Johnson