.,_ ... )t**~Ill~**

Fic>ss Incineration SeNices. Inc. Hazardous Waste lnstallaUon & Operation Pennlt Renewal Page 30 of 101 

### Additionally, the Permittee has three surface impoundments thatwere in existence

. at.the time the implementing rules for RCRA were enacted and for which the Permittee never sought full permitted status. As 

### such, these units were subject

### to the interim standards closure requirements ofOAC Chapter3745-66 but,forvarious reasons, have notyetachieved final closure. The purpose of

### this condition is

### to put the Permittee on schedule to complete closure ofthese units.

Surface Impoundment 2 orSWI2; Surface lmpoundm.ent 6 orSWI6;and Surface Impoundment 7 orSWI7 SCIUbberwater and sCIUbberwater sludge composed primarily of incinerator ash AClosure Planto close SWI6 arid SW17 with waste """';'""" u and oonsoidale the waste and unit linerfrom SWI2 in was received byOhio EPAon9/7/2000. On 11120/2000, Ohio EPA issued a NoUce of Deficiency (NOD) on this Closure Plan. The NOD response leiter dated 111212001 requested additional meeUnssWith Ohio EPAand proposed asequential responsetothe NODwith Ohio EPA approval olintennedlate plan elements. ATreatabUity Study and Analysis Plan was submllted to Ohio EPA on 121612001. On 112312002, Ohio EPA Issued a NOD on the plan. Ross responded by letter dated 2/2212002. In response, Ohio EPA Issued a NOD on S/2912002. Ross responded by latter dated 71512002. Following a meeting, Ross submllted a revised Tneatabl6ty Study and Analysis Plan dated B/2212002. Ohio EPA reviewed this submittal and by letter qated October 2, 2002 stated thet Ohio EPA had no further comment on the Treatability Study and OJq>ected RIS to proceed 

### with


### The Permittee shall complete closure of surface impoundments SWI-2, 6 and 7 in accordancewith the approved closure plan revisions located in Section I ofthe app6cation as submitted via a Class 2 Permit Modification. Request dated March 1, 2004 and as
· amended by supplemental responses dated April 22, 2004 and May 12, 2004. The

approved closure plan permits the Permittee to 

### incinerate tarps and other debrjs from this closure that are contaminated 

### with closure wastes carrying hazardous waste code F027. The approved closure plan does not include proposed changes to the Permittee's financial assurance obligations as stated in Table 1-3 on proposed revision pages 1-39through 1-46. Upon completion ofOhio EPA's review of the proposed changes

### tothe Permittee's financial assuranceobligations, proposed revisions

### tothe Permittee'sfinancial assurance obligations shall be resubmitted to 

### Ohio EPA in a Class 1A permit modification request. 

### OHIO

# m, iJ!1Vii


### B.2B Amendment of Closure Plan 

## JUN 16 Z004 OAC Rules 3745-55-12 and 3745-50-51 Should a change in the facility closure plan become necessary, the Permittee shall amend the closure plan in accordance 

### with OAC Rule 3745-55-12 (C).

VES016600Ross lnclneraUon SeNicea, Inc. HazardousWaste Installation & Operation Permit Renewal Pa9e 31 of 101



### 8.29 Content ofC!o§ure Plan , OAC Rule 3745-55-12 The Permittee shall maintain the closure plan at the facility which contains the elements setforth 

### In OAC Rule 3745-55-12 and all elements required by the terms and conditions of

### this permit. B.30 Notification ofClosure OAC Rule 3745-55-12 The Permittee shall notifythe Director Inwriting at least45 days priorto

### the date on which he expects 

## to begin final closure of afacility as required by OAC Rule 3745- 55-12(0). 8.31 Time Allowed For Closure OAC Rule 3745-55-13 Within ninety (90) days·after receiving the final volume of 

### hazardous waste, the Permittee shall remove from the facility, ortreat ordispose of

### on-site, all hamrdous waste In accordance 

### with the approved closure plan. The Directormay approve a longer period if the Permittee complies with all appUcable requirements for requesting 

## a modification to the permit as set forth in OAC Rule 3745-55-13(A). The Permittee shall complete all closure activities within one hundred eighty (180) days after receiving the final volume of hamrdous waste In accordance 

### with OAC Rule 3745-55-13. The Director may approve a longer closure period if 

### the Permittee complies with all applicable requirements for requesting a modification to the permit as set forth in OAC Rule 3745-55-13 (B). 

### 8.32 Disposal or pecontamjnation of 

### Equipment. 

## Structures· and Soils 

### OAC Rule 3745-55-14 (a)



### (b) 

### The Permittee shall decontaminate or dispose of all contaminated facility equipment, structures, and soils, as required. by OAC Rule 3745-55-14, the approved closure plan and the terms and conditions of this permit The Permittee shall notify the Ohio EPA Northeast District Office 

### within 5 working days prior

## to all rinseate and soil sampling. 

### '\ 

### OHIOEPAOHWM 

# st.r 3

# o zom

. 

## ---------- ----
VES016601Ross Incineration Services, Inc. Hazardous Waste Installation & Operation Permtt Renewal Page 32 of 101**8.~3** Certification of Closure OAC Rule 3745-55-15 The Permittee and an independent, qualified, registered professional engineershall certify thateach hazardous waste management**un~** orthe facility has been closed inaccordancewiththespecifications in the approved closure planand

### thetermsand conditions ofthis permit, as required by OAC Rule 3745-55-15. The Permittee shall furnish to the Director, upon request, documentation supporting the certification. 8.34 Survey Plat OAC Rule 3745-55-16 The Permittee must submit a survey plat to the Director and the local zoning authority no laterthan the submission ofcertification ofclosure ofeach unitthat is closed as a hazardous waste disposal unit, in accordance with OAC Rule 3745-55-16. 8.35 General Post-Closure Requiraments OAC Rules 3745-55-17,3745-55-18, 3745-55-19; 3745-55-20 (a) Post-Closure Care Period The Permitteemustbegin post-closure careforsurface impo!JndmentSWI-7 upon completion of closure of the unit and continue for 30 years after that date. Post-closure care shall be in accordance with OAC Rule 3745-55-17 and the Post-Closure Plan in Section l-4·ofthe application (submitted as a Class 2 Permit Modification Requestdated March 1, 2004 and amended by a supplemental response dated June21,2004). The approved Post-Closure Plan does notinclude•p;-ase"ajcordingtoa performance based system and" on Page E-1 Post closure ground water monitoring parameters shall be those specified in Condition J.3(a). (b) Post-Closure Security The Permittee must maintain security at the facility during the post-closure care period in accordance with

VES016602Ross lndneratlon Services, Inc. Hazsrdous Waste Installation & Operation Permtt Renewal Page 33 of 101 · the Post-Closure Plan as approved by Ohio EPA and OAC Rule 3745-5&- 17(6). (c) Amendment to Post-Closure Plan Subsequent to approval by Ohio EPA of a Post-Closure Plan for surface impoundment SWI 7, the Permittee must amend the Post-Closure Plan whenever necessary in accordance with OAC Rule 3745-55-18(Dj {d) Post-Closure Notices (I) No laterthan 60 days after certification of closure ofeach hazardous waste disposal unit, the Permittee mustsubmit

### tothe director and the local zoning authority records ofthe type, location, and quantity of hazardous waste disposed of within each cell 

## or disposal unit, in accordance with OAC Rule 3745-55-19(A). (ii) Within 60 days ofcertification of- the last unitthat is closed as a hazardous waste disposal unit the Permittee must do the following: (1) Record a notation on the deed to the facility property which contains the information required by OAC

.. Rule 3745-55- 19(6){1). (2) Submit to the Director a certification that the Permittee has recorded the notation and submit a copy ofthe document in which the Permittee placed the notation.

VES016603Ross Incineration ServicBB, Inc. Hazardous Waste lnotallallon & OpetaUon Penntt Renewal ?ago 34of 101
(3) The Permittee -request and obtain a permit modification prior

### to post-closure rem011al ofhazardouswastes, hazardous waste residues, liners, or contaminated sons, in accordance With OAC Rule 3745-55-19(C). (e) Certification of Completion of PostcCJosure Care establishedpost-closure care Permittee&certifythat the care· was**oe~fom~ed** in accordance with the specifications in the Post-Closure Plan, as required by OAC Rule 3745-55- 20. B. 36 Cost Estima1e for EaciH!y Closure and Post-Cipsure OAC**Rule~** 3745-55-42 and 3745-55-44 (a) The Permittee's most recent closure cost , prepared in accordance with OAC Rules 3745-5542, 3745-5.5-44, 3745-55-97(C)(3) 

### & (5), 3745-56-28(C)(3} and 3745-56-58(C}(2) 

# IE specified In Section I ofthe Part B permit applicationl (b) The Permittee must adjust the closure and post-closure cost estimate for inflation within 60 days prior to the anniversary date ofthe establishment of the financial instrument(s) used to comply with OAC Rule 3745-55-43 and 3745-55-45 and Permit Condition 8.39. (c) The Permittee must revise the closure cost estimate whenever there is a change in the facility's Closure Plan that increases the cost of closure, and the post-closure cost estimate whenever**theli!tJi"IJJ:~**facility's Post-Closure Plan that increases the cost of ·· uired by OAC Rule 3745-55-42(C) and 3745-55-44(C).



### OHIOEPAC 

## MAR 02

VES016604Ross Incineration Services, Inc. HaardouaWaste Installation & Operation Permit Rene_wal Page 35 of 101



### B.37 financial Assurance for facility Closure and post-Closure the facilitythe latest**req~1ired** 

### by OAC

The Permitteeli'Dmaintaincontinuous compliancewith OAC Rule 3745-55-43 and maintain continuous compliance

### With OAC Rule 55-45 or55-46. iilllrProvidedocumentation offinancial assurance, which meetsthe requirements of OAC Rule 3745-55-51, in at least the amount ofthe cost estimates required by Permit Condition 8.36. 8.36 Liability Requirements The Permittee shall maintain continuous eompllance with the requirement of OAC Rule 3745;55-47 and the documentation of llabOity by providing liability coverage which·meets the requirements of OAC Rule 3745-55-51 for sudden accidental occurrences in the amount required by the applicable rules, exclusive of legal defense costs. The Permittee also shall demonstrate compliancewith OAC Rule 3745-55-47(8) by maintaining liability coverage for non-sudden accidental occurrences inthe amount ofat least $3 million peroccurrence, with an annual aggregate ofatleast$6 million, exclusive of 

### legal defense costs. B.39 

### lncapacitv ofowners or Operators. Guarantors. or Financjallnstitutions OAC Rule 3745-55-46 The Permittee shall comply with requirements set forth in OAC Rule 3745-55-48 regarding the incapacitY of owners, operators, guarantors orfinancial institutions.



### OHIO EPADHWM



## . MAR 02 2005

VES016605Rooa Incineration Services, Inc. Hazardous Waste lnstalla1lon & OparaUon Pennlt Renewal Pagt 36 of101


### 8.40 General Reaujrem&nts for Land Disposal Restrictions OAC**Chapte~** 

### 3745·270 The Permittee shall comply with all applicable regulations regarding land disposal prohibitions and restrictions as required by OAC Chapter

### 3745-270 and as setforth 

### in Seatlon C of the Part B permit application.



# ·.

' OHIOEPADHWM 

# Sttl 302003

------------------·
VE5016606Ross lncinerstion Services, lnc. HazardousWaste Installation & Operation Permit Renewal Page 37 of 1 01 

### OHIOE!'llDIMM 

## NOV l 6 Z007

MODULE C -CONTAINERS STORAGE 

### &MANAGEMENT C. MODULE HIGHLIGHTS Containers of hazardous waste are stored in the 1) Bulk Storage Area (BSA), 2) Oxidizer Storage Building (OSB) and Container Storage Facility. The BSA is outdoors on concrete containment with approximate dimensions of 51' X 99' and used for storage of hazardouswaste withoutfree liquids in roll-offs and othercontainers. Itcan store the equivalent of 16 twenty cubic yard roll-offs (i.e., 64,632 gallons). The OSB is a 21' X 80' pre-engineered steel building used to store containers ofoxidizer and organic peroxide waste, in addition to the permitted oxidizer waste storage in the CSF. The OSB is designed to hold 144 fifty-five gallon drums (i.e., 7,920 gallons). The Container Storage Facility is an open-sided covered building with dimensions of**a~**proximately 257 feet by60 feetthat is used forstorage ofcontainers ofwastes from off -site generators and certain on-site generated wastes. Containers stored in the Container Storage Facility include various types ofsteel, plastic and composite drums, pails, buckets and boxes as well as bulk containers such as roll-offs and truck tankers. Containerswith and withoutfree liquids may be stored inthe Container Storage Facility. The Container Storage Facility has adequate secondary containment. T)'pical hazardous waste types received atthe facility in containers include: halogenated and non-halogenated spentsolvents, paintwastes, off-specification commercial chemical products and spill residues. Waste generated atthefacility and stored in containers consists primarily of treatment residuals from the incineration process. The Container Storage Facility includes 18separate storage bays. Containers accepted from off-site generators for storage in the Container Storage Facility must meet the US-DOT specifications found in 49 CFR 178. Non-bulk containers such as drums, pails, buckets and boxes are stored in racks. Bulk containers, such as roll-offs and trucktankers, are stored in the tanker bays in the Container Storage Facility. Drums, pails, buckets and boxes, subject to waste type and quantity restrictions, may also be stored in the tanker bays in the Container Storage Facility. Containers of hazardous waste may be accepted for storage and re-shipment to other hazardous waste treatment, storage and disposal facilities. The wastes in re-shipped containers typically carrywaste codes thatthe facility is permittedto store, but notto incinerate. Containers of hazardous waste may be repackaged atdesignated locations within the facility into alternate containers 

### to facilitate management of the waste. Liquid wastes received in tankertrucks may be transferred totankers operated bythe facility (i.e., yard tankers) fordirect feeding from a tanker into the incinerator.



### VES016601Ross Incineration Services, Inc. Hazardous Waste Installation & Operation Pennil Renewal Page 38 of 101

C.1 Process CapacitviAnnual Quantity Limitation OAC Rules 3745-50-43(A)(7) 

### OHIO EPA DHWM 

## NOV 16 2.1107

(a) The Permittee shall not store more than 457,031 gallons of containerized waste atany given time in the permitted container areas (Container Storage Facility, Bulk Storage Area, and Oxidizer Storage Building). At notime shall the volume of waste exceed 64,632 gallons in the Bulk Storage Area or 7,920 gallons in the Oxidizer Storage Area. The Permittee shall store hazardous waste in the types of containers (size and type) described in Section D of the Part B permit application. The Permittee may not store containers for more than one year. 

### (b) The Permittee shall at all times have access to its current container storage volume via its computer tracking system and be able to demonstrate compliance with its permitted container storage capacity limitation. (c) Permit Conditions C.1(a) and C.2 shall not applyto the Permittee's activities as a generator accumulating hazardous waste on-site in compliance with OAC Rule 3745-52-34(A). However, when accumulating waste within the permitted container storage area, in accordance with OAC Rule 3745-52-34(A), the Permittee shall not, forthetotal amount ofhazardouswaste stored and accumulated, exceed the maximum container storage inventory established underthis Condition. (d) The Permittee shall not treatwastes in containers, except by processing in the incineration unit. (e) The Permittee may receive and storewastes in containerswithout intending to treat said wastes. The Permittee may ship these wastes to another permitted facilityfortreatment, storage ordisposal. The Permitteewill handle said wastes in accordance with the practices and procedures in Sections C and D ofthe Part B permit application. C.2 Waste Identification ORC Sections 3734.02(F) and 3734.05(H) and OAC Rule 3745-50-43 The Permittee shall store in containers only the hazardous waste codes specified with process code S01 in Section A ofthe Part B permit application. The Permittee is prohibited from storing wastes in containers inconsistentwith the restrictions and prohibitions in Table CH of Section C ofthe Part B permit application. '·



### VES016608Ross lncileration Services, Inc. Hazardous Waste Installation & Operation**Perm~** Renewal Page 39of 101


### C.3 Condition ofContainers OAC Rule 3745-55-71 Ifacontainer holding hazardous waste is not in good condition (e.g., severe rusting, · apparent structural defects) or if 

### it begins to leak, the Permittee shall transfer 

### the hazardous waste from such container to a container that is in good condition or otherwise manage the waste in compliance with Sections 

### D and 

### F of the Part 

### B

· permit application, the conditions of this Permit or the hazardous waste facility

chapters of the OAC. C.4 Compatibility ofWaste wjth Containers OAC Rule 3745-55-72 The Permittee shall use containers that are compatible with the hazardous waste to be stored. C.5 Management of Containers OAC Rule 3745-55-73 {a)

(b)

(c)

(d) 

### All containerstorage shall beconducted within the containerstorage units as described in Condition C.1. ofthis permit and Section 

### Dofthe Part 

### Bpermit application. The Permittee shall keep all containers closed during storage, exceptWhen it is necessary

### to add or remove waste, and.shall not .open, handle, or.store containers in a mannerwhich may rupture the container or cause it

### to leak. Lab-pack wastes received atthe facility shall be handled in compliance with applicable storage requirements and Sections C and 

### Dofthe Part 

### Bpermit application. The Permittee shall conduct the following container management activities in accordancewith the procedures and practicesspecified in Section D 

### ofthe Part B 

### permit application: container storage and receiving, repackaging of wastes, transportation ofwastes through the facility and special handling of containers. Repackaging ofwastes may only 

### be conducted in the following areas: (i) 

### All concrete areas surrounding the incinerator; ·



## _

.._.,,,.. 

### ··---·-----------**VES01660~**Ross \ncineratlon Services, tnc. Hazardous Waste Installation & Operation Permit Renewal Page 40 of 101


### (ii} Concrete pad west ofthe old process dock; 

### OHIOEPADHWM 

# ww 16 ZOG7

(iii} 

### Concrete pads east or west ofthe process dock; (iv} 

### Concrete pad at the staging areas In the Container Storage Facility; (v) The concrete loading/unloading area bythe closed loop scrubberwater system; (vi) The concrete loading 

### I unloading area by and In the Caustic Building; (vli) Repack.5]9ing room; (viii) Within the Process Dock Building. C.6 Containment Svstems OAC Rule 3745-55-75 and ORC Section 3734.05(H} {a) The Permittee shall maintain lhe containment systems In accordance with the plans and specifications.contained in Section D 

### ofthe Part B permit application. {b} The Permittee shall maintain the containment systems as described in the Part B permit application, designed with sufficient capacity to contain ten percentofthe total volume of the 

### containers orthe volume ofthe largest container, whichever is greater. The containment systems shall be free of cracks and gaps and sufficiently impervious to contain leaks and spills and accumulated precipitation until the collected material is detected and removed. (c) Spilled or leaked waste and accumulated precipitation shall be removed from the sump or collection areas In a timely manner and in accordance with the procedures and practices specified in Section 

### Dofthe Part 

### Bpermit application. (d) 

### No hazardous wastes with free liquids shall be stored in the Bulk Storage Area. 

### C.7 Reserved C.8 Inspection Scbedules and Procedures OAC Rules 3745-54-15 and 3745-54-73 As 

### required by OAC Rule 3745-54-15, the Permittee shall inspectthe container storage areas in accordance with the inspection schedule contained in Section F of the Part B pennit application to 

### detect leaking containers and deterioration of containers and the containment systems caused by corrosion or otherfactors. The Permittee shall note the results ofthese 

### inspections in the inspection log along with any remedial action taken in accordancewith the procedures contained in Section Fofthe Part B permit application. Each container in storage for six months or more

VES016611Ross Incineration Services, Inc. 

### OHIO 

### EPADHWM**~m"** 

# ,(\ zaa1 Hazardous Waste lnstallallon & Operation Ponnlt Renewal · Page 41 of 101



### shall be inspected and stored in accordance with Section F-2b{1) of the Part B permit application and the inspection results shall be recorded in the facility operating record. C.9 Recordkeeping OAC Rule 3745-54-73 The Permittee shall complywith all recordkeeping requirements ofOAC Rule 3745- 54-73 as part ofthe facility operating record and anyother documentation showing compliance with the requirements of permit Condition C.13. and OAC Rules 3745- 54-17(8) and 3745-55-77. C.1 0 Special Container Provisions for Ignitable or Reactive Waste OAC Rules 3745-54-17 and 3745-55-76 {a) The Permittee shall not locate containers holding ignitable or reactive waste within 15 meters (50 feet} ofthe facility's property line

.

.(b) The Permittee shall take precautions to prevent accidental ignition or reaction ofignitable or reactive waste and shall folloWthe storage procedures and practices specified in Sections C, D and F of the Part B permit application. C.11 Special Container Provisions for lncompaljble Waste OAC Rules 3745-55-77 and 3745-54-17 {a) (b)
(c)



### {d) The Pennittee shall notstore incompatible waste except in accordancewith OAC Rules 3745-54-17(8) and 3745-55-77. The Permittee shall not place hazardous waste in an unwashed container that previously held an incompatible waste or material. The Permittee shall separate containers of incompatible wastes from each other and from other incompatible materials in accordance with the procedures and practices specified in Sections C, D and F of the Part B permit application. Only oxidizer and organic peroxide wastes shall be stored in the Oxidizer Storage Building. Such storage shall be in accordance with the procedures and practices specified in Section D ofthe Part B permit application. C.12 Reserved.



### VES01661Ross Incineration services, Inc. Hazardous Waste lnslallatlon &OperaUon Penntt Renewal Page 42 of 101



### C.13 Closure and Post-Closure

. OAC Rules 3745-55-10, 3745-55-11, 3745-55-78 

## NOV 16

# 2001

(a) · At closure of the container storage areas, the Permittee shall remove all hazardous waste and hazardous waste residues from the containment systems, in accordance 

### with the procedures in the Closure Plan set forth in Section I ofthe Part B 

### permit application. (b) 

### If the Permittee demonstrates that all contaminated soils cannot be 

### practically removed or decontaminated in accordance withthe Closure Plan in Section.

### Iofthe Part

### Bpermit application, the Permittee shaH close the unit and perform post-closure care following a plan approved by the Director of Ohio EPA.

VES01661:Roas Incineration Senrices, Inc. Hazardous Waste lnstellaUon & OperaUon Pennlt Renewal Pqe43of101 · 

### MODULE D • TANK STORAGE, TREATMENT AND MANAGEMEfiiT D. MODULE HIGHLIGHTS A total of 49 hazardous waste tanks are included in this permil There are 45 storagetanks and 4tanks that are both storage and treatmenttanks. All tanks are above-ground tanks. All of the tanks have been provided with a secondary containmentsystem constructed ofa reinforced concrete liner externaltothetanks and a reinforced concrete retaining wall around the perimeter. All containment systems have an impermeable coating

### \O makethesecondary containmentsystem Imperviousto thewaste stored. The sec;ondary containment system foralltanks 

### is designed to contain greater than 100 percent of 

### the capacity of the largest tank · within 

### Its boundary plus precipitation from a 25 year 24 hour rainfaU. Wastes managed In most tanks are received from off-site generators, but several tanks are dedicated to on-site generated wastes. Most ofthe off-site generated wastes managed in these tanks are transferred from tanktrucks, but somewastes aretransferred from containers intotankstorage. Wastes managed in thesetanks fall Into one or more of the following categories: high or low BTU wastes, halogenated wastes, flammable and/or ignitable wastes, fly ash sludge, and/or scrubber water. A system Is in place to evaluate wastes for potential incompatibilities prior to placing wastes in these tanks. One treatmenttanktreats residuals from the incineration process Including fly 

### ash, sludges and scrubberwater. Three treatmenttanks are part ofthe vacuum pump system fortransferring wastes, including high and/orlow BTU wastes, halogenated, flammable and/or ignitablewastes, from drums, tanktrucks and othercontai.nersto the tank storage system. All tanks are equipped with appropriate overfill prevention and, where required, over-pressure systems. 0.1 Process Capacjtv!Annual UmitatioruWaste ldentificaffon ORC Section 3734.02(F) and OAC Rule 3745-50-43 (a) The Permittee may store atotal volume 

### cif 1,125,040 gallons of hazardous waste in 49 tanks and treat a total volume of 122,DOO.gallons of hazardous waste per day in 4tanks, subject to the terms ofthis Permit and asfollows:

', 

## ' OHIO EPAOHWM 

## S£tl 30 2003

VES01661:Ross lndneraUon Sllnllcee, Inc. Hazardoua Waste lnataii.Uon &Operation Pormk Ronowal Pago#ol101 ·**':p"""'~F"--...,-•-~l'T"-,- ~C~** **--~-_,.,-r~~7""-- -~-.-.-** **~ro--"1::-7'"-;7:-~ll'"'-,;:::;--~ :T~,_.,.....** **-:~·-·-~........,~-l**

1 -:.. - t 1•**:;'_,;:;~)\h;-j..;** I**l";l.(l.._of~ffi<l•\! 1**  1**l\~11?r!l:F!;:·-,I,1!-.:** ]I**~~~~nm·** J**·~;~T~rLI.':t~:J•·** ,**\~t·Jtlttttrw·** I ;;**,~t:-".£1r-r:"(_l~ •LH.t•~~,rrr.--:"**  11**~'t' ·~**  j
- Dl::iil;.:**Jilt::W~.tS ~**  

### (

. '"( " 

## lt**~-~i'-"-'-..l._ ~~~**  _:J.:J.;;;

-**~~~.,1·--** -**~-** ;.J "-·**·---.c.~---,** Tank F111111l Ta(llcs 23-38

Tank Farm II Tanlcs37-50

Tank Farm Ill Tanks 51-64

Tanks 67 and 68

Tank75

Tank70 Hazardous waste storage lllld lroatmenltankCondenaation Tank . 9,920oach
9,920oach

9,920oach



## '

S.OOOoach

617,000

9,920 gallons for storage; (Combined trelllmant capecilyof tanks 70, 73

and741s 72,000 gallons

pordsy.) 10ft. (dlam) x 22.5 ft.
10ft. (dlam) X 22.5 ft.

10ft.(diam) x 22.5 ft.

7ft. (dlam) X

17.9 ft.
50 ft. (dlam)

### x<12 ft.

10ft. (dlam) x 22.5 ft. Yes -In plate
Yes-lnplate

Yes-lnplate

Yes ·Inplace

Yes -In place High BTU halogenated,

flammable and/or Ignitable 

# ·- High or Law BTU halogenated,

flammable and/or lgnilable waoteo Low BTU halogenated,

ftammable and/or lgnltoble wastes Flyesh wdge and scrubber waterprlorto IIIIer pressing Fly eah oiUdge and scrubber water and/or sludge

CondensoUon vapors 

### !rOm Yes -In plaoa lanks73 & 74, high orlow BTU

halogenated,

ftammable andior lgnkable 

# - Juno,1982 (Elclsting tanks forOAC Chapter· 37<15-55) Deoambet, 1987 (New tanks for OACChapter

37<15-55) Dooamber, 1987 (Newtanks lor OACChapter

37<15-55)**Aprl~** 198e (E>dstingtank

forOAC ·Chapter 3745-56) September, 1986 (New tank lor**OACCh,~r**

37<15-55

Deoamber, 1987 (New lankfor OACChepter

3745-55)



### OHIOEl'P.OHWM 

# Str 30Z003 ........



### VES01661Roaa lnclnera1lon Services, Inc. Hazardous Waste Installation & OperationPermit Ronewal Page 45 a! 101



# -----**~----** 

# r -----**-----------~-** 

# -------**--=--------~-** 

## ---,--------·------**'pf~TlFt(\•(\1~\''** : - L**S>·:~,~;R, '1~":1.;.~.:;J~"t·!·1!:**  ] 1**:~m~,ni:\r** 1 -&1..,1 

### \_,,J.H, 1**~~lr·~L~~lr~~,-- •">t·~W~ll-:-r,"i!fl**  )'**~ J~r-~;**  IL•J·J• , 

### zJ.**~l!.J~';f** ._'J**~1** 

# i

1

__**i.ll!i._~~~~~_,_~(.€di:\':** ..**l~L.**. .J

__ ,

__**J:;i_\L!Jk...;._~.._-~~- ~,__-'~** **---1~~.:..~~_]** Tank73&74 7,600each 10 fl. (diem)X Yoa ·Inplace High and/or low December, Hozardous gallonsfor 10.5 fl. 

# Bl\J-. 1g87 -storage· atarage;
. halogllllllWd, (Nowlllnka tor andb'aalment (Combined ftammable OACChepter lanka-Vac:uwn llaalmont end/orlgnitabla 3745-66) Tanka ·capaclly a! 

# - -70,73

and741a 72,000 gallons ""rday.)

· .. Tank79 58,<102 gallons 20ft. (dlam) x 24 Y oa ·Inplace Fly 8lhsludge, 1988 Hazardous for storage;

. fl. aaubberwater, (New1anktor waste 111l>raga (Traalment and/orsludge OACChap!Br and lraatmant capadtyla genaraladcn- 3745-55) tank- Surge 50,000**~;"'"** site for= ltank · 

## ,.,.dav. treatment

. 

### (b) The Permittee shall store in tanks onlythe hazardouswaste codes specified in Section A of

### the Part B application with process code S02. The Permittee shalltreat In tanks only the hazardouswaste codes specified In SectionA of the Part B 

### permit application with process code T01. (c) The Permittee ls 

### prohibited 

### from storing ortreating intanks haZardouswaste that is not identified inthis permitcondition. The Permittee Is prohibitedfrom anystorage ortreatment ofwastes in tanks inconsistentwith the restrictions and prohibitions In Table C1-1 

### of Section C 

### ofthe Part B 

### permitapplication. The Permittee shall not store characteristically corrosive wastes orwastes with a corrosion rate greater than 

### 50 mUs per year in tanks. 0.2 Desian and 

### Installation of NewTank Svstems or Components OAC Rule 3745-55-92 (a) 

### The Permittee shall construct any future new tank systems in accordance with Section 

### D-2c ofthe Part 

### B permit application. 

### (b) Priorto the operation of

### any newly constructed 

### tank system, the Permittee shall submitto Ohio EPA the certification of installation of the tank system inaccordancewith OAC Rule 3745-55-92(8)

### to ensure that proper handling procedureswere adhered to in orderto preventdamagetothe system·during · installation. ,

## '

. •, 

### OHIO.EPADHWM 

## Sl:.r 3 o 2003 ·

.... 

## --·------------------.-
VES01661Ross lndnenlllcn Services, Inc. Haurdoua Waalelntfllllatlcn &Operation Permit Renewal Page <16 of 101.


### 0.3 Containment and Detection of

## Releases OAC Rule 3745-55-93 (a) 

### NewTank Systems 

### The Permittee shall operate the secondary containment system In accordance with the requirements of

### OAC Rule 3745-55-93(8) through (F), 

### the detailed design plans and descriptions contained In the 

### Part B 

### permit application and Sections D 

### and F 

### ofthe Part B 

### permit application. 

### New tanks atthe facility are**Ta~** 

### 37-64, 

### 70, 13, 74, 75 and 

### 79

.. (b) 

### Existing Tank Systems wjt!J 

### Secoodarv Containment 

### The Permittee shaft operate the secondary containment system In 

### accol'dancewith the requirements of

### OAC Rule 3745-55·93{8) through (F), the detailed design plans and descriptions contained in the Part B permit application and Sections Dand Fofthe Part Bapplication. Existing tanks at the facility are Tanks 23-36, 67 and 68. 0.4 Operating Requirements OAC Rule 3745-55·94 (a) The Permittee shaft notplace hazardouswastes ortreatment reagents in the tank system if 

### they could cause the tank, 

### its ancillary equipment, or a containment system 

## to rupture, leak, corrode or otherwise fail. (b) The Permittee shall prevent spills and overflows from the tank or containment systems using 

### the methods described In the Part B 

### permit application. The Permittee shall complywith the requirements of

### OAC Rule 3745-55-96 if

### a leak or spiU occurs In 

### the lank 

### system. ·. (c) The Permittee shall operate and maintain alltanksystemslisted in Condition D.1 in accordance with 

### the procedures, practices and design conditions Identified in Section 0 ofthe Part B permit application.

'· 

## ' OHIOEPAOHWM 

# S[r a o

zo03 ........\



### VES01661

# M4{PY -)4. 

# rJ'f'N 'f'"'""t,-ti'( Ross Incineration Services, Inc. Hazardous Waste Installation & Operation Permft Renewal Page 47 of 101
0.5

. Inspection Schedules and Procedures OAC Rule 3745-55-95 (a) The Permittee shall inspect the tank systems in acco!dance 

### with the Inspection Schedule in Section 

### F ofthe Part

### B permit application and shall complete the itemsin permit Conditions 0.5(b) and 0.5(c) as part ofthose inspections. (b) The Permittee shall inspect the overfill controls In accordance with the procedure and schedule inthe Part B permit application. (c) The Permittee shall inspect the foUowing components of the tank system once each operating day: · 

### (i) (ii)

(iii) Above-ground portions ofthe tanksystem, 

### ifany, to detect corrosion

·. or releases 

### ofwaste; ·

Data gathered from monitoring and leak detection equipment**(e.g~.** pressure ortemperature gauges,monitoringwells) to ensurethatthe tank system is being operated accon:ling to its design; and Construction materials and the area .immediately surrounding the externally accessible portion of the· tank system, including the secondarycontainmentsystem, to detecterosion orsigns of releases 

### of hazardous waste (e.g., wet spots, dead vegetation). (d)· The Permittee shall document compliance with permit Condition 0.5 in the operating reco!d ofthe facility

.

. (e) The Permittee shall monitorandtestthetanksystems in accordancewiththe Tank Corrosion Inspection Plan in Appendix 0-1 of Section D ofthe Part 

### B permit application. 

### (f) The Permittee shall immediately remove from service any tank with a wall thickness, as determining from UT thickness testing or internal inspection, that is less than the design minimum wall thickness for either the top, shell or bottom 

### ofthetank. The applicable design minimum wallthickness forthe tank corrosion monitoring program is: the value specified in Tables 02-2 through 02,.8 in the application for the minimum design top thickness, minimum design shell thickness and minimum design bottom thickness,

VES01661'Ross Incineration Services, Inc. Hazardous Waste Installation & Operation PermH Renewal Page 48 of 101 Revlslon4 December 30, 2004 respectively; or, for Tanks 23-36, the value of 0.25 inches for the top of tanks 

### with agitators, 0.123 inches for the top of tanks without agitators, 0.137 inches for the tank bottom, 0.119 inches forthe upper portion ofthe tank shell, and 0.19 inches for the tank shell bottom portion at the leg attachment.


### 0.6 Response to Leaks or Spills OAC Rule 3745-55-96 (a) · In the event of a leak or a spnl from the tank system, from a secondarY containment system, or if a system becOmes unfit for continued use, the

· Permittee shall remove the system from service immediately and

.

complete the following actions:. (i) · Stop the flow of hazardous wasta .into the. tank system or ·secondary containment system and Inspect the system to determine the cause ofthe release. (li) ·If the release was from the tank system, the owner/operator must, within twenty-four hours after detection ofthe leak, or, ifthe

.. ·-·-·--· ·---·- 

### - 

## ------------ -----------·- --··--


### VES016611.-···· Rooa Incineration SON!cot, Inc. Hazardou• WubllnataUatlon & Opllfllllon**Penn~**Renewal Paga49of 101 ·. 

### owner/operator demonstrates that It is 

### not possible, at the earliest practicable time,· remove as much of the waste as is necessary 

### to

. preventfurther release 

### ofhazardouswaste to

### the environmentand

### to ·

allow inspection and repair ofthe tank system to be performed. Ifthe material released,was to a secondarycontainment system, all released materials must be removed withintwenty-fourhours or

### In as timelyamanneras possibleto prevent harmto human health and the environment. (Iii) Contain visible releases 'tp 

### the environment The Permittee shaH Immediately conduct a visual inspection 

### of aU releases 

## to the environment and, based on that inspection: (1) prevent further

.migration ofthe leak or spill 

## to soils or surface water and (2) remove and properly dispose of any visible contamination of the soil or ·surface water. (b) Unless the requirements of permit Conditions D.6.(b)(i) through D.6.(b)(vi) are satisfied, the Permittee shall close its 

### tank system in accordance with 

### OAC Rule 3745-55-97 and its 

### Closure Plan if

### there has been a leak or spiff from the tank system, from a secondary containment system or 

### ifa system becomes unfitfor continued use. ·(I) 

### For a release caused by a spill that has notdamaged the integrity of the system, the Permittee shall remove the released waste and make any necessary repairs to 

### fully restore the integrity of the system before returning the tank system 

## to service. (ii) 

### For a release caused by a leakfrom the primary 

### tank system to 

### the secondarycontainmentsystem, the PermitteeshaH repairthe primary 

### system prior

## to returning It 

### to service. (iii) For a release to the environment caused by a leak from the aboveground portion of the tank system that does not have secondary containment, and can bevisually inspected, the Permitteeshall repair the tank system before returning It 

### to service. (IV) 

### If the Permittee replaces acomponent

### ofthetanksystem

## to eliminate the leak, that component mustsatisfythe requirements for new tank systems or components in OAC Rules 3745-55-92 and 

### 3745-55-93. ' 

## 'OHIO Ef>ADHWM



## Sl:.t' 3 0 2003

VES01661RosslnclnetaUon Sorvlees, Inc. Hazardous Waste Installation & OpGraUon PennR Re!IOVIIII Page so of 101 

### (c) For all major repairs to eliminate leaks or restore the integrity of the tank system, the Permit!ee must obtain a certification by an independent. qualified; registered professional engineer in accordance with OAC Rule 3745-50-42(0) that the repaired system Is 

### capable of handling hazardous wastes without release for the intended life ofthe system before retuming the system to service. Examples of major repairs are: installation of.an internal liner, repair of a ruptured tank or repair or replacement of a secondary containment vault 0. 7 Recordkeeplng and 

### Reporting , OAC Rules 3745-55-96, 3745-55-91(A),and 3745-55-92(G) (a) The Pennittee shall report

## to the Director, Within 24 hours ofdetection, when aleakor spill occursfrom thetanksystem orsecondary containmentsystem tothe.environment. (A.leakorspill ofone pound orless

### ofhazardouswaste, that is Immediately contained and cleaned-up need· not be reported. Releases that are contained within a secondary containment system need not·be reported). (b) Within 30 days of 

### detecting a release 

## to the environment from the tank system or secondary containment system, the Permittee shall report the following infonnatlon to the Director: {i) likely route ofmigration of

### the release; (ii) 

### Characteristics of the surrounding soil {including soil composition, geology, hydrogeology, and climate); (iii) Results of any monitoring or sampling conducted in connection with the release. Ifthe Pennittee finds itwill be impossible to meet this time period, the Pennittee should providethe Directorwith aschedule ofwhen the 

### results will be available. This schedule must be provided before the required 3o-day submittal period expires; (iv) 

### Proximity of downgradient drinking water, surface water, and populated areas; and · (v) Description ofresponse actions taken or planned.



### •. \ 

## Str> 30 2003

VES01662Ross lnclnenlt!on ServlCIII, Inc. Hazardous Willie lnslallatlon &Operatlcn Pennlt Renewal Page 51 of 101 

### (c) The Permittee shall submit

### to the Director all certifications of major repairs to correct leaks within seven days from returning the tank system to use. (d) The Permittee shall obtain, and keep on.file at the facility, 

### the written statements by those persons required 

### to certify the design and installation ofthe tank system. 0.8 Closyre and Post..Ciosyre Care OAC Rule 

### 3745-55-97 (a) At closure of the tank system(s):·.the Permittee shall follow the procedures in the Closure Plan in Section I ofthe Part B pennit application. (b) 

### Ifduring closure of any tank system, the Permittee concludes that not all contaminated soils can be practicelly removed or decontaminated In accordancewiththe Closure Plan, the Permittee shallsubmitawritten permit modification request which includes a demonstration of why removal or decontamination is not practical and a Post-Closure Plan for such tank system. D.9 Specjal TaQk Provisions for Ignitable or Reactive Wastes OAC Rule 3745-55-98 (a) IliaPermittee shall not place ignitable or reactive waste In the tank systeim or In the secondary containment system unless the procedures specified in tile Part B permit application are followed. The Permittee shall document compliance with this condition and place it In the operating record. (b) The Permittee shall comply wltti the requirements for the maintenance.of protective distances between the waste management area and any public ways, streets, alleys, or an adjoining property line that can be built upon, as required in Tables 2-1 through 2-6 of 

### the National Fire Protection Association's "Flammable and Combustible Uquids Code" (1991 or most recent edition) incorporated by 

### reference in OAC Rule 3745-50-11. (c) The Permittee shall followthe fire and explosion prevention procedures and practices In Section D of the Part B permit application when storing or placing ignitable or reactive waste in a tank system.


## '' OHIO EPADHWM



# ..**SE~** 

## 30 Z003

VES016621/JIV( 

### rJJ-v} u - 

## 5e'

;-lf•llr Ross lnclneratlon SeNices, Inc. Hazardous Waste lnstaUatlon & OperaUon Permit Renewal Page52of101 •
0.10 Soecjal Tank Provisions for lncomoatible Wastes OAC Rule 3745-55-99 (a) The Permittee shall not simultaneously place incompatible wastes, or Incompatiblewastes and materials, in the same tank system. Thetanks will be emptied and thoroughly rinsed and visually inspected before wastes that are incompatible with the previous contents ofthetanks are placed in them. The Permittee shaH document compliance with the decontamination requirements and place that documentation into the operating record. (b) The Pennittee shall notplace hazardous waste in atanksystemthat has not been decontaminated and that previously held an Incompatible waste or material unless the requirements of permit Condition 0.1O(a) are met. (c) The ·Pennlttee shall follow the procedures and practices to identify incOmpatible wastes and to prevent simultaneously placing incompatible wastes in the same tank that are ·identified'in Sections C and D ofthe Part B permit application. 0.11 Compliance Scbedule [This Section intentionally left blank.] Tlte Pen

### nitte~**sn~ll** t1se the inspection eriteria listed in Section 0 of the Part B permit appliemion 

### to**~i3tlally eval~:~ate,**  prior 

### to transfer,

..nether

..ater aeetJmulated in the tanl< 

### fern1 containment trench is eontarnin!lted**•t~ith h~rdotts**  uaste. Within 

### 90**de~s** ofthe effective date of tl•ls perntit; the Permittee shaH lll:lbmit 

### to Ohio EPA for revieh, specific proeed1:1res deriv·ed from the inspeeliol1 criteria listed in Section D of the Part 0 per111it 

### application 

### fol* eot,dHcting these inspeetions, 

### ineh:eding doetttnentetion of**rest)~,** identifiCl!tiolt ofthe perso" eondtJcting tlte inspection and thedate ofthe 

### it iSpeetion.

VES01662

# -- Ross Incineration Servlcos, Inc. HazanlouaWaatelnatalla1lon & Operation Pennft Renewal P-53of101


### MODULE E • CORRECTIVE ACTION REQUIREMENTS 

# ·. E.1 CorrectJve Ae!jon 

### at

### the Faej!itv OAC Rules 3745-50-10 and 3745-55-011 In accordance with OAC Rule 3745-50-10 "waste management unit" means any discernible unit atwhich solid waste, hazardous waste, Infectious waste 

### (as those terms are defined 

### In ORC Chapter 3734), construction and demolition debris (as defined In ORC Chapter 3714)**industri~l**

### waste, orotherwaste (as those terms are defined in ORC Chapter6111), hasbeen,placed atanytime, irrespective ofwhether the unitwas Intended forthe managementofwaste orhazardous

### waste. Such units include any area at a Facility at which wastes have been routinely and systematically released. For the purpose of Corrective Action, Facility is defined as all contiguous property under the control of the .owner or operator seeking a permit under Subtitle C of 

### RCRA. The terms Interim Measure (IM), RCRA Facility Investigation (RFI), Corrective Measures Study (CMS) and. Corrective Measure Implementation (CMI) are defined in the Ohio Corrective Action Plan (OCAP). The Permittee must InstitUte Corrective Action as necessary 

### to protect human health and the environment for all releases of 

### hazardous wastes or hazardous constituents from anywaste management units (WMUs) atthe Facility, regardless ofthe time.atwhlch waste was placed in such units. E.2 Correct!ye Ac!ion Bevond the Facilitv Boundarv OAC Rules 3745-55-011 The Permittee must implement Corrective Action(s) beyond the Facnity property boundary, where necessary to protect human health and the environment, unless the Permittee demonstrates 

## to the satisfaction of Ohio EPA that, despite the Permittee's best efforts, the Permittee was unable to obtain the necessary permission to undertake such actions. The Permittee is (lot relieved of all responsibility

## to clean up a release that has migrated beyond the Facility boundary where off-site access isdenied. On-site measuresto address such releaseswill be addressed underthe RFI, CMS, and CMI phases, as determined to be necessary on a case-by-case basis,

'· 

## 'OHIOEPADHWM 

## S!:.P 302003

VES01662Rosa Incineration Setvloes, Inc. Hazardous Waste lnstaRaUon &Operation PennftRenewal Page 54 

### ot 101 · 

### E.3 Jgent!ficatlon ofWMVs ·

. OAC Rules.3745-50-44(d) & 

### 3745-55-011

USEPA prepared an RFA (RCRA Facility Assessment) report forthe Permittee's faciUty dated July 21, 1987. 

### The RFA identified potential releases and potential release pathways including groundwater, soils, surfacewaterand air. Based onthe results ofthe RFA. the Permitteewas required

## to implementanRFI. Consequently aCorrectiveAction Program requirementwas added to SecUonVI ofthe U.S. EPA RCRA Part B Permit issued 

## to the Permittee on September8, 1988. The Permittee began Implementation of the RFI by preparing the Facility Background Report thatwas submitted to U.S. EPA on May 3, 1989. The Facility Background Report provided an historical site profile and environmental setting of the facility. The historical site profile provided a.description ofownership, facility operation, a.site descript!on, a summmy ofsolidwaste management units (SWMU) and the volume and types of wastes handled, and a chronology of the waste management practices that have been conducted throughoutthe life ofthe facility. The environmental setting provided an initial description of the hydrogeological, geological and meteorological characteristics ofthe site. The F acilily Background Report Indicates that various waste treatment and waste management practices have occurred at the facility since 

### it began operating in 1949. Consequently, different sections of the site have had multiple and overlapping uses during the years of operation. The Permittee's RFI Work Plan designates four SWMU Areas where 

### past waste management practices occurred

. and SWMUs are located. A summary of the SWMUs within each of the four SWMUA Areas, including Information on waste management unit type, general dimensions, s!XUctural description, time periods ofoperation and an abbreviated list of wastes managed in the urilt, is provided In Table J3-1 ofSection 

### J ofthe Part B permit application. Detailed SWMU descriptions are found In 

### the Permittee's FacilityBackground Report, Section2.4 "ChronologyofKnown Waste Management Practices" (Pages 2c

### 18through 2-42). 

### Pastwaste management practice areas are represented spatially in Figure J..1 In Section J 

### ofthe Part B permit application. 

### E.4 

## Reserve!f. E.5 · 

## BEl

. OAC Rule 3745-55-011 The PeflYlittee began implementation ofthe RFI required by SectionVI,ofthe U.S. EPA RCRA Part B Permit issued to the Permittee on September 

### 8• 1988 by 

### OHIO EPADHWM 

## SEr 302003 · .._!**VES0166~**Ross Incineration SeNices, Inc. Hazardous Waste Installation II. Operation Permit Renewal Page 55 of 101 

### preparing the Facility Background RepC?rt that was submitted 

### to U.S. EPA on May 3, 1989. Subsequent to preparation of the Facility Background Report, the Permittee submitted a report entitled 'Investigative Analysis" to U.S. EPA on February 7, 1990. The 'Investigative Analysis" report provided an assessment of the nature and extent of contamination of the Permittee's facility based on multimediasampling and analytical data collected in and around SWMUsfrom 1986 through 1989. The "Investigative Analysis" also evaluated potential risks posed 

### by site contamination to human health and the environment.

. Subsequent to the "Investigative Analysis" report the Permittee submitted a proposed RFI Work Plan to U.S. EPA and Ohio EPA on September25, 1991. The proposed RFI Work Plan included results ofmultimedia sampling and analysis from 1986 through 1991 and a site characterization based on this data. The proposed RFI Work Plan site characterization data constitute the initial phase ofthe RFI work at the facility and is often referred to as Phase 1. After responding to several Notices of Deficiency from U.S. EPA, the Permittee submitted a revised RFI Work Plan on November 3, 1993 which was approved by U.S. EPA on March 3, 1994. The site characterization work completed under the November 3, 1993 work plan is often referred to as Phase II ofthe RFI. Characterization underthe November 3, 1993 RFI Work Plan included multimedia sampling and analysis in and around SWMUs and the Equipment Storage Area (ESA), further sampling of site surfece waterbodies,further analysis ofgroundwater characteristics, groundwatermodeling and an assessment of human health and ecological risk. The Permittee conducted the activities identified in the November3, 1993 RFI Work Plan in 1994 and 1995 and submitted an RFI Report to U.S. EPA and Ohio EPA on December 7, 1995.

· In May 1997 U.S. EPA and Ohio EPA provided comments to 

### the Permittee on the

December 7, 1995 RFI Report and on the scope of the RFI. U.S. EPA and Ohio EPA haveworked with the Permittee since 1997 to definethe final scope ofthe RFI, address data gaps in site characterization and improve the ecological risk assessment. To address U.S. EPA and Ohio EPA concerns, the Permittee has prepared a Work Plan Addenda for U.S. EPA and Ohio EPA review which represents the third stage (Phase Ill) of RFI activities at the facility. On December 9-12, 2003, the Permittee conducted the Phase 111 sampling for the RFI based on the approved RFI Work Plan (dated November 3, 1993) and the approved RFI Work Plan Addenda (dated July 2, 2002). ·RIS submitted the results of the Phase Ill sampling and analysis to Ohio EPA by letter dated February 13, 2004. In aletter dated March 30,2004, Ohio EPAstated: "Ohio EPA is satisfied that Ross Incineration Services has completed all required sampling and analysis work identified in the approved RFI work plan including Phases II and Ill ofthe work plan. The data package submitted to Ohio EPA meets the goals of the approved work plan and should be useable in completing the RFI Report for the RIS facility including facility characterization, evaluation and assessment of ecological and human health risk. There is no present need to collect additional RFI data."

VES01662'··-

...·· Ross Incineration Services, Inc. Hazanlous WastelnstallaUon &Operation Permit Renewal Page 56 ol101 

### (



### Permittee will prepare and submit RFI progress reports 

### to Ohio EPA on a monthly basis during Work Plan Implementation activities. Otherwise, RFI progress reports will be prepared and submitted to Ohio EPA on aquarterly basis. Upon completion ofthe Phase Ill work, Permittee will prepare a revised RFI Report, which is expected

.to bethe Final RFI Report, and submititto Ohio EPA in accordancewith the revised 

### Phas!!!.tl( Work Plan S¢hedUI!!! {Augvst7, 2004). The Permittee mustconduct an RFI 

### to thoroughly evaluate the nature and extent of the release of hazardous wastes and hazardous constituents from all applicable WMUs identified in Permit Condition E.3. above and Permit Condition E.10. The majortasks and required submittal dates are shown in Permit Condition E.5(a), (b) and (c) below. The scope of work for each of the tasks is found in the RFI workplans approved by USEPA priorto the effective date ofthis permit, orfor newly Identified waste managements units identified in Condition E.1 0, in the RFI section ofthe Ohio EPA Corrective Action Plan. (a) RFI Workplan Corrective Action oversight will transition to Ohio EPA on the date the renewal is issued final. Ohio EPA will accept all documents and activities completed in accordancewithworkplans submitted and approved underU.S. EPA authority prior

### to the issuance of this permit. In the case of a newly discovered waste management 1..\nit the Permittee must submit a written RFI Workplan 

### to Ohio EPA pursuant 

### to a schedule established by Ohio EPA. Ohio EPA may determine based on site-specific

. facts that an update to the RCRA Facility Assessment (RFA) is necessary prior 

### to preparation ofa RFI Workplan. (i) If necessary, Ohio EPA shall provide written comments on the RFI Workplan to the Permittee. (ii) Within 45 days of receipt of any Ohio EPA comments on the RFI Workplan, the Permittee must submit either an amended or new RFI Workplan that incorporates any Ohio EPA's comments. (iii) 

### Ohio EPAwill approve or modifyand approve, inwriting, the amended or new RFI Workplan. The RFI Workplan, as approved oras modified and approved, shall be incorporated into this permit and become an enforceable condition of this permit. Subsequent changes to the

. approved RFI Workplan must be authorized by Ohio 

### EPA.

VES01662Ross Incineration Services, inc. Haz.ardous Waste Installation &Operation Permlt Renewal Page 57 o!101 

### (b) RFIImplementation The Permittee must implementthe RFI Workplan accordingtothe terms and schedule in the approved RFI Workplan. The Permittee shall implement any RFI Workplan approved pursuant to Condition E.5(a) according tothe terms and schedule In such approved RFI Wcirkplan. (c) RFI Final Report The Permittee shall submit an RFI Final Report 

### to Ohio EPA for the work completed pursuant to the REI Workplan apprbved 

### by U.S. EPA according totheterms and schedule iritheapproved RFi Workplan Addenda dated July 

## 2, 2002 and the revised Phase Ill REI Work Plan Schedule in Attachment 1 of 

### Section 

### J ofthe permit application. Forany REI Workplan approved pursuantto Condition E.5(a), within 60 days · after the completion of the RFI, the Permittee shall submit an REI Final Report to Ohio EPA. The RFI Final Report shall describe the procedures, methods, and results ofthe RFI. The Final Report for the work completed pursuant to the RFI Workplan approved byU.S. EPA andforworkcompleted pursuantto**~:~ny** 

### RFI Workplan approved pursuantto Condition E.5(a) must contain adequate information

### to support further decisions concerning corrective action at the· Facility. In the case of a newly discovered unit, the Permittee shall submit an RFI Final Report 

### to Ohio EPA within sixty (60) days after the completion ofthe RFI. The RFI Final Report shall describe the procedures, methods, and · results ofthe RFI. The Final Report must contain adequate information 

### to support further decisions concerning corrective action at the Facility. (i) (ii) 

### If necessary, Ohio EPA shall provide written comments on the RFI Report 

### to the Permittee. · Within 60 days ofreceipt ofOhio EPA's comments,the Permittee shall

. submit either an amended or new RFI Reportthatincorporates Ohio EPA's comments.

VES01662

### , ....,.



# -- Rcaa Incineration SeMces. Inc. HaurdouaWaste lnalallat!on &Operallon Ponnll Renewal Page 58of 101


### ' (iiQ Ohio EPA shall approve or modify and approve, In writing, the amended or new RFI Report. The RFI Report, as approved oras modified and approved,

, shall 

### beincorporated into this permit and become an enforceable condition

ofthis permit Subsequent changes 

### to the approved RFI Report must be authorized by Ohio EPA. E.8 lnterjm Measures CIM) Based on the RFI Final Report or other Information documenting a release of hazardous waste or constituents

## tothe !!nvlronment, Ohio EPA may require (orthe Permittee may propose) the developme,nt and Implementation ofan IM (this may include an IM Worl<plan) at any time during 

### the life of the permit 

### to mitigate or eliminate a threat to human health or the environment The Permittee must implement the IM upon atime frame established by 

### Ohio EPA. E.7 Peterrnina!IOn 

## of No Furtber Action {a) Permit Modification Based on the results ofthe completed RFI and other relevant information, the Permittee may submit an application 

### to Ohio EPA for a permit modification underOAC Rule 3745-50-51 

### to terminatethe Corrective Action

, tasks that the Permittee 

### is obligated bythis permit to complete. This permit modification application must conclusively demonstrate that there are no releases of hazardous waste orconstituents from WMUs atthe Facilitytllat pose an unacceptable risk 

## to human health and the environment. 

### If,,based upon reviewofthe Permittee's requestforapermit modification, the r&Sults of the completed RFI, and other information, Ohio EPA determines that releases or suspected releases which were investigated either are nonexistent or do not pose an unacceptable risk to human health and the environment, Ohio EPAwill approve the requested modijication. Decisions regarding the completion of RCRA Corrective Action and no further action may be made for the entire Facility, for a portion of the Facility, or for a specific unit or release.

'

## 'OHIOEPADliJII-'1



## , St.r 3 0Z003

VES01662Rosa lnclnerallon Selvlcea, Inc. Hazardous Waolll lnslallaUon &Operation Permtt Renewal Page 59 of 101 

### (b)

.

### Periodic Monitoring A detenninatlon of no further action shall not preclude Ohio EPA from requiring continued or periodic monitoring of air, soil, ground water, or surface water, 

### if necessary

### to protect human health and the environment, when site-specific circumstances Indicate that a potential or an actual release of hazardous waste or constituents 

### exists. (c) Further Investigations A determination of no further aptlon shall not preclude Ohio EPA from requiring further Investigations, studies, or remediation atalaterdate, 

### if new information or subsequent analysis Indicates that a release or potential release from aWMU atthe Facility may pose an unacceptable 

### risk. to human health or the environment In such a case, Ohio EPA shall Initiate a modification to the terms 

### ofthe permitto rescind the determination made in accordance 

### with Permit Condition·

### E.7(a). Additionally, in the event Ohio EPA determines that there is insufficient information on which to base a determination, the Permittee, upon notification, is required to develop a Workplan and upon Ohio EPAapproval ofthatWorkplan, perform additional investigations as needed. E.B Corrective Measures study <CMSl If Ohio EPA determines, based on the results of 

### the RFI and any olher relevant information, that corrective measures are necessary, Ohio EPA will notify the Permittee in writing that the Permittee shall conduct a CMS either as described below oras descnbed in Ohio EPA's notification to the Permittee. The purpose of the CMS will be to develop and evaluate the corrective action attematlve(s) and 

### to outline one or more alternative corrective measure(s) that will satisfy the performance objectives speclfiedin Condition E.9. (a) · CMS Workplan The Permittee shall submit a written CMS Workplan to Ohio EPAwithin 90 daysfrom the notification by Ohio EPAofthe requirementtoconductaCMS.



## Slrl 30 Z003.

VES01662Rcaslnclneratlon SelVIces, Inc. Hazan:lous Waste Installation & OperaUon Permit Renewal Page

## eo of 101 (1)


### (2)

(3) 

### Ifnecessary, Ohio EPA shall provide written comments on the CMS Worl<plan to

### the Pennittee. Within 60 

### days of 

### receipt of Ohio EPA's comments, the Pennittee shall submit either an amended or new CMS Workplan ·that Incorporates Ohio EPA's comments. · Ohio EPA shall approve or modify and approve, in writing, the amended or new CMSWorkplan. The CMS Workplan, as approved or.as modified and appi'Qved, shall be 

### Incorporated into this permit and become an enforceaQie condition of this permit. Subsequent changestothe approved CMSWorkplan mustbe authorized by Ohio EPA (b) 

### CMS,Workplan Implementation The Permittee shall implement the CMS Workplan according to the terms and schedule in the approved CMS

### Workplan. (e) 

### CMS Final Report Within 60 

### days afterthe completion ofthe CMS, the Permittee shall submit a CMS Final Report to 

### Ohio EPA The CMS Final Report shall summarize the results of the investigations for each remedy studied and must include and evaluation of each remedial alternative. (1)
(2)



### (3) 

### If necessary, Ohio EPA shall provide written comments on the CMS Final Report

### to tbe Permittee. Within 60 

### days of 

### receipt of Ohio EPA's comments, the Permittee shall submit either anamended or new CMS Final Report that incorporates Ohio EPA's comments. Ohio EPA shall approve or modify and approve, In writing, the amended 

## or new CMS Final Report. The CMS Final Report, as approved oras modified and approved, shall be incorporated into this permit and become an
.enforceable condition of this permit. Subsequent changes to the approved CMS Final Report must be authorized by Ohio EPA.



### OHIO EPAOHWM**s~r** 

# so zooa

VES01663RonlncineraUcn Setvlcas, Inc. HazardousWaste lnslallsllon &OperaUon Pennft Renewal Page61 of 101 

### E.9 Correc!!ve Measures Implementation lCMD The Peonitlee must Implementone ormore ofthe Corrective Measures authorized by Ohio EPA. Ohio EPA shall authorize one or more 

### ofthe Corrective Measures In the c.MS 

### Reportas approved by Ohio EPA pursuant

### to Condition E.

# a(c), and will 

### notifythe Permittee In writing ofthe decision. The Corrective Measure selected for implementation must (1) 

### be protective of human health and 

### the environment; (2) 

### attain media cleanup .standards; (3) 

### control the source(s) 

### of releases 

## so as to 

### reduce or eliminate further releases 

### of hazardous waste(s) (Including hazardous constituent[s]); and (4) 

### comply with all applicable standards for management of wastes that are generated during impiSqlentatlon. Iftwo ormore ofthe Corrective Measuresstudied meetthethreshold criteria set out above, Ohio EPA 

### will authorize the Corrective Measures Implementation by considering remedy selection factors including: (1) 

### long-term reliability and effectiveness; (2) 

### the degree 

### to which the 

### Corrective Measure will 

### reduce the toxicity, mobilityorvolumeof

### contamination (3)

### the Corrective Measure's short-term effectiveness; (4) 

### the Corrective Measure's implementabllity; and (5) 

### the relative cost associated with the alternative. · (a) Permit Modification Ohio EPA will initiate a permit modification, as proVided by OAC Rule 3745-50-51, to require implementation of the corrective measure(s) authorized. · The Permittee shall not implementthe corrective measure until the permit is. modified pursuant 

### to OAC Rule 3745-50-51. {b) Financial Assurance OAC Rule 3745-55-011 Within 45 days after receiving approval of the CMI, the Permittee must provide financial assurance in the amount necessary 

### to Implement the corrective measure{s) as required by OAC Rule 3745-55-011 (B) and (C). E.10 Newly ldentjfjed §WMUs or Releases OAC Rule 3745-55-011 (a) Generallnformation 

### '

## ' The Permittee shall submit 

### to Ohio EPA, withln 30 days of discovery, the following information regarding any 

## newWMU identified at the Facfllty:OHIO EPAOHWI 

## S£P 3 0200:

VES01663

# - 

# - Roes Incineration Services, Inc. Hazardous Waste lnotallaiiOI) & Opera!lon Pennlt Renewal Page 62 of 10t 

### (I) The location of

### the unit on the site 

### topographic map; (ii) Designation of

### the type ofunit; (Ill) 

### General dimensions and 

### structur;ll description (supply any available drawings); (iv) 

### When the unitwas operated; and (v) Specifications of all**wast~(s)**

### that have been managed at the unit

. (b) Release lnfonnatlon The Permittee shall submit to Ohio EPA. within 

### 30 days of discovery, all available infonnatlon pertaining 

## to any release of hazardous waste(s) or hazardous constituent(s) from any new or existing WMU. E.11 Corrective

## Actloo for Newly 

### !denHfred

## WMUS and Releases OAC Rule 3745-55-011 

### If Ohio EPA determines In accordance with Condition E.5 that a RCRA Facility Investigation Is required for newly identified WMUs, the Permittee shall submit a wn'tten RCRA Facility Investigation Workplan 

## to Ohio EPA upon a timeframe established in written notification by· Ohio EPA. Ohio EPA shall act upon the workplan as specified in Condition E.5. · Further investigations or corrective measures will be 

### established by Ohio EPA following the procedures in Conditions E.6 and E.8. Permittee shaD make such submittal in accordancewith timeframes estabHshed by Ohio EPA.



### '

## ' OHIOEPAOHWM

..· 

## SEt' 302003**VES0166~**Ross lncineratton Services, Inc. Hazardous Waste lnstaUfjotlon & Operation Permit Renewal Page 53 of 101 

### MODULE F ·TREATMENT IN MISCELLANEOUS UNIT 

### F. MODULE 

### HIGHLIGHTS Thefilter press treats scrubberwaterfrom the closed loop scrubberwater system by physical removal of solids from the scrubber water feed stream. A damp cake of compressed soHds is generated, dropped into a container, and transported to an offsitetreatment or disposal facility. The liquid filtrate is recycled backto the closed loop scrubberwater system. The filter press is located in the Filter Press Building. Thefilter press has a 2.4 cubicyard per batch capacity. Secondarycontainmentfor the filter press is provided by the Filler Press Building liner and sump system which has a total capacity of 23,070 gallons.

· F.1 Reserved.

F.2 Process Capacity/Annual Limitation The Permittee shall not exceed a maximum process treatment capacity of 111 ,DOD gallons per day of scrubber water feed to the filter press. F.S Waste Identification OAC Rule 3745•57·90 The Permittee shall treat in the permitted hazardous waste filter press only scrubber water and scrubber water sludges from blow-down operations of the closed loop scrubberwater system carrying the hazardous waste codes specified in Section A of the Part B permit application underthe process codes o!T04andT03and lorwhich incineration Is permissible under the restrictions and prohibitions in Table C1-1 of Section C of the Part B permit application. F.4 Assessment/Certification of Miscellaneous Unit OAC Rules 3745-57-91 and 3745-50-42(0) The Permittee shall keep on file at the facility a written statement by a qualified registered professional engineer that attests that the filter press system**wa~** properly designed and installed. The written statement must also include the certification ij.S required by OAC Rule 3745-5Q-42(D).



### VES01663:Ross Incineration SeNioes, Inc. HazardousWaate lnolallaUon & Operatlon.Pormlt Renewal Page 64 of 101.


### F.5 Containment System OAC Rule 

### 37 45-57-91 (a)



### (b) (c) 

### Secondary containment must

### bedesigned, installed and operated

### to prevent any migration of waste or accumulated liquid out of the system to soil, groundwater or surface water. Secondarycontainmentmust

### becapableofdetectingandcollecting releases and accumulated liquids untilthe collected material is removed. The secondarycontainmentmus\meetthe requirements ofOAC Rule 

### 37 45- 55-93, F.6 

### General Olll!rat!ng 

### Requirements OAC Rule 

### 3745-57-91 (a) Hazardouswaste ortreatment reagents shall notbe placed in thefilter press system if they could cause the filter press, 

### its ancillary equipment, or the secondary containmentsystem to rupture, leak, corrode orotherwisefail, as required by OAC Rule 

### 3745-55-94. (b) 

### The Permittee must use appropriate controls and practices 

### to prevent spills or overflows from the filter press or containment system. (c) The filter press must be operated In accordance with the procedures and praclices in Section D of 

### the Part B permit application, manufacturer's instructions and accepted Industry practice. (d) The filter press must be maintained In accordance with manufacturer's recommendations and accepted industry practice. · (e) The Permittee must comply with the 

### requirements of**OA~** 

### Rule 

### 37 45-55c96 ifa leak or spm occurs in the filter press system. F.7 Inspections OAC Rule 

### 3745-57-92 (a) 

### The Permittee shall inspectthe hazardous waste filter press system daily in accordance with OAC Rule 

### 3745-55-95 and Pages 

### 21 and 

### 22 of 

### 45 of Appendix F-2 of Section Fofthe Part B permit application. 

### '

## '' OHIO EPADHWM 

## SEP 302003

VES01663· ........•" Ron Incineration SeMc:es, Inc. Hazan!ouaWaste lnstellaUon &Oper11!on Permit Renewal Page85 of 101 · 

### (b) The Permittee shall document compliance with Condition F.7 (a) in an Inspection log. 

### F.8 Resoonse to Leaks or Spills and Disposition 

## of Leakjna or 

## Unfit for Use Miscellaneous 

## Svslem OAC Rule 3745-57-92 A hazardouswastefilterpress system orsecondarycontainmentsystemfromwhich there has been a leak or spUI, or which is unfit for use, must be removed from service immediately and the Permittee must satisfy the foUowing requirements in accordance with OAC Rule 3745-55-96, (a) Cessation of Usa The Permittee must immediately stop the flow of 

### hazardous waste into the filter presssystem orsecondarycontainmentsystem and inspectthe

### system to determine the ceuse of

### the release. (b) Removal of

### Waste From the Miscellaneous Unitor Secondary Containment System (i) If

### the release was from the filter press system,,the Permittee must, within twenty-four hours after detection of

### the leak, remove as much waste as necessary to preventfurther release of hazardouswaste to the environment and to allow inspection and repair of

### the filter press system to be performed. {iij Ifthe material released was to a secondary containment system, all released materials must be removed within twenty-four hours ofthe release 

### to prevent harm to human health and the environment (c) Containment ofVisible Releases 

## to the Environment The Permittee shall immediately conduct avisual inspection ofthe release and, based uponthat inspection, preventfurther migration ofthe leakor spill to soU or surface water and remove, and properly dispose of, any visible. contamination of 

### the soU or surface water.

OHtOEPADHWM 

## SEI' 3 0Z003

VES01663RosaIncineration Services. Inc. Hazardous Wasta lnslaRa11on & Operation Parmft Renewal Page 68 of 101. 

### (d) Notitlcatlons Anyrelease

## to the environment. exceptas provided in OAC Rule

### 37 45-55-96 (0)(2), 

### mustbe reported 

### to the

### directorofOhio EPAwithin twenty-four hours of detection. · (e) The Permittee shall obtain a certification by an independent, qualified professional engineer, that any major repair has been satisfactorily performed, and the unit 

### Is capable 

### of handling hazardous waste without release for the intended life 

### of the 

### system. The certification must be submitted to the director of**Ohio·(:~>** 

### A within seven days after returning the filter press system to use. 

### F.9 Special Reaujrements (a) Ignitable or Reactive Waste The Permittee shall not place Ignitable or reactive 

### waste in the filter press. (b) Incompatible Waste 

## (0 The Permittee must not place incompatible waste in the same filter press system or place hazardous waste in afilter press systemthat previously held an incompatiblewaste or material unless it 

### is done in
· accordance with 

### OAC Rule 

### 3745-55-99. (iQ The Permittee shall document compliance with 

### Condition 

### F.9 (b

### )(I) 

### of this permit, as required by 

### OAC Rule 

### 37 45-55-99, and place this documentation in 

### the operating record. 

### F.1 !l 

### Closure and Post-Closure Care OAC Rule 

### 3745-57-91 and 

### 3745-57-93 At closure of the filter press system, the Permittee shall follow the procedures In SeCtion lofthe Part

### Bpermitapplication In accordance

### with OAC Rules 

### 3745-55-10 through 

### 3745-55-40.

'

### '

## ' OH!OEPADHWM 

# SEi' 302003

VES016631Ross lnclneratlon Services, Inc. Hazatdous Waste lnslallation & Operation PermH Renewal Page 67 of 101


### MODULE G ·POST..CLOSURE CARE

G.1 Module Highljghts This section is applicable to units with in-place closure approval by Ohio EPA. The following unit llsubject

### to post-closure care:
. Surface impoundment SWI 7

G.2 Unit Identification The Permittee shall provide post-closure care for the following hazardous waste management unit upon completion of the closure requirements as found in this Permitand OAC Chapter 55,subject

### to theterms and conditions 

### ofthis permit, and as described

# IIIII: • ,

OHIOEPAOHWM 

## MAR 02 

## 2005

·--------
VES01663iRoss Incineration Services, Inc. Hazardous Westo lnatollallori & Operation Pennll Renewal Page 68 of 101
G.3 Post-Closure Pr9Cedures and Use of Property OAC Rules 3745-55-17 and 3745-55-18 (a) The Permittee shall conduct post-closure care for each haZardous waste management unit listed in permit Condition G.2. above, to begin after completion 

### of closure ofthe unit and continue for 30 years after that date, except that 

### the 30-year post-closure care period may 

### be shortened upon application and demonstration approved by Ohio EPA that the factlity is secure, or may be extended by Ohio EPA 

### if the Director finds this is necessary to protect human health and the environment. 

### (b) The Permitteeshall maintain and monitorthegroundwatermonitoring system and complywith allother applicable requirements

### ofOAC Rules 3745-54-90 thru 99 and OAC Rule 3745-55-01 during the post-closure period. (c) The Permittee shall complywiththe requirementsforsurface impoundments as fpltows: (i) maintain the integrity and effectiveness of the final cover, including making repairs to the cap, 

## as necessary, to correct the effects of settting, subsidence, erosion, and other events; and (ii} prevent run-on and run-off from eroding or otherwise damaging the final cover. (d) The Permittee shall complywith all security requirements, asspecified inthe Part B permit application. (e) The Permittee shall not allow any use 

### of the units designated in permit Condition G.2. which will disturb the integrity ofthe final cover, liners, any components of the containment system, or the function of the facility's monitoring systems during the post-closure care period. 

### (f)

pos•t-closu're care**acti~lities** provisions of

### the Post-Closure Plan.



### OHIOEPADHWM 

## MAR 02 2005

VES016631Rosa Incineration Sen/lcea, Inc. HazardousWasts lnstallallon & Operation Permit Renewal Page 69of 101


### G.4 InSPections

_OAC Rule 3745-55-17

The Permittee shall inspectthe components, structures, 

### and equipment atthe site in accordance with the Inspection Schedule. G.5 Notices and Cer!jf!cation OAC Rule.3745-55-19 (a)

(b) 

### No later than 60 days after certification of 

### closure of. each permitted hazardouswaste disposal unit, th!il Permittee shall submit

### to the local zoning authority, or the authority 

### with jurisdiction over local land use, and 

## to the Director, a record of the type, location, and quantity of 

### hazardous wastes disposed 

### of within each cell or other disposal unit 

### of the facility. 

### For hazardouswastes disposed of

### before January 12, 1981, the Permittee shall identifythe type, location, and quantity ofthe hazardous wastes

### to the best of his knowledge and In accordance 

### with any records he has kept Within 60 days of certification of closure 

### ofthe first and the 

### last hazardous waste disposal unit, the Permittee shall: 

### (Q Record, In accordance 

### with Ohio 

### law, a**notatio~;~** 

### on the deed 

## to the facility property, or 

## on some other Instrument that is normally examined during the 

### title search, that 

### will in perpetuity notify any potential purchaser ofthe property that: (aa) the 

### land has been used to manage hazardous.

## wastes; (bb} its 

### use Is restricted under OAC Rule.3745-55-10 thru 20; and (cc) the survey platand record ofthe type, location, and quantity of 

### hazardous wastes disposed of 

### within 

### each cell or other hazardous waste disposal unit ofthe factlity have been flied with the Director and the Lorain County zoning authority. (ii) Submita certification 

## to the Director, signed bythe Permittee, that he has recorded the notation specified in permit Condition G.3(b)(l), Including a copy 

### of the document in which the notation has been placed.
'· '• 

### '

. OHIO 

### EPADHWM 

## SEJ' 302003

________ .....

# ________ _
VES016639Rooslnclnatatlon Services, Inc. HazardousWaste Installation & Opatatlon Permit Renewal Page 70 of 101 

### (c) Ifthe Permittee or any subsequent owner oroperator ofthe land uponwhich the hazardous waste disposal unit 

### Is located wishes to remove hazardous wastes and hazardous 

### waste residues, the liner, 

### if any, or contaminated sons, then he shall request a modification to this permit in accordance with the appUcable requirements in OAC Chapter3745-50. The Permittee orany subsequentowneroroperatorof

### the landshall demonstrate thatthe removal of

### hazardous wastes will satisfythe criteria of OAC Rule 3745-55-17(C). (d) 

### No laterthan 60 days after completion of

### the established post-closure care period for**~:~ach** 

### hazardouswaste disposal unit, the Permittee shall submitto 

### the Director, by registered mail, 

## S. certification thatthe post-closure care for
· the hazardous waste disposal unit 

## was performed In accordance with the

specifications in the approved Post-Closure Plan. The certification must be signed by the Permittee and an independent, registered professional engineer. Documentation supporting the independent, registered

.professional engineer's certification must be furnished to the Director upon requestuntilthe Directorreleasesthe Permitteefrom thefinancial assurance requirements for post-closure care under OAC Rule 3745-55-45. G.6 

### Financial Assurance OAC Rule**3745~5-45** 

### The Permittee shaH continuously maintain financial assurance during the postclosure period and complywith all applicable requirements of OAC Rules 3745-55- 40thru 51. G.7 Post-Closure 

## P&nntt MoSifiQatjons OAC Rule 3745-55-18 The Permittee must request a permit modification to authorize a change in the approved Post-Closure Plan. This request must be made in accordance with 

### the appticable requirements of OAC Chapter 3745-50 and must in9lude a copy ofthe proposed amended Post-Closure Plan for approval bythe Director. The Permittee shall request apermit modification whenever changes in operating plans orfacility design affect the approved Post-Closure Plan, there is a change in the 

### expected year offinal closure, or other events occur during the active life of

### the facility that affect the approved Post-Closure Plan: The Permittee must submit a written request for a permit modification at least 60 days prior to the proposed change In facility design or operation, or no laterthan 60 days afteran unexpected event has occurred 

### which has affected the Post-Closure Plan.

., 

### ' OHIO EPADHWM 

## S£1' 30 2003

VES01664RoulnclneraUon Servl..,., Inc. HazardousWaate lnslallallon & OpetaUon PennltRenewal Page71 ol101
MODULE I(A) ·INCINERA110N
I(A).1 MODULE HIGHLIGHTS 

### The Incineration unit Includes the following components and systems: (a) (b) (c)

(d) (e) 

### Two enclosed combustion devices: the rotary kiln and the main chamber; Material handHng and 

### feed systems for fiquid and solid wastes as identified ln Section 

### 0-5 of

### the permit**app&!:~~tlon,** 

### An esh handling systemfor removing the ash remaining afterthecombustion of wastes which includes ash cooling, de-watering, separation of metal pieces and conveying ash into appropriate containers; 

### An air pollution control system for removal of acidic gases and particulate matter; and Associated instrumentation and control systems. Wastes are introduced into either the rotary kiln or the main, chamber. Flue gas from the rotary kiln flows 

### into the main chamber which functions as a secondary combustion chamberfor the rotary kiln. Flue gases passfrom the main chambertothe airpollution control equipmentwhich consists ofaquench/cyclonechamber, aradial scrubber, agas/tiquid contector, two serially-oper;ited wet electrostatic precipitators (WESPs), an Induced draftfan and a stack. This series of 

### air pollution control equipment removes contaminants (primarily particulates and acid gases) contained in the flue gas priorto discharge through a stackto the atmosphere. Stackemissions are monitored byContinuous EmisSion Monitor$ (CE.Ms)forcarbon monoxide, oxygen and nitrogen oxides. Carbon monoxide is 

### the primary indicator ofcombustion efficiencyand destruction efficiency of hazardous constituents 

### In the wastes. Operation ofthe incineration system 

### is monitored 

### and controlled by a Honeywell TDC 3000 

### distributed control system (DCS). Critical process parameters are continuously monitored bythe 

### DCSand are accessible

## tothe control rooQ1 operator. The control system maintainskeyprocess parameterswithin permitted ranges. The 

### OHIO EPA 

## SEt' 31

VE.S01664Ro

..Incineration Senllc:es, Inc. Hazo.rdous Waste lnslallatlDII & Operation**Penn~** Renewal Page 72 of 101


### control system will automatically cut off waste feeds if

### certain process parameters, as defined by this pennit, fall outside of

### the allowable operating range. · · Procedures In the facility's waste analysis plan and other sections of the Part B pennit application limit hazardous wastes fed to 

### the incinerator to those that the facility Is 

### pennltted to Incinerate. Exceptforchanges required bythe recentlyinstalled airpollution control system,the incinerator operating limits in this permit are the same as those in the facility's previous U.S. EPA permil U.S. EPA based these limits on the facility's 1992 trial bum. The facility conducted aperformal)cetest in October of

### 2000 to demonstrate that current system performance is consistent with performance during the -1992 trial bum. The Permittee submitted the results ofthe 

### performance test in the Part B permit application 

### as data in lieu of

### a trial bum. I(A).2 Identification Criteria for Permitted and Prohibited Waste OAC Rule 3745-57-44 Except during the periods specified in the conditions for Short-Term Incineration underaShakedown Period,Trial Bum or Post-Trial Bum conducted in accordance with a plan approved by Ohio EPA, the Permittee may incinerate 

### the following hazardous wastes, as specified in this permit and only under the terms oHhis permit. The Permittee may onlyfeed 

### the hazardous wastes as Identified below at the facility subject to pennit Conditions I(A).3. through I(A}.5., and I(A).S. (a) The Permittee shall only incinerate hazardouswastes meeting 

### the following criteria: 

### Q) The Permittee shall not feed any hazardous waste containing any organic hazardous constituent listed in the Appendix to OAC Rule 3745-51-11 ofthe Administrative Code unless the constituent has a thermal stability Class ranking equal to or less than Class 1. (ii) The Permittee shall not feed any hazardous waste whose current Ohio EPA hazardous waste code number does not appear in Part A

. of

### the permit application underthe process code**~f**

### T03. 

### (iii) The Permittee shall not feed any hazardous waste for which incineration would 

### be

. inconsistent 

### with 

### the restrictions and prohibitions in Table C1-1 of Section C. of 

### the Part, B permit application. · '.. 

### OHIOEPADHWM 

## S£t' 3

## 0 2003



# ----- ·----··--·--- - ..


### VES01664'<--.. Ross lnclnora!Jon Services, Inc. Hazardous Waste Installation & Opemtion**Perm~** Renewal Page 73 of 101 (iv)

(vi)

(vii)
(viii)

(ix) The Permittee shall not feed any hazardous waste in excess ofthe maximum concentration and annual volume limitations in Table XIV

· of Part A of the Part 

### B permit application

..

The ash content of waste fed to the incinerator shall not exceed the limits in Attachment A ofModule I( A)tothis permit and Table 05-6 of Seption 0 ofthe Part B permit application. Systemtotal halogen dailyaverage in wastefeed shall notexceed the limit in Attachment 

### A of Module I(A) to this permit. The heating value of waste fed to the incinerator shall be within the range of heating value limitations in Table 05-6 of Section 0 of the Part B permit application. Theviscosity ofwaste fed to the incinerator burners shall notexceed the limits inTable 05-6 of Section 0 ofthe Part B permit application. (b) Throughout operation, the Permittee shall conduct sufficient analysis in accordance with the Waste Analysis Plan to verify that waste fed to the incinerator iswithin the physical and chemical composition limits specified in this permit · The Permitteeshall conductwaste analysis ofthe incinerator waste feeds at least once a calendar month in accordance with Section'C-1e of Section

# c of the Part B application, to verify that the waste feed to the incinerator is within the physical and chemical limits specified in Table 05-6 ofSection D ofthe Part B permit application. Records ofthis activity shall 

### be kept atthe facility according to OAC Rule 3745-54-73 (9)(3). (c) Auxiliary fuel or bypass waste fuel meeting the conditions and criteria identified in Section 0-5c (1 )(f)(ii) of the Part B permit application may be used in the incinerator during start-up, shutdown and upset conditions.



### VES01664:**,.~.··\J** 

### .::'

### r~t**~** ' "'\.. t Roaa lndneration Setvk:es, Inc. Hazardous Wastelnstllllatlon &Operation PennR Renewol Page 74 of 101 

### (d)

(e)
(f) (g) 

### The point of injection or feed for all hazardous waste streams fed into the incinerator shaH be consistent 

### with Table 

### C1-1 

### of Sedion C ofthe Part B permit application. All waste streams fed intothe incinerator shall be within the characteristics set forth in Table 05-6 ofSection 0 of the 

### Part B permit application. Only waste feed systems specified In Section 0-5 of the Part B permit application shall be used to feed wastes 

### to the Incinerator. 

### The Permittee shall notfeed wasti!S through the kiln aerosol can feederand the second main chamber aerosol ,can feeder until and unless they are modified to the same design and operating standards as the first main

. chamber. aerosol can feeder and Ohio EPA has approved these

modifications In accordance with permit Condition l(A).9(e). I(A).3 Construction. Instrumentation. and Qperatjonal Pertormance Beaulrements

. OAC Rule 3745-57-45**···~.**

.. ; 

### Wastes described In permit Condition I(A).2. may

### be fed to the incinerator only in ,>/ 

### compliance with permit Conditions I(A}.3(a) through (w). (a) The Permittee shalloperate-and maintain all components ofthe incineration system in accordance with·the design plans, specifications and practices contained in Section 0-5 of the Part B permit application. (b) The Permittee shaD install, test, operate and maintain au Instrumentation, Including all associated instrument loops, monitors, analyzers and the 

### distributed control system, inaccordance

### withthe design plans, performance specifications and maintenance practices contained in Section D-5 ofthe Part B permit application. · (c) The Permittee shall maintain the Incinerator so 

### that when operated in accordance with the operating requirements specified in this permit, itwill meet the performance standards specified in permit Conditions I(A).3(d) through I(A).3(f). (d) The incineratorshall achieve a destruction and removal efficiency (ORE) of 99.99 percent for each of the following principal organic hazardous constituents (POHC) foreachwaste feed. Thedesignated POHcspursuant to OAC Rule 3745-57-42(8) are carbon tetrachlod,de and

. 

### ' 

### OHIOEPADHWM 

# SEr 30.tfl03

,· ..

### ·--------------··--...


### VES01664·Ross Incineration Se!'lices, Inc. Hazardous Waste Installation & Operation**Penn~** Renewal Page 75 of 101



### (e)

(f)

(g)

(h)


### (i)



### (j)

(k)
(I) 

### (m} monochlorobenzene. The ORE value shall be determined usingthe method specified in OAC Rule 3745-57-43(A)(1}. The Permittee shall control hydrogen chloride (HCI) emissions, suchthatthe rate ofemissions is no greaterthanthe largerofeither 1.8 kilograms per hour (4 pounds/hour) or one percent ofthe HCI in the stack gas prior to entering any pollution control equipment. The incinerator shall not emit particulate matter in excess of 180 milligrams per dry standard cubic meter (0.08 grains per dry standard cubicfoot) when corrected for the amount of oxygen in the stack gas, in accordance with the formula specified in OAC Rule 3745-57-43(C). · Carbon monoxide concentration in the stack exhaust gas, monitored as specified in permit Condition I(A).5, and corrected forthe amount ofoxygen in the stack gas, shall notexceed the limit in Attachment A of Module I(A) to this permit. The Permittee shall be limited to the waste feed rates in Attachment A of Module I(A) to this permit. Combustion temperature for the kiln and main chamber, monitored as specified in permit Condition I(A).5, shall be maintained within the limits in Attachment A of Module I(A) to this permit. Combustion gas volumetricflow, monitored as specified in permit Condition I(A).5, shall be maintained within the limits In AttachmentAof Module I(A} to this permit. The mass feed rates oftoxic metals to the incinerator shall not exceed the limits in Attachment A of Module I(A) to this permit. Atomization air pressure shall be no less than the limits in Attachment A of Module I(A) to this permit. The air pollution control equipment, including the quench/cyclone chamber, a radial scrubber, a gas/liquid contactor, two 

### serially-operated wet · electrostatic precipitators (WESPs} and the induced draft fan shall be operated within the limits in Attachment A of Module I(A} to this permit.

VES01664!

# '·· ·:""'- 

# - Ross Incineration SerVIces, Inc. Hazardous**Was~** lna1allatlon &OperaUon PermitRenewal Page 76 of101 

### (n)



### (o)

(p) (q)



### (r) The Permittee shall controlfugitiVe emissions from the combustion zone of the Incinerator 

### by maintaining the pressure in the kiln and main chamber,· monitored as specified in permit Condition I(A).5, so that the limits in AttachmentA of Module I(A) ofthis permit are not exceeded. No hazardous waste streams, other than bypass \\taste fuel meeting the conditions and criteria identified In Section D-5c 

### (1)(f)(il) ofthe Part 

### B permit application, shall be fed into the incinerator until the minimum temperature conditions in AttachmentA ofModule I(A) 

### to this permit have been attained. In the event of a shutdown of

### the Incinerator, the procedures identified in Section D-5c 

### (1)(f)(v) 

### ofthe Part 

### B permit application shall be followed. The Permittee shall, for each set of 

### 10 activations of 

### the automatic waste feed cut-off system due to the exceedance of either minimum operating temperature or maximum carbon monoxide emissions limits in Attachment Aof Module I(A)while hazardouswaste remains inthe combustion chamber (i.e., hazardous. waste residence time has not transpired prior 

### to the hazardouswaste feed cutoff) during a rolling 

### 60-day block period, submit to the Director of

### Ohio EPA a written report within 

### 5 calendar days ofthe 1Oth exceedance documenting the exceedances and results of the investigation

.and corrective measures taken. Feed Restrictions for the Side Door and Direct Feed Locations (0 

### The Permittee shall follow 

### the procedures and practices identified In Sections 

### C, Dand F ofthe Part 

### Bpermit application for determining the compatibility of

### waste materials being fed to the side door and tanker and container direct

### feed mechanisms of

### the 

### Main Chamber. (iQ The Permittee shall follow the procedures and practices Identified in section 0-Sc 

### (1)(c)(iv) ofthe permit 

### application When feeding waste into the Main Chamber through the side doorfeed mechanism. (iiQ The Permittee shall followthe procedures and practices identified in Section Dofthe Part 

### Bpermit application for operation of

### the tanker and drum direct feed systems, the side door feed system and the direct feed areas. 

## '·. '·

### OHIOEPADHWIII**SE~** 

## 30Z003 . i



### VES016646Ross Incineration Selvlcea, Inc. HazardousWaste lnetallatlan &Operation Permh Renewal Page71 of 101 

### (iv) The Pennittee shall comply with the following general operating requirements .foroperation of

### the direct feed systems and the direct feed areas: The direct transfer of hazardous waste to the incinerator shall be conducted so that itdoes not: (1) Generate extreme heat or pressure, fire, explosion or violent reaction; (2) Produce uncontroH!!d toxic mists, fumes, dusts or gases in sufficient quantities 

## to pose a risk of

### fire or explosion; 

### (3) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions; (4) 

### Damage the structural integrity of the container or direct transfer equipment containing 

### the waste; (5) Adversely affect the capability of the incinerator to meet the standards provided in OAC Rules 3745-57-43 (B) 

### and (C); or

·(6) Threaten human health orthe environmqnl The· Permittee shall operate 

### the direct feed transfer of hazardous waste to the Main chamber and 

### the transfer of 

### low 

### BTU waste from Tank Farm 

### Ill to the Main Chamber in accordance with the automatic safety cutoff limits specified in Section D ofthe Part 

### B permit application and Attachment 

### B of Module I(A) to 

### this permit. The Pennittee shall conduct direct feed transfer only in areas with spill containment as indicated In**Secti~ms** 

### D and F ofthe Part B 

### permit application. The Pennittee shall conductinspections ofthe directfeed area in accordance with Sections D and 

### F of the Part 

### B permit application, maintain records of these Inspections In the operating record of the facility and make them available for review for at leastthree years from the date of

### the inspection. 

### '

## ' OHIOEPAOHWM 

# St.I' 

# 302003

VES01664iRoss. Incineration Services., Inc. Hazardous Waste Installation & Operation PennK Renewal Page 78 of 101

(s)

(t)

(u)

(v} (v) Reserved. (vi) The Permittee shall notfeed empty containers through the side door feedmechanism unlessthe provisionsapplicable to emptycontainers in the Side Door Implementation Plan dated November 23, 1998, which plan 

### is included in U.S. EPA's Administrative Orders dated December 12, 1998, are mel The incinerator shall cease operation when changes in the waste feed, incinerator design or operating conditions exceed. limits designated in this Permit, pursuant to OAC Rule 3745-57-45(F). The Permittee shall complywith allthe applicable requirementsfor restricted wastes and treatment residues (ash, scrubber water, etc.) specified in the rules found in OAC Chapter 3745-270. Pursuant to OAC Rule 3745-57-43(0), for the purposes of enforcement, compliance with the operating conditions specified in permit Conditions

. I(A).3(g} through I(A}.3(v} will be regarded as compliance with the performance standards specified in permit Conditions I(A}.3(d) through I(A}.3(f). However, evidencethatcompliancewiththeseoperating conditions

.is insufficient to ensure compliance with the aforementioned performance standards may be. •information" justifying modification, revocation, or reissuance 

### ofthe permit pursuantto OAC Rule 3745-50;-51. Wastes may be fed during the periods for Short- Term Incineration underthe Shakedown Period, Trial Bum Period, and Post-Trial Burn Period without meeting permit Conditions I(A).3(g) through (v) only ifsuch operations are conducted in accordance with a plan approved by Ohio EPA I(A).4 Inspection Reauirements OAC Rule 3745-57-47 The Permittee shall inspect the incineration unit in accordance with the Inspection Schedule in Section F 

### of the Part B permit application and shall complete the following as part ofthese inspections:

VES01664SRoss Incineration Services, Inc. Hazardous Waste Installation & Operation Permit Renewal "- Page 79of101 (a)



### (b)
(c) The Permittee shall thoroughlyvisually inspect he incinerator and associated equipment (including pumps, valves, conveyor, , pipes, etc.) for leaks, spills, fugitive emissions, and signs oftampering, as. pecified in Pages 14 and 15 of 45 in Appendix F-2 of Section F of the Part• pemnit application. The Permittee shall continuously monitor the istributed control system 

### for proper operation while the incinerator is in op ration. The Permittee shall test the emergency wa te feed cut-off system and associated alarms at leastweekly toverifyope· bility, and documentthe test as specified on Page 

### 45 of

### 49 in Appendix 

### F 2 of Section F of the Part 

### B permit application. The monitoring systems · 

### I be tested by simulating an upset condition of one monitoring parameter on a rotating, weekly basis which will engage the waste feed cutoff syste

. Waste feed cut-offsystem testing is perfonned weekly to verify operabilitY The emergencywastefeed cut-offtestwill be conducted once during each ' lendarweek, exceptforany calendar week inwhichthe waste is notfed**to~** e incineratorfor 48 hoursor more. (d) The Permittee shall conduct all other In · ections applicable to the incineration unit as specified in Appendix 

### F- · of Section 

### F of the Part 

### B permit application. I(A).5 Monitoring Requirements OAC Rule 3745-57-47 (a) While incinerating hazardous waste, the Penm (i)

(ii) Maintain and operate the monitoring sys. mslisted under "Monitoring System" for each operating parameter ;isted under "Parameter and Monitoring Location" as listed in Attach' ent 

### C of Module I(A) to this permit; and Monitor and record data for each oper ting parameter listed under "Parameter and Monitoring Location" at · e frequency specified under "Monitoring Frequency" as listed in A ' chment C of Module I(A) to this permit; (iii) Maintain and operate the backup man oring systems listed under "Backup Monitoring System" in Attach •ent C of Module I(A) to this permit, and when backup monitoring sys ems are utilized, record data from the backup monitoring system att e frequency specified under "Backup Monitoring Frequency" in Attac ment C of Module I(A) to this permit.



### VES01664!Ross Incineration SeNic:es, Inc. Hazordou.Waste lnetellaUon & Operation Pennl Renewal Page 80 of 101 ·. 

### (b) The Pennittee shall calibrate the monitoring equipment for each operating parameterlisted under'Parameterand Monitoring Location"atthe frequency specified under ·caubration Frequency" 

## as listed inAttachment Cof

### Module I(A) to this permit.

(c) 

### The Pennittee shall maintain and calibrate daily the 

### continuous CO monitoring**equ~ment** 

### as specified In Section D of 

### the Part B permit application. In addition the CO monitoring equipmentshall be examined by the equipment supplier's representative at least one time per year and certified by the supplier or an independent, properly trained and certified Individual that the equipment has been calibrated In accordance with the manufacturer's recommended procedures and guaranteed accuracy

## to +/- 

### 10 ppm or +/-2.5% offull scale readings, Whichever is greater. The Pennlttee shall documentthe results of

### all calibrations required by this permit condition. The Pennlttee shall log the 

### following data While Incinerating hazardous 

## waste: (Q Quantities of chemicals used In conjunction 

### with air pollution control equipment in tons/month of

### caustic used or equivalent. (ii) Quantities of ash and air pollution control sludges generated in tons/month. (iii). 

### Results ofviscosity

### tests on liquidwastes and bypassfuels

## to be used in the burner. (d) Upon request of Ohio EPA, the Permittee shall perform sampling and analysis of 

### the 

## waste ant;! exhaust emissions to verify that the operating requirements established In the permit achieve the performance standards. I(A).6 Waste feed Cut-Off Requirements OAC Rule 3749-57-45

· (a) The Permittee shall not feed hazardous wastes 

## to the Incinerator unless all monitoring systems listed under 'Monitoring System" in Attachment C of Module I(A) to this permit and that have a monitoring frequency of "Continuous• or 'Continuously" specified under "Monitoring Frequel')cy" in AttachmentC of Module I(A) to this permit, are on-line, properly\Operatfng and continuously monitoring the specified parameters. ·'

### OHIOEPk~WM 

# ,, SEP 30ZODJ ' ;



### VES016650

# -- Rosa Incineration Services, Inc. Hazardous Waala lnataUatlon &Operation Pennlt Renewal Page 81 of101 

### (b) In case of a malfunction of 

### the automatic waste 

### feed cut-off systems, the Permittee shall perform manualshutdowns in accordancewith

### the approved procedures In the Part 

### Bpermit application. The Permittee shall not 

### rvstart the Incinerator until the problem causing the malfunction has been located and corrected. (c) Thewaste feedstothe incineratorshall beautomaticallycutoffwheneverany operating limit Identified as a waste feed cutoff limit In Attachment B of Module !(A) to this permit is exceeded or if

### both CO continuous emissions monitoring systems are off-line**~or** 

### any reason. An alarm shall be actuated whenever any operating limit Identified as an "Alarm Only" limit In Attachment B of Module I(A) tothis permit is exceeded. The Pennittee shalltestthe automaticwaste feed cut-offsystemweekly and documentthetest using pages 42 and 42.1 of45 inAppendix F-2 ofSection F ofthe Part B permit application. · (d) Unless the Pennittee can show otherwise per OAC Rule 3745-51-03(0), residue from the incineratoris 

### hazardouswaste,the Permittee Is agenerator and must manage this hazardous waste according to the Ohio hazardous waste regulations. The Permittee shall manage residue from the incinerator in accordance with the applicable practices and procedures in Sections C and 0 of 

### the Part B permit application. !(A).7 Closure OAC Rule 3745-57-51 The Pennlttee shall follow the procedures in the Closure Plan in 

### Section I of the Part B permit application•. I{A).B Recordi<eeoing (a) The Pennittee shall record and maintain, in 

### the operating record for this facDity, all monitoring and inspection data compiled underthe requirements ofthis permit (b) The Permittee shall record in the operating record for this facility the date and time of all automatic waste feed shut-offs, including the triggering parameters, reason for the shut-off, and corrective actions ta!<en. The Permittee shall also record all failures ofthe automatic waste feed shut-off systems and corrective actions taken. .OHIO EPADHWM

. 

## SE.I' 30ZOD3 ·

VES016651Roaa Incineration Serllcos, Inc. Hazardous Waate lnatallallon & Operation PormftRenewal Page 82 ol101 

### (c)

(d) 

### The Incinerator and associated equipment (pumps, valves, conveyors, piping, etc.) must be subjected to thorough visual inspection, at least daily, for leaks, spills, fugitive emissions and signs of 

### tampering. These

.Inspections shall be recorded in the daily inspection log and become part of 

### the facility's operating log 

### (pursuantto OAC Rules 3745-57-47 (B) and (D)). The Permittee shall document all emergency process termination (EP'T) incidents atthe

### facUlty and promptly reportthe occurrence of

### the EPT, cause ofthe EPT and associated emissions to Ohio EPA. I(A).9 

### Compliance Scbedule (a) No laterthan one year after the effectiVe date ofthis permit, the Permittee shall submit a plan to reduce the frequency of 

### emergency process termination incidents (EPTs) atthe facility to the Ohio.EPA. The plan shan· include alisting ofall EPT incidents in thefiveyearperiod preceding the date of the effective date of this permit To the extent determinable by the Permittee, the listing shall include the Immediate and root causes of each EPT. The plan shall consider all reasonable options for reducing the frequency of EPT incidents, including improving the reliability of 

### electrical supply to and within the facility. The pian shall 

### be approved by 

### a certified professional engineer qualified ln electrical distribution systems and process plant control systems. Ohio EPAwill 

### reviewthe EPTfrequency reduction plan as submitted by 

### the Penriittee, and If 

### necessary, notify Permittee of

### deficiencies. Ifnecessary, Ohio EPA 

### will request that the Permittee submit a permit modification requestto implement feasible options that consider costs 

### and reductions in emissions 

### from EPT events or Ohio EPA will Initiate such a permit modification request (b) The Permittee shall evaluate the abRity of the containment system for incinerator tanker direct feed locations Number 1 and 

### 2 to safely contain releases of highlyvolatile and flammable liquid wastes (e. g. Class 1A, 18 and 1C liquids). Forthose wastes possessing flammabDity properties thatare**not~onsistent** 

### with using the trench as part ofthe containment system, 

### the Pemiittee shall Include the following options In 

### its evaluation: 

### OHIOEPADHWM 

## SEr 302003**~------** ··-------· 

### -· -


### VES016652Ross Incineration Services, Inc. Hazardous Waste Installation & Operation Permit Renewal Page83 ol101 

### (i) Do nottanker direct feed, or (ii) Feed at tanker direct feed location number 3, or (iii) Modifythe containment system to address the concerns with the risk of ignition of flammable liquids contained in the trench. The Permittee will submit to Ohio EPA for review within 6 

### months after the effective date of this permit a plan detailing the .methods to'be used for conducting the evaluation and for assessing the hazards of a release of highlyvolatile and flammable liquidwastes from incineratortankerdirectfeed

· locations Number 

### 1 and 

### 2. Ohio EPA will either approve the plan, issue a

notice ofdeficiencies or a revised plan. Upon receipt of an approved plan, the Permittee shall conduct the evaluation and submit the results of the evaluation to Ohio EPA for review within six months. Ohio EPA will either approvethe evaluation, issue anoticeofdeficienciesora revised evaluation. Ifany,changes 

### to tanker directfeed eontainment oroperations are required as a result of

### the evaluation, Ohio EPAwill requestthatthe Permittee submit a permit modification request 

### to implement such changes or Ohio EPA will initiate a permit modification requesl If the Permittee believes that any of the preceding schedules provide insufficienttime 

### to complete the requested work, the Permittee may submit a permit modification request documenting the basis for'such belief and requesting an amended schedule. (c) The Permittee shall extend the concrete paving atTaitker Direct Feed Site Number 

### 3 so that no portion of any directfeed tanker projects over an unpaved area and 

### to provide adequate lateral extensions from the tanker centerline (five feet minimum each side of centerline) for adequate cont,a,inmento!releases.

### Until~~ended concfi!t$

### pavJn~ i!licqmpleted,**th~. :~uni~**  

### shall place**tal'!~tli** 

### completely over**_cq:O~;:re~,** 

### including

### prpvi~i11~**~d~ate** lateral

### eX!~r;l~tons from the

### ~nl<e~**~literline** (five feet 

### qunil)ll,\l)i each side of centerl1ne):When per:fqrmmgtanker directfeeding at

. Site Number 3. The Permittee shall constructthe pavingtothe same standards asthe paving proposed forformer OCSA 1 and described in the Permittee's letterto Ohio ·EPA dated June 

### 13, 1995. Within 

### 90 days of completion of the paving, the

Permittee shall submit appropriate documentation, including "as-built" drawings and a Professional Engineer's certification, in a permit modification requesl · Alternatively 

### if Permittee does not intend to constructthe paving to the same standards as the proposed paving for former OCSA 

### 1 described in the

VES016653

## ff1 'SIS/OS
ROS$ Incineration SeNices, Inc. Hazardous Waatelnstallatlon & Oparatlon Penni! Renewal Page 84 of 101
Permittee's letterto Ohio EPA dated June 13, 1995, Permittee shall submit a permit modification request priorto installation which includes appropriate drawings and construction standards. The Permittee shall submit the required permitmodification request no laterthan**~onths** afterthedate ofthis permit. The Permittee shall complete construction no later than six months after Ohio EPA approval ofthe construction drawings.· If the Permittee believes th.at any of the preceding schedules provide insufficienttime to complete the requested work, the Permittee may submit a permit modification request documenting the basis for such belief and requesting an amended schedule. (d) 

# w ,. (e) The Permittee shall not operate the second main .chamber aerosol can feeder until: 

### (i) It has been modified to the same design and operating standards as the first main chamber aerosol can feeder;



### VES016654Ross Incineration Services, Inc. Hazardous Waste Installation & Operatlpn Permit Renewal Page 85 of 101 (ii) The Permittee has submitted 

### to Ohio EPA a permitmodification request that includes documentation that the feeder has been so modified and a request to operate; and (iii) The permit modification request is approved by Ohio EPA. (f) The Permittee shall conduct an incineration performance test within six months of Ohio EPA's approval of the Permittee's MACT Comprehensive PerformanceTest Plan and each succeeding three years. Theperformance test plan shall be submitted to Ohio EPAat leastsix months priorto the test date and shall address all regulations and other conditions that may be needed to protect human health and the environment. ·The Permittee shall submitto Ohio EPA the report documenting performancetest activities and · results within 6 month of conducting eaCh performance test.



### VES016655Ross Incineration Services, Inc. Hazardous Waste Installation & Operation Permit Renewal 

## Attachment A..:Module I(A}

Incinerator Qperating Limits

1. Waste feed 1-hour rolling average, \b/hr. Excludes recycled waste feeds

..

1.1 2.

. 3.



### 4. 5. 6. 7.

. 8. 9. 10. 11.

12.

13

.. 14. 15. 16. 17. 18.

19.

20. f Total system hazardous waste feed rate. (lb/hr) Liquid waste to main chamber (ib/hr) Tota\ waste to main chamber (lb/hr) Liquid waste to kiln (lb/hr) Total waste to kiln (lb/hr) Waste Feed (tons/year). Excludes .recycled waste feeds. Bypass fuel rate to mainchamber, lb/hr Bypass fuel rate to kiln-liquid feed lb/hr · Bypass fuel rate to kijn-natural gas, f\ 3/min · h 0 Kiln combustion temperature waste feed cutoff ; F

.. h 0 Main chamber combustion temperature waste feed cutoff , F

. . 0

. Radial Flow Scrubber_inlet temperature, F Radial Flow Pressure Drop, hourly rolling average, inches WC Gas-Liquid Contactor Drain, pH hourly rolling average CO level, ppm dry corrected to7% 0 2 1-hour rolling average Total induction fan, ampsj

..System halogen daily average waste feed, lb/hr i

Liquid burner feed waste atomization pressure, psig

Main Chamber Kiln, psig FueJ·bumer atomization air pressures

Main Ctiamber, osi 

### i •Kiln, psig Liquid feed ash content, % Solid feed ash content, % 0 Combustion gas volumetric flow, acfm at 140 F saturated Main chamber vacuum, in. H20 for 15 seconds KUn vacuum, in HzO for 30 seconds 0 WESP electrical settings Total power, hourly rolling averageVA ·Scrubber water flow rates

. . . m Radial Flow Scrubber hourly rolling average (gpm)
· mn · ·Gas Liquid Contactor hourly rolling average (gpm) ' Metals feed limits, lb/hr (24-hr rolling average) For each specific metal, maximum feed rates to the kiln and main chamber shall not be employed simultaneously. 

### Maximum

26,057 12,852 18,515 5,685 19,848 105,120

10,190 4,000

667I 2,400 2,400

194 

### NA NAg. 100 .k 2,000

10Q 

### NA
NAg NAg 40 100 70,000

NAg NAg



### NA NA 

### Minimum

0 0 0 0 0 0 

### NAg NA NA 1,1oo1 1,700 

### -NA

10 6.Q 

### NAg

*k



### 5 80
16 90 

### NAg NAg NAg 0.05 0.05



### BOO

. 2200



### OHIO EPA DHWM 

## JUL 11 ZOOB

VES016656Rosa Incineration Services, Inc. Ha:t,!J'dous Waate lnalaUation & Openlllon PonnH Renewal 

## Attachment A-Module I(A) 

## Incinerator Operating Limits (Cont.)

·Carcinogenic metals 

### Maximum arsenic (As) Maximum beryllium (Be) Maximum cadmium (Cd) Maximum chromium (Cr) Kiln (K) 

### 9.56ib!lb 8.02lbJh

. Main Chamber (M.C.)



### 23.51bJh

. 195.2lbJh Additive EffectOfCarcinogenic Metals 

### b 

### 1.74lbJhd 3,59lbl_!lb 4.20 lbJh8



### .47.2lbJh

Ohio EPA has limited the combined risk effect ofthe carcinogenic metals to be less

. -5 than 1.0 x 10

. •
. .



### . Therefore, the carcinogenic metals will 

### also berestricted by 

### the following equation:

AKMIK + 

### AMcf'NMC + 

### BKIXK+ 

### BMcfXMC + 

### Cl(IYK+ 

### CMciYMC + 

### HI4ZK + 

### .HMclZMc 

### !: 1.0 

### ANI + 

### BIX + 

### C/Y + 

### HIZ:: 1.0 

### where: 

### AK 

## =actual**2~h** rolling average, lblh of arsenic to

### the klln 

### AMc 

### =actual 24-h rolling average, lblh of.arsenic to the main chamber 

### B K 

### =actual 24-h rolling average, lblh ofberyUium to the kiln



### .BMc 

## =actual 24-h rolling average, lblh of berytfium to the main chamber 

### CK 

### = actual24-h rolling average, lblh of cadmium to the kl1n 

### CMc 

# = actual24-h rolling average, lblh ofcadmium to the main chamber 

### HK 

### =actual 24-h rolling average, lblh oftotal chromium to the klln 

### HMc = actual24-h rolling average, lblh oftotal chromium to the main chamber 

### WK 

### = 18.91blh (maximum) of arsenicto the klln based on 1.0 

### x 10-5 Risk Facto! 

### 5 WMc 

### = 1.741blh (maximum) of arsenic to the main chamber based on a 1.0 x 10 Risk Factor ){K 

### = 18.66 lblh (maximum) of beryllium to the kiln based on 1.0x 10-5 Risk

## F~or lCMc 

### = B.35iblh (maximum) of beryllium to the main**chamberbasedo~.o** x 10 .Risk Factor 

### YK 

# = 23.521blh (maximum) of cadmium to the kiln based on 1.0x 10

... Risk**F~~r** 

### Y



### MC 

### =4.20 lblh (maximum) of cadmium to the main chamber based on**~** x 10 Risk Factor 

### Z.K = 1509.51blh (maximum) of chromium to the kiln based on 1.0x 10 Risk**Fa~r** 

### Z.Mc 

### = 1509.51blh (maximum) of chromium to the main chamber based on 1.0 x .10· Risk Factorc 

### Noncarcinogenic metals Kiln (K) 

### Main Chamber 

### K 

### + MCa


### Maximum Antimony (Sb)

Maximum Lead (Pb) Maximum Thallium 

### (T1) 

### Maximum Sarium 

### (Ba) Maximum Silver 

### (Ag) Maximum Mercury (Hg) ' (M.C.) 

### 83.9ibJh 123.1lbJh 142.51bJh 219.9ibJh

12.9lbJh 11.3lblh 

### b 37.5 lblhd < 

### 83.9 lbJh 77.2lbJh < 

### 123.1lblh 142.51bJh \< 

### 142.51blh 219.91bJh 

### '< 219.91blh

12.9 lblh < 

### 12.9 lbJh 11.31b/h < 

### 11.3lbJh 

### OHIOEPA0HWM 

## SFtl**~** 

## n ?nm

VES016657Ross lriclneration Services, Inc. Hazardous Waste Installation & Operation Permit Renewal 

## Attachment A-Module I(A) Incinerator 

## Operating Limits {Cont.)

EXPLANATION OF SUPERSCRIPTS: a) Values are based on the following equation: Kiln + Main Chamber= Maximum Kiln x Decimal Percentage Fed to Kiln t Maximum Main Chamber x {1 -Decimal Percentage Fed to Kiln)< Maximum Kiln b) Value Is based on adjusted Tier I and EPA Removal Efficiency c) Value is based on corrected emission rate for 43% lead recovery inspike sample d) Value Is based on test condition 2 overall system removal efficiency {OSRE) for lead and corrected emission rate from 43 lead recovery in spike sample e)

. Value Is based on test condition 1 OSRE for chromium f) Includes weight of containers g) NA=Not applicable h) ·Waste feed cutoff as follows: If the instantaneous temperature drops below 1700'F or goes above 2400'F, Alarms as

..

follows:·

. . · If temperature drops below 1845'F fpr 2 minutes or goes above 2255'F for 2 minutes. W

the kiln temperature goes above 2355'F for more than 50 seconds. I) Kiln burner waste feed atomization pressure and kiln burner atomization air pressure may be zero during**period~** when the kiln burner-is not being utilized-. Main chamberburner waste feed atomization pressure may be .zero during periods when the main chamber burner is not in use. j) Total induction fans amps applicable onlywhen combustion fan gas flow rate monitor is off line. k) · Fananip range will be. that established during interim operation period for air pollution control equipment. I) RIS complies with its current·kiln temperature limit by adding 200'F to the reading of the kiln dropout

· box the.,mocouple. Therefore, the allowable kiln WFCO temperature range of 1700 to 2400•F is translated to.1500 to 2200'F as indicated by the thermocouple atthe outlet ofthe dropout box. Tliis adjustment results from the approximately 200•F temperature drop across the kiln dropout box caused by heat losses and water evaporation/cooling from the wet ash removal system. m) Pump current will be used**a~** a back-up for flow meter failure. Pump current ranges to be detenmined after start-up. · n) Total contactorflow and WESP flush flow during WESP flush. o) RIS will operate the WESP controller in a manner that maximizes the particulate·removal perf9rmance of the unit. This shall include but not be limited to setting the controller to automatically maximize effective secondary voltage while considering the manufacturer's recommended maximum spark rate. RIS wil not arbitrarily or artificially lower WESP controller set points, except for the purposes of particulate removal performance testing or to optimize particulate removal perfonmance

. by minimizing sparking

.. RIS wm record the initial conilguration parameters of the WESP controller

and any deviations**therefrom~** including the reason for such deviation, in the operating record.



### OHIO EPA DHWM



## · .. JUL 11 

## ZOdB

VES016658' 1
- --, • --, f r • Ross lncfneration Services, Inc. · Hazardous Waste Installation & Operation Pennlt Renewal 

### Attachment B • Module I(A) Waste Feed Cutoff Actuating Events and Settings Operating Limits Exceeded Kiln Main Kiln & Main Chamber Chamber Gas Temp Main Chamber 

### X" Gas Temp Kiln 

# x• Gas Flowrate 

# x• Negative Draft 

### X" 

# x' CO Concentration X Loss ofAtomization X Loss of both WESP Operation X APCE Temperature Pressure Differential Scrubber Liquor pH Scrubber Water Flowrate Electrical Settings, WESP, Low Specific Power · August1Z,2004 Revision 1

Alarm

Alarm Only Alarm Only Alarm Only Alarm Only Alarm Only OJcygen Alarm Only a Instantaneous waste feed cutoff actuated if temperature goes above 24oo•F or drops below 17oo·F. b Waste feed cutoff following deviation ofoperating parameters for 5 minutes. c Waste feed cutofffollowing deviation of operating parameters for 30 seconds

.. d Waste feed cutofffollowing deviation ofoperating parameters for 15 seconds. Gas Temperature Main Chamber Waste feed cutoff shall be actuated when temperature deviates from the operating limits specified in I able D5-4 ·item 4. Alarm only will sound at 2255•F and 1845•F after 2 minutes. Gas Temperature Kiln Waste feed cutoff shall be actuated when temperature deviates from the operating limits specified in I able D5-4
- item 3. Alarm only will. sound at 2355•F after 50 seconds and 2255•F and 1845•F after 2 minutes.

. Slagging Operating Condition at 2355•F for 50 seconds is as follows:

• This specific operating condition Is applied only when an optimal slagging condition Is required; • An instantaneous and appropriate action is implemented by adjusting the kiln temperature 

### to its normal operating temperature range of 1845•F to 2255•F when the applicable alarm system Is activated. · Gas Flowrate Waste feed cutoff shall be actuated when the gas flow rate deviates from the applicable operating limits specified in Table 05-4
- Item 9 or 15 as applicable for more than 5 minutes. Neaative Draft Kiln • Waste feed cutoff shall be actuated 

### to kiln when the operating limits for the kiln specified in Table 05-4· item 17 are exceeded. Main Chamber- Waste feed cutoff shall be actuated to the main chamber when the operaiing limits for the main chamber specified in Table 05-4- item 16 are exceeded,



### VES016659**~** \,.,'
. 

## .. 'Roaa lnclne11itlon Services,-Inc.**H~oua** Waste Installation & Opera6on Permit Renewal 

## Attachment B-Module I(A) Waste Feed CutoffActuating Events and Settings (Cont) CO Concenlratjon
- Waste feed cutoff shall be actuated to kiln and main-chamberwhen the operation limits specified in Attachment A, Item 8 of

### this permit application are· exceeded. Loss 

## ofAtomjzatjon Air
- Waste feed cutoff shall be actuated to the kiln and main chamber when the main chamber atomizing air pressure drops below the operating limit specified in AttachmentA, Item 

### 12

.. Loss of both WESP Operation -Waste feed cutoff shall be 

### actuated to the kiln and main chamber when both WESPs are not in operation (exclusive ofWESP wash cycle). APCE Temperature -An 

### alarm will be actuated when the temperature of

### the gases at the radial flow scrubber inlet exceed limit speclfled·in Attachment A, 

### item 

### 5. APCE Pressure Djfferentjal
- An alarm will be actuated when the pressure differential across the radial flow scrubber drops below the limits specified in Attachment A, item

### 6. Scrubber Liquor 

### pH
- An 

### alarm will be actuated when the pH ofthe scrubber liquorfrom the gas liquid contactor rundown drops below the limits specified in Attachment A, item 

### 7. ScrubberWater Flow 

### rate- An alarm will be actuated when the water flow rate to the radial flow scrubber or gas liquid contactorfalls outside the operating range specified in AttachmentA, item 

### 19. · EJectrical Setting -An 

### alarm will be actuated when the electrical settings to the WESP units fall outside the operating range specified in Attachment A, item 

### 18. Oxvaen
- An 

### alarm will be activated when the oxygen concentration in the stackfalls below 9%, dry 

### basis. · Automatic Safety Control System; Liquid feed 

### rate- Liquid feed from the direct feed or Low Btu Tank Farm (Tank Farm 

### Ill) to

. the main chamberwill be automatically cutoff whenever the following conditions are sensed:

- Low Btu from Tank Farm Ill or direct feed flow rate of

### 5000 lbslhrfor 10 seconds;

- Low Btu from Tank Farm Ill or direct feed flow rate of 13000 lbslhrfollowing the first 

### 30 seconds ofwaste feed. 

### Ar alarm 

### will be actuated wheneverthe Low Btu from Tank Farm 

### Ill or direct feed flow rate is 5000 lbs/hr. Liquid flow rates to the incinerator are continuously monitored by 

### the Control 

## Room Operator. Should the automatic cutoffsystem not actuate when exceeding one of

### the liquid feed cutoff limits above, the Operatorwill take corrective measures to assurethat waste .......·•

### '••(:_,~:-~)

feed is cutoff at the location .ofthe upset condition. · OHIO 

### Ef'A

### Dl-!1.:;,: 

## S£t' 302003

VES016660Ross lncinera.. .:1rvices. Inc. Hazanlous Waste Installation & Operation Pennll Renewal 

### Attachment C-Module I{A) IncineratorOperating Parameter Monitoring Systems and Frequencies

Indicator

Discharge

amps Hourly transducer HoWiy

Backup

### Oiilo£11l!.~

VES016661Ros9 Incineration Services, Inc. Hazardous Waste lnstaUatlon & Operation Permit Renewal Page 86 of 101 

### MODULE J • 

### GROUND·WATER DETECTION MONITORING
J.1 MODULE HIGHLIGHTS This module addresses the ground water monitoring program associated with Surface Impoundment SWI 7 at Ross Incineration Services. This unit is being monitored duringthe post-closure periodthat began in 2004. Surface Impoundment SWI 7 was closed with waste-in-place and is subject to post-closure ground water**monitoring(~** 

### J.2 Well Location. Installation and Construction OAC Rule 3745-54-97 The Pemnlttee shall install, as needed, and maintain a ground water monitoring system as specified below: (a) The Pemnittee shall maintain the groundwater monitoring wells as shown on Figure 1 In Section Eofthe approved pemnit application, which is part ofthe Ground Water Detection Monitoring System required to comply with OAC rules 3745-54-97(A), (B) and (C), in accordance with the detailed plans and specifications presented in Section E ofthe approved permit application and

· in conformance with the following list:

.. 

## -- --. --··------'--------



### VES016662RosslnclneraUon ServiCBS, Inc. Hazardous Wasle lnSiellalion & OperaUon Pennft Renewal Page 87 of 101

Berea Sandstone MW-2 MW-5 MW-11A MW-24A MW-25A The groundwatermonitoring system must:yield samples in upgradientwells that represent the quality of the background ground water unaffected by leakage from any regulated unit(s}, and in downgradientwells yield samples that represent the quality of water passing the point of compliance. The number and location of monitoring wells must be sufficient to identify and define all logical release pathways to the uppermost aquifer from the regulated units basedon site-specific hydrogeologic characterization. (b) 

# The Permitteeshall removeorreplace anymonitoringwell identified in permit Condition J.2(a) in accordancewith the permitmodification process setforth in OAC Rule 3745-50-51. must map asspecified on Figure 1 for permit Condition J.2(a). (c) All wells removed or replaced in accordance with pei'IT!it Condition J.2(b) shall 

### be properly plugged and abandoned. Well plugging and abandonment methods, certification, and justification shall be submitted to the Director through the permit modification process in OAC Rule 3745-50-51. (d) Whenever any ofthewells specified in permit Condition J.2(a) are replaced, the Permittee must demonstrate to Ohio EPA thatthe ground water quality atthe replacementwell meets the criteria in permit Condition J.2(a) within a twoyear period ofthe date of replacement using means appropriate to the reason for replacement. (e) The Ground Water Detection Monitoring System that complies with OAC Rule 3745-54-97(A), (B), and (C) shall include atable ofunique identifiers for eachwell (both upgradientlbackground and downgradienUcompliancewells), zone monitored, and hydrogeologic gradient from the unit(s) as well as the surveyed ground surface elevation of all monitoring wells.



### OHIO EPA DtiWM 

## MAR 0 2 2006

VES016663Ross Incineration SeNlces, Inc. Hazardous Waste lnsfaRatlon & Operatlon PeiTilH Renewal Page BB of 101
J.3 Indicator Parameters and Monitoring Constituents OAC Rule 3745-54-98 (a) The Permittee shall monitor all the wells listed par'am•ete•rs and constituents Identified meetthe reotuir••meonts

Antimony An;enlc Barium Beryllium Cadmium Chromium

Cobalt Copper

Lead Mercury Nickel Selenium

Silver Thallium Tin Vanadium Zinc TOC 

### TOX (b) Establishing Bacfwround

is replaced, or for those parameters and in COridi·tion J.3(a) which include parameters and constituents required byOAC Rule 3745-54-98(A)forwhich no background values are established atthe time the permit is issued, the Permittee shallestablish backgroundvalues in accordancewiththefollowing procedures: (i) During each sampling event, the Permittee shall take a minimum of one sample from eachwell(background andcompliance pointwells), and analyzefor

### eacti parameterorconstituentspecified in the permit. Background ground water quality for a monitoring parameter or constituent may be based on a sequence 

### offour samples, taken ata quarterly interval that assures,. to the greatest extent technically feasible, that an independent sample is obtained 

### ofthe background well{s), or 

### OHIOEPA DHWM 

## MAR 02 2005

VES016664

# ,.. Ross Incineration Services, Inc. Hazardous Waste Installation Be Operation Permit Renewal Page 89 of 101 (ii) A background database shall be compiled for each constituent and/or parameter using an alternate sampling procedure specified in the permit modification request and approved by Ohio 

### EPA (c) Uodatjng Background



### OHIO EPAOHWM 

## MAR 02 2005 · following: (i) Background is not updated with less than 

### 4 newdata points at any onetime; 

## Oi) Thenew background (previous background data plus newbackground data) should be checked for slowly increasing trends. If a slowly increasing trend is identified then the background should not be updated unless concurrence from Ohio EPA is received that 

### it has been adequately demonstrated that the increasing trend is not the result of a release from the. regulated unit; · (iii) Background updates should be accumulative and not a moving window, unless a trend is identified in the background data. 

### As required in permitCondition J.3(c)(ii), the identifiedtrendswould have to be adequately demonstrated to not be the result ofa release from

. the regulated unit otherwise the background update would not be permitted; and (iv) When atrend in background data has been identified and it has been adequately demonstrated to not be the result of a release from the regulated unit, then a moving window background should be used. The size of the moving window will be dependent upon the rate of change and the best balance between background size and variance.



## -----·-------

VES016665Ross Incineration Services, Inc. Hazardous Waste lnsteUaflon & Operation PennH Renewal Page 90 of 101
J.4 Sampling and AnaNsjs Procedyres OAC Rule 

### 3745-54-97(0) and 

### (E)**.!!!!!!El!.!!1ll!!:!~**analysistechniques and procedures in

. are In accordance 

### with the rec,uirem,enlts 

### E). The Permittee shall use the techniques and procedureswhen obtaining and analyzing samplesfromthe groundwater monitoring wells identified in J.2(a):

(b) The well shall be checked for the presence of immiscible layers priorto purging in any monitoring well or wells where the presence of dissolved concentrations ofany GWMP parameter has been · that be present as outlined in (c) Samples shall be collected and handled (including well evacuation, sample

(d)

(e) withdrawal, preservation, cor1taineriza·tion fillr,.tir•n and equipment described in

be**calil~rat'ed** At a minimum, calibrations recommendations.

in

(g) Laboratory analytical methods, detection limits and**sarr~** hnlriin"

· in accordance with techniques· described In
(h) Quality assurance, including field/Jab/equipment blanks,

### dluup~~l~ica~t:~e:,::~~~~ and identification of potential shall be a accordance 

### with the methods described in 

# IIIIIMI. OHIO EPADHWM 

## MAR 02 

## 2005

VES016666Ross Incineration SeMces, Inc. Hazardous Waste Installation &Operation Permit Renewal Page 91 of 101 (I) Chain ofcustody procedures, including standardized field tracking reporting forms, and sample labels, shall be implemented in accordancewith Section E of the approved permit application. J.5 Elevation ofthe Ground-Water Surface (a)

.

{b)

(c) The Permittee shall determine the elevation ofthe ground water surface at each program well identified in Permit Condition J.2(a) each time the ground water is sampled in accordance with Section E of the approved permtt application. The Permittee shall utilize methods, procedures, and results specified in Section E

### ofthe approved permitapplicationforsurveyingtheground surface elevation 

### of all monitoring wells included in Permit Condition J.2(a). The Permittee shall record thetotaldepthofanywells installed inaccordance with permit Condition J.2 and the surveyed elevation ofthe top of casing, ·ground surface and/or apron elevation, and the protective casing of the monitoring well(s) within 90 days of the date of installation (with as-buitt drawings). · J.6 Statistical Procedures OAC Rules 3745-54-97 (G),{H) and (I) and 3745-54-98{F)**~'!hen** evaluatingthe monitoring results in accordancewith PermitCondition J.7, the Permittee shall use the statistical methods and procedures in Section E of the approved permit application which include the following elements of identifying statistically significant evidence of contamination in accordance with OAC Rule 3745-54-97(G}, (H) and (1): (a) The Permittee shall use an appropriate statistical procedurefor determining whether a statistically significant change has occurred. Any statistical method that is chosen must comply with the following performance standards as appropriate:



### VES016667Ross Incineration Services, Inc. Hazardous Waste lnstellaUcn & Oporatlcn Pennll Renewal**Pa~** 92of101 · 

### (Q The statistical method shall utilize a sample size appropriate forthe form of statistical test employed and large enough to ensure with reasonable confidencethatacontaminant release tothegroundwater from the facility will be detected. (li) The statistical procedure must be protective of

### human health and the environmentand provide reasonable confidence thatthe migration of hazardous constituents from a regulated unit into and through the aquiferwill be indicated. (iiQ The statistical method must be used In evaluating ground water monitoring data for each hazardous**const~uent** 

### specified In permit Condition J.3(a). 

### (tv)

. The statistical method must be appropriate forthe distribution of

### the
· data used to establish background or concentration limits. If the

distribution for the constituents differ, more than one statistical
· method may be needed. (v) The statistical method must provide a reasonable balance between the probabirttyoffalsely Identifying anon-contaminating regulated unit and the probability offailing to Identifya contaminating regulated unit (vi) The statistical method shall account for data below the limit of detection 

### with one or more statistical procedures that are protective of human health and the environment Anypractical quantltation limit (PQL) 

### approved in the permit that Is used In the statistical method shall 

### bethe lowest concentration level that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions that are available to the facility. Compliance may be facilitated by refemng to the _methods outlined in the most recent version of SW-846. (vii) Ifnecessary, the statistical method**~hall** 

### include proceduresto control or correct for seasonal and spatial variability as well as temporal correlation in the data. · (viiQ Ifa tolerance or prediction Interval procedure Is utilized, the levels of confidence and, for tolerance intervals, the percentage of the population that the interval must contain, shall be approved in the permit in Condition J.6(b). These parameters must be determined 

### OHIO EPADHWM ·-. ·•. 

## SEJ' 3 02003

----------·-··---···---·-···-··
VES016668Ross Incineration Services, Inc. Hazardous Waste Installation & Operation**Penn~** Renewal Page 93 of 101
afterconsideringthenumberofsamples inthe background data base, the data distribution, and the range of concentration values for each constituent of concern. (b) The Permittee shall choose and submit to Ohio EPA the appropriate statistical method within 90 days ofthe last background sampling event

. J.7 Monitoring Program and Data Evaluation 

### (a)

(i) In addition tothe parameters in Permit Condition J.3(a), the Permittee shall collect samples for chloride from all wells listed in Permit Condition J.2{a) during each sampling event {ii) TOX specific: The Permittee shall use an approved statistical procedure for determining whether a statistically significant TOX increase has occurred. Ifa statistical increase in TOX is confirmed, then the Permittee shall have the laboratory analyze the chloride sample taken from the affected well or wells, otherwise chloride samples will not be analyzed. The Permittee shall use the chloride concentration data to evaluate the potential for chloride interference in the analytical methodology. {iii) TOX specific: Ifelevated chloride concentrations are found to act as a laboratory interfering agent, then no further response will be necessary bythe Permittee. However, 

### ifchloride ·is determined notto be an interfering agent, the Permitteeshall immediately resample the affected well{s) for TOX and chloride, and reanalyze per Permit Condition J.7{a){iQ

.



### . {iv) TOX specific: If following the re-sample, elevated chloride

·concentrations are found to aetas a laboratory interfering agent, then

nofurther response will be necessary by the Permittee. However, if chloride is determined not to be an interfering agent, the Permittee



### OHIOEPADHVt'M 

## MAR 02 ZOfi5

. 

### --··-·---· 

## --- ---
VES016669

# . Ross, Incineration Services, Inc. Hazardous Waste Installation & Operation Permit Renewal Page 94 of 101
shall sample and analyze the affected well(s) for VOCs (SW-846 Method 82608), SVOCs (SW-846 Method 8270), and chloride to evaluate any potential impact to ground water from the land-based units. (v) TOG-Specific: The Permittee shall use an approved statistical procedure for detennining whether a statistically significant TOC increase has occurred. Ifa statistical increase in TOC is confirmed through a resample, then the Pennittee shall immediatelysampleand analyze the affected well(s) for VOCs (SW-846 Method 82608) and SVOCs (SW-846 Method 8270) 

### to evaluate any potential impact to ground water from the land-based units. (vi) If the results of the initial sampling for metals, VOCs or SVOCs indicate contamination, then the Pennittee shall follow the response requirements in Penni! Condition J.10. Ifthe results are non-detect for the VOCs/SVOCs or do not indicate a statistically significant differenceforthe metals,then the Pennittee may remain in Detection Monitoring. (b) The Pennittee shall implement the post-closure ground water protection program in Section E of the approved pennit application, as modified by permn Condition B.35(a), by May 1, 2005i (c) The Detection Ground Water Monitoring Program,**refe~nced** in permit Condition J.7(b), must be able to detennine with reasonable confidence whether any hazardous constituents have entered the ground water as a result of activities from the unit/area covered by this penni!. The Pennlttee shall detennine ground water quality as follows: (I) The Pennittee shall collect, preserve, and analyze samples pursuant 

### to Pennit Condition 

### J.4. (ii) The Permittee shall determineground waterqualityateach monitoring well annually during the post-closure care period of the regulated units, exceptthatsampling and analysisfornewmonitoringwells MW32 and MW-33shall be conducted onthefollowing schedule: quarterly forthe

### firsttwo years, then semi-annuallyforfive years, then annually.



### VES016670Ross Incineration Services, Inc. Hazardous Waste lnslaUatlon & OperaUan Pennlt Renewal Page 95 of101 

### (iiQ

(IV)
(V)



### (vi) The Permittee shall express the ground water. quality at each monitoring well in a form necessary for the determination of statistically significant increases. The Permittee shall determine the ground water 

### flow rate ·and direction in the uppermost aqulfer at least annually. The Permittee shall determine whether there are any statistically significant Increases over the background values for all parameters Identified in permit**Cond~on** 

### J.3(a) each time ground water quality is determined atthe complia'llce poinl In determining whethersuch an increase has occumed, the Permittee mustcompare the groundwater quality at each monitoring well specified in permit Condition J.2(a) to the background ground water quality specified in permit Condition. J.3(b)orotherstatistical limitapproved bythe director, in accordance 

### with the statistical procedures specified in permit Condition J.6. If there Is aconfirmed detection ofanyof

### the parameters Usted in permit Condition J.3(a), then the Permittee shall take the response actions and fulfill the requirements of permit Condition J.10 regarding statistical evidence ofcontamination. The Permittee shall perform the evaluations described in permit Condition J.7(c)(v) within 90 days after completion ofsampling. J.8. Recordkeeoing and Reporting OAC Rule 3745-54-97(J) (a) Ooeratlng Record · OAC Rules 3745-54-73(8)(5) and (6}, 

### 3745-54-97(J) and 3745-54-98(C) Ohio EPA may request a copy ofthe full QualityAssurance/Quality Control (QA/QC) reportfor a particular sampling event if

### circumstanceswarrant, but in general QA/QC data will not be required except as described below. The Permittee shall enter all ofthe following information obtained in accordance with permit Conditions 

### J.5 and J.7 In the operating record, as required by OAC Rules 3745-54-73(8)(5) and 

### (6), 3745-54-97(J) and 3745-54-98(C): The laboratory results from each of the wells and their associated qualifiers including the laboratorysheets forthefull volatile and**semi~** 

### volatile analyses (must include method codes, detection,limits, and · units ofmeasurement); \ OHIO 

### EPADHWM 

## SEt' 30 2003

VES016671Ross Incineration Services, Inc. Hazardous Waste lnstoUatlon & Operation PermR Renewal Page S6 ol101 · · (ii) The date each well was sampled (tabulated); Qii) The date, time, and identification of all blanks and duplicates; (lv) 

### Any field log documentation ofdeviation from the procedures in the Part B permit application orthe Sampling and Analysis Plan (SAP), including documentation ofparameter omissions during thesampling event. · ·

. (v) The date the Permittee**I"EI~lved** the results from the laboratory;

(vi) The date the owner or operator completed their review of the analytical laboratory'sverification oftheaccuracyand precision ofthe analytical data and determined its quality. This reviewshall be based upon the elements In permit Condition J.S.(a)(vii); 

## '


# . (vii) The results of the data validation review per permit Condition J.B(a)(vi) including: report completeness, chain of custody, sample receipt form, signed statement of validity, technical holding time review, dataqualifiers Includingtheirdefinitions, dilutions, blank data, spikes, spike recovery 

### %, surrogate recovery, and an explanation of any rejected results consistent 

### with the U.S. EPA and Ohio EPA guidelines for data review; (viii) Results of all blanks and duplicates (trip, field,· equipment, and method); (ix) Results ofthe field parameters; (x) 

### All chains ofcustody; (xi) The datethe statistical evaluation was completed; (xii) The statistical evaluation of the data according to the statistical tests(s) that the Director has specified (must include ali computations and results ofstatisticaltests) OAC Rules3745-54-73(B)(6), 3745-54- 97(J) and 3745-54-98(C); (xiii) Any change in well status (i.e., going from unaffected to affected status and vice versa); '·'· \


## SEt' 3 02003

VES016672'--. ,-;:" Ross Incineration SeNices, Inc. Hazardous Waste Installation & OpOI'IIIIon Pennft Renewal Page 97 of 101 

### (xiv) Ground water surface elevations taken at the time of sampling each well as required 

### by OAC Rule 3745-54-73(8)(6); (XV) 

### Data and results ofthe annual determination ofthe ground waterflow rate and direction as required by OAC Rule 3745-54-73(8)(6); and (xvi) The results of the last three yeani ofall inspections required under OAC Rule 3745-54-15(D) related to ground water monitoring and equipment as required under OAC Rule 3745-54-73(B)(5). (b)

. All established

### b~:;~~~·~~[,~,~ determine ,., submitted submit the analytical results, an appropriate method, and the statisticalcalculationswithin 90 days ofthe completion ofthe lastbackground sall'!pling event. (c) Annual & 

### Other Periodic Required Reoorts OAC Rules 3745-54-75 and 3745-54-97(J) The Permittee must submit an annual report to the Director by March 1st or the first business daythereafter ifthis falls on aweekend. The annual report must reference the titles and dates ofany otherperiodic reports required by the permit or any updates tothose reports (for example, due to confirmation sampling, comments by Ohio EPA, etc.), butgenerallydo not need to include duplicates of hard copies previously submitted. The annual report must include, at a minimum, the analytical results required by permit Conditions J.7(c)(ii), thegroundwaterelevation data required bypermitCondition J.!i(a), ·the annual flow rate and direction required by penni! Condition J.7(c)(iv), and the results of the initial statistical analyses required by permit Condition J.7(c)(v). In addition, a copy on disk 

### ofall ground water and blank data must be submitted electronically intheformat supplied bythe Director, a hard copy of well-specific information (location [latitude and longitude], depth, construction, etc.) for any new/replacementwells, and any other information specified in the instructionsforthe annual report not addressed in this permit Condition must be submitted by March 1

..ofthe subsequentyearas required by OAC Rule 3745-54-75.



### OHIO EPADHWM 

## MAR 02 

## 2005

VES016673Ross Incineration SeNices, Inc. Hazardous Waste lnslalletlon & Operation**PIIITII~** Renewal Page 98 of 101 · 

### (d) Other Reoorts OAC Rule 3745-54-77(C) The Pennittee shall comply 

### with any reporting requirements that become necessary under permit Condition J.10 In accordance with the schedules In the regulations covered by that permit Condition and as required by OAC Rule 3745-54-77(C). If any ofthese dates falls on a weekend, the reports will be due no later than the following business day. Be-sampling reports must include the same types of information as the initial reports pertaining
· only to the re-sampled well(s).

. · J.9 Assurance of Compliance OAC Rules 3745-54-92 and 3745-54-98 The Permittee shall assurethe Directorthatduringtheterm ofthe permittheground water monitoring program will ensure the earliest possible detection of contamination leakagefrom the regulated units,thatanycontamination leakagewill be characterized, and that the need for further action will be determined. J.10 Specjal Requirements If 

### Significant Increases Occur In Values for Parameters or Constituents OAC Rule 3745-54-98(G) If the Permittee has determined a statistically significant increase in any of the metals.identified in PermitConditionJ.3(a) inaccordancewith statistical procedures specified In PennitCondition J.Sand J.7, oradetection abovethe method detection limitfor anyVOCs or SVOCs Identified in Permit Condition J.7(a)(lv) and J.7(a)(v), the Penilittee must (a) Notifythe Directorin writing, within seven (7) 

### days ofthat determination. The notification must indicate what parameters or constituents have shown statistically significant increases (metals) or detection !!bove method detection limits (VOCs/SVOCs) and the corresponding analytical results. (b) Within 30 days re-sample the ground water in the affected well(s) in Permit ConditionJ.2(a) and determinethe concentration ofwell-speclficparameters listed In Permit Condition J.10(a). (c) Ifthe results ofthe resample confirm the initial results for metals, VOCs, or SVOCs or if the Permittee elects not to re-sample, then the detected compounds form the basis for compliance monltcring. If the re\sampling 

### OHIO EPADHWM



# . SEP 30Z003 '. 

### '

VES016674'·, '';,**~** . 

### ·' Roas lnclnera1ion SeMce8, Inc. Hazardous Waste lnalallallon &Operation PonnkRenewal Page 99 of 101 · 

### results are non-detectfor the VOCs/SVOCs ordo not indicate astatistically significant difference for the metals, then the Pennittee may remain In Detection Monitoring. (d) Within 90 days 

### ofconfirming a statistically significant Increase in metals or aVOC/SVOC detectionabove method detection limits, submittothe Director an application forapennit modification to establish acompliance monitoring

(e) ·program. The application must include the following infonnation: (i) An identification ofthe cqncentration of each metal, VOC or SVOC detected in the ground 

### water ateach monitoring well at the point of compliance

.

.(ii) 

### Any proposed changes tothe ground water monitoring system atthe facility necessaryto meetthe requirements ofcompliance monitoring under OAC Rule 3745-54-99. (iii) Any proposed changes to 

### the monitoring frequency, sampling and analysis procedures ormethods orstatistical procedures used atthe facility necessary to 

### meetthe requirements ofcompliance monitoring and the Ground Water Protection Standard. (iv) 

### For each hazardous constituent detected at the compliance point, a proposed concentration limit under OAC Rule 3745-54-94(A)or a notice of intent to 

### seek an alternate concentration limit ·for a hazardous constituent under OAC Rule 3745-54-94(8). (v) The Pennittee shall begin sampling and analy;zing for the new constituents atthe next regularly scheduled sampling eventfollowing the event in which they were determined to be present. Submit to the Director an engineering feasibility plan (EFP) for corrective action and all data necessary to satisfactonly justify an alternate concentration limit (ACL) within 180 days 

### of detennining a statistically significant increase, unless the concentrations ofall hazardous constituents identified underpennitCondition J.1O(b) do notexceedthe respective values fisted in Table 1ofOAC Rule 3745-54-94 (ortheir respectiveMCLs), orthe Pennittee has sought an ACL variance for every hazardous constituent identified under pennit Condition J.1O(b). If

### the Pennittee's ACL request is

· denied, Ohio EPA will specify a time frame for submittal ofthe EFP. '· '· 

### OHIO EPA Dff.\':,1



## SEt' 302003

... ·--- ·-·----------


### VES016675RosalnclneraUon Servfc:et1, Inc. Haurdoua W&ala lnalallatlon & Opentllcn Panni! Renewal Page 100 of 101 

### (f) If the Permitteedetermines, pursuantto PermitCondition J.7( c)(V), thatthere Is a statistically significant increase above the background values for the hazardous parameters specified in Permit Condition

.J.3(a), he may demonstrate thata source other than a regulated unit caused the Increase orthatthe Increase resulted from error in sampling, analysis, or evaluation or natural variation in the ground water. In such cases, the Permittee shall: 

### (1) Notify the Director in writing within seven 

### (7) days 

### of determining a statistically significant increase that he intends to make a demonstration.

. . ·

. . 

# . (ii) Within 90 days 

### of determining a statistically significant increase, submit a reportto the Director which successfully demonstrates that a source otherthan a regulated unit caused the increase, orthatthe

. increase resulted from error in sampling, analysis, orevaluation. (iiO Within 90 days of determining a statistically significant increase, submittothe Director an application fora permitmodificationto make any appropriate changes to the detection monitoring program atthe facility. (IV) The Permittee may make this demonstration in addition 

## to, or in lieu 

### of, submitting a permit**modificatior:~** application for a compliance ground water monitoring program under OAC Rule 3745-54-99. However, 

### the same period 

### of ninety (90) days is required for both a successful "Other Source Demonstration• and the submittal of the permit modification application for compliance ground water monitoring. The Permittee is not relieved 

### of the ninety (90) day requirement for submitting a permit modification unless the "Other Source Demonstration• is deemed successful by· Ohio EPA prior to the ninety (90) day time Hmil (v) Continue to monitor in accordance 

### with the detection monitoring program at

### the facility. J.11 Reouest for Permit Modification OAC Rule 3745-54-98(H) Ifthe Permittee or the Director determines the detection monitoring program no longer satisfies the requirements ofthe regulations, the Permittee must, within 90 days ofthedetermination, submitthe date ofthatdetermination and an application 

### OHIOEPAOh'WM 

## SEP 3 02003

VES016676Rosa lnclneraUon Services, Inc. Hazardous Waste Installation &Opwtion Pennlt Ranewal Page 101 of 101 

### forapennitmodification

### to make any appropriate changes

### totheprogramwhichWill 

### satisfythe regulations. · Nothing in this permit shall limit Ohio EPA from requiring additional ground water protection requirements in the Permittee's corrective action program or In any. post-closure pennit issued to the Permittee.
END OF PERMIT CONDinONS



### OHIOEPAOh'Vf.w 

# SEr 302003

VES016677

# VES016678-016711.pdfOHD 980 613 541

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) PERMIT

Facility Name and Location: Heritage·WTI. Inc. fWTD 1250 St. George Street East Liverpool. Ohio 43920 Owner(s): Heritage-WTI. Inc. (WTD 1250 St. George Street East Liverpool. Ohio 43920 Operator(s): Heritage-WTI. Inc. IWT!l 1250 St. George Street East Liverpool. Ohio 43920 U.S. EPAIdentification Nnmber: OHD 980 613 541 Effective Date: May 1. 2009 Expiration Date: May 1. 2019

Aathorized Activities: 

# • The U.S. Environmental Protection Agency hereby issues a Resource Conservation and Recovery Act (RCRA) permit (hereinafter referred to as the "permit") to Heritage-WTI, Inc. (d.b.a. WTI) (Owner and Operator hereinafter referred to as the "Pennittee" or addressed inthe second person as "you") in connection with the hazardous waste treatment, storage, and disposal facility in East Liverpool, Ohio. This permit is issued underthe Solid Waste Disposal Act, as amended bythe Resource Conservation and Recovery Act of 1976, and the Hazardous and Solid Waste Amendments (HSWA) of 1984 (42 USC§ 6901 et seq.) (collective1yreferredto as RCRA) and EPA's regulations promulgated thereunder (codified, and to be codified, in Title 40 ofthe Code of Federal Regulations (40 CFR)).

'I



### VES016678OHD 980 613 541

Specifically, this pemrit addresses (1) air emissions standards for equipment leaks (40 CFR Part 264, Subpart BB), for tanks and containers (40 CFR Part 264, Subpart CC), and for miscellaneous units (40 CFR Part 264, Subpart X); and (2) other federal RCRA regulations for which the state has not yet been authorized. This permit contains the federal RCRApermit conditions. The Permittee also has a state RCRA pepnit which contains conditions issued bytheState ofOhio's RCRAprogram authorized under 40 CFR Part 271. Anyhazardous waste activity whichrequires a RCRA permit and is not included either in this permit orthe state RCRA permit is prohibited. Permit Approval: On June 30, 1989,the State ofOhio received final authorizationpursuant to Section 3006 of RCRA, 42 USC§ 6926, and 40 CFRPart 271, to administer the pre-HSWA RCRA hazardous waste program. The State ofOhio has also received final authorization to administer certain additional RCRA requirements on several occasions since then. However, because the U.S. EPA has not yet authorized the State ofOhio to admiriister certain regulations, including air emission standards for eqnipment leaks, tanks and containers, and air emission standards associated with miscellaneous units, and certain otherregulations, the U.S. EPA Region 5 is issning the RCRA pennit reqnirements for operations at the Permittee's facility which fall underthese regulations. You must comply with all tenns and conditions contained in this permit. Thispermit consists of all the conditions contained herein, all documents attached hereto and all documents listed or cross-referenced in these documents, approved submittals (including plans, schedules and other documents), and the applicable regulations contained in 40 CFR Parts 124, 260, 261,262,264, 266, 268, 270, and applicable provisions ofRCRA. This permit is based on the assumptions thatthe information submitted: (1) in the Permittee's RCRA permit renewal application and in any subsequent modifications to that application (hereinafter referred to as the "Application"), is accurate, and (2) that the facility is configured, operated and maintained as specified 

### in the permit, and as described in the Application. Anyinaccuracies in the submitted information maybe grounds for the U.S. EPA to terminate, revoke and reissue, ormodifY this permit 

### in accordance with 40 CFR §§ 270.41, 270.42 and 270.43; and for enforcement action. You must inform the U.S. EPA ofany deviation from, or changes in, the informationin the Application thatmight affect your ability to comply with the applicable regulations or conditions ofthis permit.

ii



### VES016679OHD 980 613 541


### Opportunityto Appeal: Petitions for review must be submitted within 30 days after EPA serves notice ofthe final permit decision. Anyperson who filed comments on the draftpermit or participated inthepublichearing may petition the Environmental Appeals Board to review any condition ofthe permit decision. Any person who failed to file comments orfailed to participate in the public hearing on the draft permit may file a**p~tition** for review only to the extent ofthe changes from the draft to the final permit decision. The procedures for permit appeals are found in40 CFR § 124.19. 

### Effective Date: This permit is effective as ofMay 1. 2009 and will remain ineffect until May l. 2019, unless revoked and reissued under 40 CFR § 270.41, terminatedunder 40 CFR § 270.43, or continuedin accordance with 40 CFR § 270.51(a).

# By:f-.,~~4-

. are! M. Guernero uector Date: 

# vVlM. 

# 81 2IJDj

Land and Chemicals Division



### iii

VES016680OHD 980 613 541

TABLE OF CONTENTS

SECTION I--STANDARD PERMIT CONDITIONS

.................................................................... ! i.A EFFECT OF PERMIT

............................................................................................ ! I.B PERMIT ACTIONS

................................................................................................ ! LB.! Pennit Review, Modification, Revocation and Reissuance, and Termination

................................................................................................. ! I.B.2 Permit Renewal

.............................................................................................2 I.C SEVERABILITY

....................................................................................................2 LD DEFINITIONS

........................................................................................................2 I.E DUTIES AND REQUIREMENTS

..........................................................................2 I.E.! Duty to Comply

.........................................................................................2 l.E.2 Duty to Reapply

........................................................................................3 LE.3 Penni! Expiration

......................................................................................3 LE.4 Need to Halt or Reduce Activity Not a Defense

.......................................3 I.E.5 Duty to Mitigate

........................................................................................3 I.E.6 Proper Operation and Maintenance

...........................................................3 I.E.7 Duty to Provide Information

.....................................................................3 I.E.8 Inspection and Entry

.................................................................................4 I.E.9 Monitoring and Records

............................................................................4 I.E.!O Reporting Planned Changes

......................................................................

### 5 I.E.ll Reporting Anticipated Noncompliance

.....................................................5 LE.l2 Certification ofConstruction

.....................................................................

### 5 l.E.13 Transfer ofPennits

....................................................................................6 I.E.I4 Twenty-Four Hour Reporting

...................................................................6 LE.IS OtherNoncompliance

...............................................................................7 I.E.16 Other Information

......................................................................................7 I.F SIGNATORY REQUIREMENT

............................................................................8 I.G REPORTS, NOTIFICATIONS AND SUBMITTALS

...........................................

### 8 I.H CONFIDENTIAL INFORMATION

......................................................................8 !.I DOCUMENTS TO BE MAINTAINED AT THE FACILITY

..............................8 I.L I Operating Record

.........................................................................................9 

### U.2 Notifications

...............................................................................................9 I.L3 Copy ofPermit

............................................................................................9 I.J ATTACHMENTS AND DOCUMENTS INCORPORATED BY REFERENCE

..........................................................................................................9 I.K COORDINATION WITH THE CLEAN AIR ACT

............................................ 10

iv



### VES016681OHD 980 613 541

TABLE OF CONTENTS (CONTINUED) SECTION II-- OTHER FEDERAL RCRA REQUIREMENTS

.................................................. ! 0 II.A Additional Hazardous Waste Numbers

................................................................ ! 0 SECTION III-- AIR EMISSION STANDARDS FOR EQUIPMENT LEAKS (40 CFRPart 264, Subpart BB)

................................................................ ! 0 liLA General

...................................................................................................................I0 III.B Equipment Leaks

................................................................................................... !! III.B.! Waste Determination and Equipment

....................................................... 11 III.B.2 Pumps in Light Liquid Service

.................................................................. !! III.B.3 Pressure ReliefDevices in 

### GasN apor Service

......................................... 12 III.B

### A Sampling Connection Systems ......................................•.........................12 III.B.5 Open-Ended Valves orLines .................................................................. 13 III.B.6 Valves in GasNapor Service or in Light Liquid Service

........................ 13 III.B.7 Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light Liquid or Heavy Liquid Service, and Flanges and Other Connectors

............................................................................. 13 III.B.8 Delay ofRepair

...................................................................................... 14 III.B.9 Closed-Vent Systems and Control Devices

........................................... 14 III.B.l0 Alternative Standards for Valves in Gas!Y.apor Service or in Light Liquid Service; Percentage ofValves Allowed to Leak

................ 14 III.B.ll Alternative Standards for Valves in GasNapor Service or in Light Liquid Service: Skip Period Leak Detection and Repair

............... 15 III.B.l2 Test Methods and Procedures

................................................................ 15 III.B.I3 Recordkeeping and Reporting Requirements

.........................................15 SECTION IV-- AIR EMISSION STANDARDS FOR TANKS AND CONTAINERS (40 CFRPART264, Subpart CC) IV.A General

................................................................................................................... 15 IV.B Waste Determination

............................................................................................. 16 IV.C Tanks

.................................................................................................................... 17 IV.C.! General

....................................................................................................I 7 IV.C.2 Tank Farm

...............................................................................................I 7 IV.C.3 Process Water Tanks

..........................................................,.................... 19 IV.C.4 BulkFeed Tanks (S-1 and S-2)

...............................................................19 IV.C.5 Laboratory Waste Tank (L-1)

.................................................................20 IV.D Containers

..............................................................................................................20

v



### VES016682OIID 980 613 541

TABLE OF CONTENTS (CONTINUED) IV.D.l Requirements for Levell Container Standards

........................................20 IV.D.2 Requirements for Level2 Container Standards

........................................21 IV.D.3 Compliance with 40 CFR §§ 264.1088 through 1090

...............................22 IV.D.4 Waste Stabilization Prohlbition

................................................................22 IV.E Closed-Vent System and Control Devices

.............................................................22 IV.E.I Closed-vent Systern

...................................................................................22 IV.E.2 Operations ofVentilation HeaderBlower and Secondary Vent Blower

..23 IV.E.3 Control Devices

...............................................:.......................................24 IV.E.4 Disposal ofSpent Carbons

......................................................................... 26 IV.E.5 Compliance with Consent Decree

..............................................................26 IV.F Tanks and Containers ExemptUnder 40 CFR § 264.1082(c)(l) From the Standards in40 CFR §§ 264.1084 Through 264.1087

............................................................26 IV.G Inspection, Recordkeeping, and Reporting Requirements

.......................................27 SECTION V

-- AIR EMISSION STANDARDS FOR MISCELLANEOUS UNITS UNDER 40 CFR PART 264, SUBPART X V.A General

....................................................................................................................27 V.B OlU!ll Extruder Pulper Unit

......................................................................................27

vi



### VES016683OHD 980 613 541 Page I of 28



### SECTION I-- STANDARD PERMIT CONDITIONS [.A EFFECT OFPERMIT Tlris pennitcontains the federal permit conditions. The Permittee also 

### has a state RCRA permit. You are hereby ailowed to manage hazardous waste in accordance with this permit. Under this permit, the storageand treatment ofRCRA hazardous waste must comply with all terms and conditions in this permit. Other aspects ofthe storage and treatment ofRCRA'hazardous wastes are subject to the conditions in the state-issued portion ofthe RCRA permit. Anyhazardous waste activity which requires a RCRA permit and is not included either in this permit or the state RCRA pennitis prohibited. Subject to 40 CFR §270.4, compliance with the RCRA permit during its term constitutes compliance forpurposes ofenforcement with Subtitle C ofRCRA except for those requirements not included in the permit which: (I)become effective by statute; (2) are promulgated under40 CFR Part268 restricting theplacement ofhazardous waste in oron the land; (3) are promulgated under40 CFR Part264 regarding leak detection systems; or (4) arepromulgatedunder subparts AA, BB, or CC of40 CFR Part 265 limiting air emissions. (40 CFR § 270.4) This permit does not: (I) conveyanypropertyrights or any exclusiveprivilege (40 CFR § 270.30(g)); (2) authorize any injury to persons orproperty, orinvasion ofotherprivate rights; or(3) authorize any infringement ofstate or local law orregulations. Compliance with the terms ofthis permit does not constitute a defense to any order issued, or any action brought, under: (1) Section 3013 or 7003 ofRCRA; (2) Sections 104, 106(a), or 107 ofthe Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 USC§§ 9601 etseq. (commonly known as CERCLA); or (3) any other law protecting human health, welfare, or the environment. 

### I.B PERMIT ACTIONS I.B.l Permit Review, Modification,Revocation and Reissuance, and Termination The U.S. EPA mayreview and modifY, revoke and reissue, or terminate this permit for cause, as specified in 40 CFR 

### § 270.41, 

### §270.42, and§ 270.43. TheU.S. EPA may also review and modifY this permit, consistent with 40 CFR § 270.41, to include anyterms and conditions it determines are necessarytoprotect human health and the environment under Section 3005(c)(3) ofRCRA. The filing ofa request for a permit modification, revocation and reissuance, ortermination, or a notification ofplanned changes or anticipated noncompliance on your part will not stay the applicability or enforceability ofany permit condition. (40 CFR 

### §270.30(f))



### VES016684OIID 980 613 541 Page 2 of 28
Youmay request a modification ofthis permitllllder the procedures specified in 40 CPR 

### § 270.42. You mustnot perform anyconstruction associated with a Class 3 permit modification request lllltil suchmodificationrequest is granted and the modification becomes effective. You mayperform construction associated with a Class 2 permit modification request beginning 60 days after submission ofthe request unless the Director, Land and Chemicals Division, U.S. EPA Region 5 (Director), establishes a later date. (40 CFR § 270.42(b)(8)) I.B.2 PermitRenewal This permit mayberenewed as specified in 40 CFR § 270.30(b) and Condition I.E.2 ofthis permit. Inreviewing any application for a permit renewal, the U.S. EPA will consider improvements in the state ofcontrol and measurement technology, and changes in applicableregulations. ( 40 CFR § 270.30(b) and RCRA Section 3005( c)(3)) 

### I.C SEVERABILITY This permit'sprovisions are severable; ifanypermit provision, orthe application ofany permit provision to any circumstance, is held invalid, suchprovision's application to other circumstances and the remainder of

### this permit will not be affected. Invalidation ofany statutory

### orregulatoryprovision on which any condition of

### this permit is based does not affect the validity ofany other statutory

# or regulatorybasis for that condition. (40 CFR § 124.16(a)) 

### I.D DEFINITIONS The terms used in this permit will have the samemeaning as in 40 CFRParts 124, 260 through 266, 268 and 270, unless this permit specificallyprovides otherwise. Where neitherthe regulations nor thepermit define a term, the term's definition will bethe standard dictionary definition orits generally accepted**sc~entific** or industrial meaning. 

### I.E DUTIES AND REQUIREMENTS l.E.l Duty to Comply Youmust comply with all conditions ofthis permit, except to 

### the extent and for the duration for which an emergencypermit authorizes such noncompliance (40 CFR 

### § 270.61). Anypermitnoncompliance, exceptunderthe terms ofan emergencypermit, constitutes a violation ofRCRA and will be grounds for: enforcement action; permit termination; revocation and reissuance; modification; or denial ofa permit renewal application. (40 CFR § 270.30(a))



### VES016685I.E.2 Duty to Reapply OHD 980 613 541 Page 3 of 28

Ifyou wish to continue the permit regulated activities afterthe expiration date, you must apply for and obtain a new permit. You must submit a complete application for a new permit at least 180 days beforethe permit expiration date, unless the Directorgrants permission for a later submittal date. The Director will not grant permission to submit the complete application for a new permit later than the permit's expiration date. (40 CFR 

### § 270.10(h) and§ 270.30(b)) I.E.3 PermitExpiration Unless revoked orterminated, this permit and all conditions herein will be effective until the expiration date ofthis permit. Thispermit and all conditions herein will remain in effectbeyond the permit's expiration date ifyou have submitted a timely, complete application (40 CFR § 270.10 and§§ 270.13 through 270.29), and, through no fault ofyour own, the Director has not made a final determination regardingpermit reissuance. (40 CPR §§ 270.50 and 270.51) I.E.4 Need to Haltor Reduce Activity Not a Defense In an enforcement action, you are not entitled to a defense that itwould have been necessary to halt orreduce thepermitted activity to maintain compliancewith this permit. (40 CFR § 270.30(c)) I.E.S Dutyto Mitigate In the event ofnoncompliance with this permit, you must take all reasonable steps to minimize releases to the environment resulting from the noncompliance and must implement all reasonable measures to prevent significant adverse impacts on human health or the environment. (40 CFR §270.30(d)) I.E.6 Proper Operation and Maintenance You must always properly operate andmaintain all facilities and treatment and control systems (and related appurtenances) thatyou install or use to comply with this permit. Proper operation andmaintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance/quality control procedures. This provision requires you to operate back-up or auxiliary facilities or similar systems only when necessary to comply with this permit. (40 CFR 

### §270.30(e)) I.E.7 Dutyto Provide Information Youmust provide the Director, within a reasonable time, anyrelevant information that the Directorrequests to determine whether there is cause to modify, revoke and reissue, or



### VES016686OHD 980 613 541 Page 4of 28 terminate this permit, or to determine permit compliance. You must also provide the Director, upon request, with copies ofanyrecords this penni!requires. The information you must maintain under this penni!is not subjectto the Paperwork Reduction Act of 1980, 44 USC §§ 3501 etseq. (40 CFR §§ 264.74{a) and 270.30{b)) 

### J.E.8 Inspection and

### Entry Upon the presentation ofcredentials and otherlegallyrequired documents, you must allow theDirector or an authorized representative to (40 CFR §270.30{i)): I.E.S.a Enter at reasonable times upon yourpremises where a regulated activity is located or conducted, or where records must bekept underthe conditions ofthis permit; I.E.S.b Have access to and copy, atreasonable times, any records that you must keep underthe conditions ofthis permit; I.E.8.c Inspect, at reasonable times, any facilities, equipment {including monitoring and control equipment), practices, or operations regulated orreqnired under this permit; and I.E.8.d Sample ormonitor, at reasonable times, any substances at any location to ensure permit compliance or as RCRA otherwise authorizes. Notwithstanding anyprovision ofthis permit, U.S. EPA retains the inspection and access authority which it has under RCRA and other appiicable laws. I.E.9 Monitoring and Records I.E.9.a Samples and measurements taken for monitoring purposes must be representative ofthe monitored activity. Themethods used to obtain a representative sample ofthe wastes, contaminated media, treatment residue, or otherwaste to be analyzed must be the appropriate methods from Appendix I of40 CFR Part 261, or the methods specified in the state-approved and/or U.S. EPAapproved waste analysis plan, or an equivalent method approved bythe Director. Laboratorymethods must be those specified 

### in Test Methods forEvaluating Solid Waste: Physical/ChemicalMethods (SW-846, latest edition),Methods for Chemical Analysis ofWater and Wastes (EPA 600/4-79-020), or an equivalent method, as specified in thereferenced waste analysis plan. (40 CFR § 270.30(j){l)) I.E.9.b You must retain, at the facility, all records as specified in 40 CFR § 264.74. I.E.9.c You must subrrrit all monitoring results at the intervals specified 

### in this permit.



### VES016687OHD 980 613 541 Page 5 of 28

I.E.9.d You mustretain all reports, records, or otherdocuments, requiredbythis permit, and records ofall dataused to complete the application for thispennit, for a period ofat least 3 years from the date ofthe reports, records, or other documents, unless a different period is specified in this penni!. The 3-year period maybe extended byrequest oftheDirector at anytime and is automatically extended duringthe course ofany unresolved enforcement action regarding this facility. (40 CPR§§ 270.30(j), 270.31, and 264.74(b)) I.E.lO Reporting Planned Changes Youmust notifY the Director as soon as possible ofanyplanned physical alterations or additions to thepermitted facility. (40 CFR § 270.30(1)(1)) I.E.ll ReportingAnticipatedNoncompliance You must notifY the Director, 

### in advance, ofany planned changes in thepermitted facility or activity that mayresult in pennit noncompliance. Advance notice will not constitute a defense for any noncompliance. (40 CPR § 270.30(1)(2)) I.E.l2 Certification ofConstruction Subject to the requirements of40 CPR§ 270.32(b)(2) and§ 270.42 AppendiX I, youmust not operate anyRCRA air emission control devices completed after the effective date of this permit, or any hazardous waste management uuits that rely on such devices to meet the requirements ofthis penni!, until you have submitted to the Director, by certified mail or hand-delivery, a letter signed bothbyyour authorized representative andby a registered professional engineer. That lettermust state that theportions ofthe facility coveredby this permit (including ail air eruission control devices requiredbythis permit) havebeen constructed in compliance with the applicable conditions ofthis penni! (40 CFR § 270.30(1)(2)). Inaddition, you must not operate the pennitted control devices, or any hazardous waste management uuits thatrely on such devices to meet the requirements of this permit, until either: I.E.l2.a The Director or his/herrepresentative has inspected those portions ofthe facility and finds them in compliance with theconditions ofthe permit; or I.E.12.b The Director waives priorinspection and the Permittee may commence treatment, storage, ordisposal ofhazardous waste ifthe Permittee has not received notice from the Director ofhis orher intent to inspect within 15 days ofthedate of submission ofthe letterdiscussed in I.E.l2 above, as specified in 40 CFR § 270.30(1)(2)(ii)(B).



### VES016688I.E.13 

### TransferofPennits OHD 980 613 541 Page 6of 28

This pennit is not transferable to anyperson, except afternotice to the Director. You must inform the Director and obtain prior approval ofthe Directorbefore transferring ownership or operational control ofthe facility (40 CFR 

### § 270.42, Appendix 1). Under40 CFR § 270.40, the Directormayrequire pennitmodification, orrevocation and reissuance to change the Permittee's name and incorporate other RCRA requirements. Before transferring ownership or operation ofthe facility during its operating life, you mustnotify the Director and obtainprior approval and notify the new owner or operatorin writing of the requirements ofthis permit and the requirements of40 CFR Parts 264, 268, and 270. (40 CFR §§ 264.12(c), 270.30(1)(3), and 270.40(a)) I.E.14 

### Twenty-Four Hour Reporting I.E.14.a Youmust report to the Director anynoncompliance with this penni! that may endangerhuman health orthe environment. Anysuchinformation mustbe promptlyreported orally, but no later than 24 hours after you become aware ofthe noncompliance. I.E.14.b The oral report discussing the occurrence and its cause must include the following information (40 CFR §§ 270.30(1)(6) and 270.33): (1) release ofany hazardous waste that may endangerpublic drinking water supplies; (2) release or discharge ofhazardous waste which could threaten the environment or human health outside the facility; or (3) fire or explosion from the hazardous waste management facility which could threaten the environment orhuman health outside the facility. You must includethe following information: (1) Name, title andtelephone number ofthe person making the report; (2) Name, address and telephone number ofthe facility; (3) Name, address and telephonenumber ofowner or operator; (4) Date, time and type ofincident; (5) Lacation and cause ofincident; (6) Identification and quantity ofmaterial(s) involved; (7) Extent ofinjuries, ifany; (8) Assessment ofactual orpotential hazards to the environment and human health outside the facility, where applicable; (9) Description ofany emergency action taken to minimize the threat to human



### VES016689health and the enviromnent; and OHD 980 613 541 Page 7 of 48

(I0) Estimated quantity and disposition ofrecovered material that resulted from the incident. I.E.14.c In addition to the oral notification required under Conditions l.E.l4.a aod I.E.l4.b ofthis permit, a written report must also be provided within 5calendar days after you become aware ofthe circumstances. The writtenreport must include, but is notlimited to, the following: (I) Name, address and telephone number oftheperson reporting; (2) Incident description (noncompliance including anynilease or discharge of hazardous waste), including cause, location, extent ofinjuries, ifany, and an assessment ofactual orpotential hazards to the environment and human health outside the facility, where applicable; (3) Period(s) in which the incident (noncompliance including any release or discharge ofhazardous waste) occurred, including exact dates and times; (4) Whether the incident'sresults continue to threaten human health and the environment, which will depend on whetherthe noncompliancehas been corrected and/or the release or discharge ofhazardous waste has been adequately cleaned up; and (5) Ifthe noncompliance has notbeen corrected, the anticipated period for which it is expected to continue, and the steps taken orplanned to reduce, eliminate, and prevent the recurrence ofthe noncompliance. The Directormay waive the requirement that written noticebeprovided within 

### 5 calendar days; however, you will thenberequired to submit a writtenreport within 15 calendar days ofthe day on which you must provide oral notice, in accordance with Conditions l.E.l4.a and I.E.14.b ofthis permit. (40 CPR§ 270.30(1)(6)) I.E.15 OtherNoncompliance You must report all instances ofnoncompliance not reported under Condition I.E.I4 ofthis permit, when any other reports this permitrequires are submitted. Thereports must contain the information listed in Condition I.E.I4. (40 CPR§ 270.30Q)(10)) I.E.16 Other Information I.E.16.a Whenever youbecome awarethat you failed to submit or otherwise omitted any relevant facts in the permit application or other submittal, or submitted incorrect information in the permit application or other submittal, you must



### VES016690OHD 980 613 541 Page 8of 28 promptlynotifytheDirector ofanyincorrect information orpreviously omitted information, submit the correct facts or information, and explainin writing the circumstances ofthe incomplete orinaccurate submittal. (40 CFR § 270.30(1)(11)) I.E.16.b All otherrequirements contained in40 CFR § 270.30 not specifically described in this permit are incorporated into this permit and you must complywith all those requirements. I.F SIGNATORY REQUIREMENT You must sign and certify all applications, reports, or information this permit requires, or which are otherwise submittedto the Director, in accordance with 40 CFR § 270.11. (40 CFR § 270.30(k)) I.G REPORTS, NOTIFICATIONS AND SUBMITTALS Except as otherwise specified inthispermit, all reports, notifications, or other submittals that this permitrequires to be submittedto the Director, the Regional Administrator, or to U.S. EPA should be sentby certifiedmail, express mail, or hand-delivered to the U.S. Enviromnental Protection Agency, Region 5, at the following address: RCRA Branch, LR-8J Land and Chemicals Division U.S. EPA RegionS 77 WestJackson Boulevard Chicago, fllinois 60604 1.11 CONFIDENTIAL INFORMATION In accordance with 40 CFR Part 2 Subpart B, you may claim any information this permit requires, or is otherwise submitted to the Director, as confidential. You must assert any such claim at the time ofsubmittal inthemannerprescribed on the application form or instructions, or, inthe case ofother submittals, by stamping the words "Confidential Business Information" on each page containing such information. Ifyou made no claim at the time ofsubmittal, the Directormay makethe information available to the public without further notice. Ifyou assert a claim, the information will be treated in accordance with the procedures in40 CFR Part 2. (40 CFR § 270.12) 1.1 DOCUMENTS TO BEMAINTAINED AT THE FACILITY Youmust maintain at the facility, until closure is completed and certified by an independent registered professional engineer, the following documents and 

### all amendments, revisions, and modifications to them.



### VES016691

### 1.1.1 OperatingRecord OHD 980 613 541 Page 9 of 28

You mustmaintain in the facility's operatingrecord the documents required bythis permit, and bythe applicableportions of40 CFR §§ 264.1035, 264.1064,264.1084,264.1088, 264.1089 and 40 CFR § 264.73 (as they apply to the equipment used to comply with this permit). 1.1.2 Notifications Ifyou receive hazardous waste(s) from off-site generator(s), you must maintain notifications from generators accompanying initial incoming shipment ofwastes subject to 40 CFR Part 268 Subpart C, that specifytreatment standards, as required by40 CFR §§ 264.73, 268.7, and this permit. 

### 1.1.3 Copy ofPermit You must keep a copy ofthis permit on site, including all the documents listed in any attaclunents, and you must update it as necessary to incorporaie any official permit modifications. 

### I..J ATTACHMENTS AND DOCUMENTS INCORPORATED BY REFERENCE I.J.l All attachments and documents that ibis permit requires to be submitted, ifany, including 

### all plans and schedules are, upon the Director's approval, incorporated into this permit byreference and become an enforceable part ofthis permit. Since required items are essential elements ofthis permit, failure to submit any ofthe required items or submission ofinadequate orinsufficient information maysubject you to enforcement action under Section 3008 ofRCRA. This action may include fines, or permit suspension orrevocation. LJ.2 This permit also includes the documents attached hereto, all documents crossreferenced in these documents, and the applicable regulations contained in40 CFR Parts 124, 260, 261, 262, 264, 268, 270, and the applicable provisions ofRCRA, all ofwhich are incorporated herein byreference. I.J.3 Any inconsistency ordeviation from the approved designs, plans and schedules is a permit noncompliance. The Directormay grant written requests for extensions ofdue dates for submittals required in this permit. I.J.4 Ifthe Directordetermines that actions beyond those provided for, or changes to what is stated herein, are warranted, the Directormaymodifythis permit according to procedures in Condition I.B ofthis permit. I.J.5 Ifanydocuments attached to this permit are found to conflict with any ofthe Conditions inthis permit, the Condition 

### will take precedence.



### VES016692LK COORDINATIONWITH THE CLEANAmACT 

### OIID 980 613 541 Page 10 

### of 28



### You must fully comply with the requirements contained in this permit. This permit does not include the requirements imposed by the Clean Air

### Act. SECTION 

### II- OTHER FEDERAL RCRA REQUmEMENTS li.A ADDITIONAL HAZARDOUS WASTE NUMBERS 

### In addition to the hazardous waste numbers listed in 

### the state-issued portion ofthe RCRA permit, you may handle the newly listed hazardous wastes, promulgated under the HSWA, at your facility ouly ifyou have processed a Class 2 permit modification in accordance with 40 CFR § 

### 270.42(g). All handling ofthese wastes must comply with the provisions of the state-issued portion ofthe RCRA permit that (i) are applicable to 

### hazardous wastes, and (ii) 

### are in accordance with regulations for which the state has 

### been federally authorized pursuant to Section 3006 ofRCRA (42 USC § 6926), 

### and 40 CFR Part 271. In 

### addition, all handling ofthese wastes must also comply with ail provisions ofthe federally-issued portion oftheRCRA permit. Hazardous Waste Numbers: Kl81

SECTION III·- AmEMISSION STANDARDS FOR EQUIPMENTLEAKS (40 CFR 

### Part264, SubpartBB) III.A GENERAL 

### III.A.l In 

### accordance with 40 CFR § 

### 264.1 064(m), ifequipment is subject to 40 CFR Part 264, Subpart BB and to regulations at 40 CFR Part 60, 61, or 63, the Permittee may elect to determine compliance with 40 CFR Part 264 Subpart BB eitherby documentation pursuant to 40 CFR § 

### 264.1064 ofthis subpart, orbydocumentation ofcompliance with the regulations at 40 CFR Part 60, 61, or 63. The documentation ofcompliance under 40 CPR Part 60, 61, or63 shall be kept with or made readily available with the facility operating record. III.A.2 Ifthe Permittee elects to determine compliance with the regulations at 40 CFR Part 264 Subpart BB by documentation ofcompliance with the regulations at 40 CFR Part 60, 61, or 63, as specified in 40 CFR §

### 264.1064(m), the air 

### emission standards for equipment leaks specified hereinafter shall not apply, except as specified in 

### III.A.3 and III.A.4. III.A.3 The election in III.A.1

- 2 above is applicable only forperiods during which the equipment is operated, monitored and repaired in accordance with an air emission standard in 40 CPR Part 60, 61, or 63 that is applicable to the equipment. For any period during which any piece ofequipment used in 

### your facility would otherwise be subject to the requirements of40 CFR Part 264, Subpart BB, and during which:

VES016693OHD 980 613 541 

### Page II 

### of 28



### III.A.3.a such equipment is not subject to regulation under an applicable air emission standard in 40 CFR Part 60, 61, or 63; III.A.3.b the applicable standard does not require that such equipmentbe operated monitored, and repaired in accordance with the standard; or III.A.3.c the standard does not require that appropriate records ofsuch equipment be prepared and maintained; then: you must comply with and keep documentation ofcompliance in accordance with the requirement of40 CFR Part 264 Subpart BB. III.A.4 The Permittee shall provide annually to the Director a certification describing the Permittee's election ofcompliance. III.B EQUIPMENT LEAKS (40 CFR Part264, SubpartBB) The Permittee must process a permitmodification and have it approved by the Director, prior to installation and operation ofa compressor(s) which is (are) in contact with hazardous waste with organic concentrations ofat least I0 percent by weight. III.B.l Waste Determination and Equipment The Permitteemust determine each hazardous waste stream for which (I)the hazardous waste is "In light liquidservice"

### as defined in 40 CFR §264.1031 and (2) the hazardous waste has an organic concentration ofat least l 0 

### percentby weight. You must comply with all applicable requirements of40 CFR § 

### 264.1 050 through 40 CFR § 

### 264.1065, regarding air emission standards for equipment leaks. III.B.2 Pumps in Light Liquid Service (40 CFR § 264.1052) III.B.2.a Each pump in light liquid service must be monitored monthly to detect leaks bythe methods specified in 40 CFR § 

### 264.1063(b), except: any pump that is (I) 

### equipped with a dual mechanical seal system and for which the requirements of 40 CFR § 

### 264.1052(d) are satisfied, (2) designated, as described in 40 CFR § 

### 264.1064(g)(2), for no detectable emissions, as indicated by an instrumentreading ofless than 500 ppm above background, and for which the requirements of40 CFR § 

### 264.1052(e) are satisfied, or (3) equipped with a closed vent system complying with the requirements of40 CFR § 

### 264.1052(1). III.B.2.b Each pump in light liquid service shall be checked by visual inspection each calendar week for seal leaks.

VES016694OHD 980 613 541 Page 12 of 28 -III.B.2.c A leak is detected if. (1) an instrumentreading of!O,OOO ppm or greater is measured, or (2) there is anindication ofliquid dripping from thepump seal. III.B.2.d When a leak is detected, it shall be rep.aired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR §264.I059 • Standards: Delayofrepair. The frrst attempt at repair must be madeno later than 

### 5 calendar days after eacb leak is detected. III.B.3 Pressure ReliefDevices 

### in GasNapor Service (40 CFR § 264.1054) III.B.3.a Except during pressure releases, each pressure reliefdevice in gas/vapor service shallbe operated withno detectable emissions, as indicated by an instrumentreading ofless than 500ppm above background, based on the method specified 

### in 40 CFR § 264.!063(c). (40 CFR § 264.1054(a)) III.B.3.b After eachpressure release, the pressure reliefdevice shall be returned to a condition ofno detectable emissions (i.e., less than 500 ppm above background based on the method specified in 40 CFR § 264.1063(c)), as soon as practicable, but no laterthan 

### 5 calendar days after each pressure release, except as provided 

### in 40 CFR § 264.1059. (40 CFR § 264.1054(b)(l)) III.B.3.c No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to confirm the condition ofno detectable emissions, as indicated byan instrument reading of!ess than 500ppm above background, as measured bythe method specified 

### in 40 CFR § 264.1063(c). (40 CFR § 264.1054(b)(2); 40 CFR § 264.1063(c)) III.B.3.d Any pressure reliefdevice that is equipped with a closed-vent system capable ofcapturing and transporting leakage from the pressure reliefdevice to a control device as described in40 CFR § 264.1060 is exempt from the requirements in ConditionIII.B.3.a through III.B.3.c. IU.B.4 Sampling Connection Systems (40 CFR § 264.1055) Each sampling connection system, except in-situ sampling systems and sampling systems withoutpurges, shall collectthe samplepurge for return to theprocess or for routingthem to the appropriate treatment system, and shall be equipped with a closed-purge, closed-loop, or closed-vent system which meets one ofth<> following requirements: III.B.4.a Return the purged process fluid directly to the process line; IU.B.4.b Collectandrecycle the purged process fluid; or IU.B.4.c Be designed and operated to capture and transport all the purged process



### VES016695OHD 980 613 541 Page 13 of 28 fluid to a wastemanagementunit that complies with applicable sections of40 CFR §. 264.1084 through§ 264.1086 or a control device that complies with 40 CPR § 264.1060, Standards for Closed-Vent Systems and Control Devices. III.B.S Open-ended Valves or Lines (40 CFR § 264.1056) III.B.5.a Each open-ended valve or linemust be equipped with a: (1) cap, (2) blind flange, (3) plug, or (4) second valve, which seals the open end at all times except during operations requiring hazardous waste stream flow through the open-ended valve orline. m.B.S.b When a double block and bleed system is used, thebleed valve or line mayremain open during operations that require venting the line between the block valves but shall seal the open end at all othertimes. III.B.S.c Each open-end valveor line equipped with a second valve shall be operated in a manner such that the valve onthe hazardous waste stream eud is closed before the second valve is closed. m.B.6 Valves in GasNapor Service orin LightLiquid Service (40 CFR § 264.1057) III.B.6.a Each valve in gas/vapor service or in light liquid service shall be mouitored monthly to detect leaks in accordance with 40 CPR§ 264.1057(a) and (c), except as provided in 40 CPR§§ 264.1057(f), (g), and (h), 264.1061 and 1062. III.B.6.b Ifaninstrumentreading ofI0,000 ppm or greater is measured, a leak is detected. When a leak is detected, it mustberepaired as specified in 40 CPR§§ 264.1057(d) and (e). III.B.7 Pumps and Valves in Heavy Liquid Service, Pressure ReliefDevices in Light Liquid or HeavyLiquid Service, and Flanges and Other Connectors (40 CFR § 264.1058) III.B.7.a Pumps and valves inheavy liquid service, pressure reliefdevices in light liquid orheavy liquid service, and flanges and other connectors must be monitored within 5 days by the method specified in 40 CFR § 264.1063(b) ifevidence ofa potential leak is found byvisual, audible, olfactory, or any otherdetection method. Ifan instrument reading of 10,000 ppm or greater is measured, a leak is detected. III.B.7.b When a leak is detected, you must repair the leak as soon as practicable, butnot later than 15 calendar days after it is detected, except as providedin40 CFR § 264.1059. The first attempt at repair shall bemade no later than 5 calendar days after each leak is detected. III.B.7.c First attempts atrepairinclude, but are limited to, thebest practices



### VES016696**de~~cribed** under40 CFR § 264.1057(e). OHD 980 613 541 Page 14 of 28

III.B.7.d Any connector that is inaccessible or is ceranric or ceramic-lined is exemptedfrom monitoring and recordkeeping requirements, as specified in 40 CFR § 264.1058(e). (40 CFR § 264.1058(e)) lll.B.S Delay ofRepair (40 CFR 

### § 264.1059) III.B.S.a Delay ofrepair ofequipmentfor which leaks havebeen detectedwill be allowed if: (I) the repair is technically infeasible without a hazardous waste management unit shutdown (in such cases, repair ofthis equipment shall occur before the end ofthe next hazardous wastemanagement unit shutdown); or (2) the equipmentis isolated from the hazardous waste management unit and does noi continue to contain or contacthazardous waste with organic concentrations at least 10%by weight. IIJ.B.S.b Delay ofrepair for valves will be allowed if: (1) emissions ofpurged material resulting from immediaterepair are greater than the emissions like]y to result from delay ofrepair; and (2) when repairprocedures are effected, the purged material is collected and destroyed orrecovered in a control device complying with 40 CFR § 264.1060. III.B.S.c Delay ofrepair forpumps will be allowed if: (I)repairrequires the use of a dual mechanical seal system thatincludes a barrier fluid system; and (2) repair is completed as soon as practicable, butnot later than 6 months after the leak was detected. III.B.S.d Delayofrepair beyond a hazardous waste management unit shutdown wiJI be allowed for a valve only ifprovisions of40 CFR § 264.1059(e) aremet. III.B.9 Closed-Vent Systems and Control Devices ( 40 CFR § 264.1060) Closed-vent systems and control devices used to meet therequirements ofthis Section IIIshall comply with theprovisions of40 CFR §§ 264.1033 and 264.1060. III.B.lO Alternative Standards for Valves in GasNapor Service orin Light Liquid Service; Percentage ofValves Allowed to Leak (40 CFR § 264.1061) You may elect to have all valves within a hazardous waste management unit (e.g., all interconnected tanks in a tank farm or otherhazardous waste management unit) complywith an alternative standard that allows no greaterthan 2% ofthe valves to leak. Ifyou elect to complywith 

### this alternative standard, you must comply with the provisions of40 CFR §§ 264.106l(b)and (c).



### VES016697OHD 980 613 541 Page 15 of 28 III.B.ll Alternative Standards for Valves in Gas/Vapor Service or in LightLiquid Service: Skip Period LeakDetection and Repair (40 CFR 

### § 264.1062) You may elect for all valves subject to the requirements of40 CFR § 264.1057 within a hazardous waste managementunit to complywith one ofthe alternative workpractices specifiedbelow. Ifyou elect to comply with one ofthe alternative workpractices, you must complywith all the requirements for valves as described in III.B.6 ofthis permit, except as specified in III.B.l I.a and III.B.ll.b below: III.B.ll.a After 2 consecutive quarterly leak detection periods with the percentage ofvalves leaking equal to orless than 2 %, you maybeginto skip one ofthe quarterlyleak detectionperiods for thevalves. III.B.U.b After5 consecutive quarterly leak detection periods with the percentage ofvalves leaking equal to orless than 2 %, you maybegin to skip 3 ofthe quarterly leak detectionperiods for the valves. You must monitor valve leaks monthly in accordance with 40 CFR § 264.1057, if thepercentageofvalves leaking is greaterthan 2 %, but you may again elect to use the alternative standards aftermeetingthe requirements of40 CFR § 264.1057(c)(l). III.B.12 TestMethods and Procedures (40 CFR § 264.1063) The leak test methods and proceduresmustbe as specified in 40 CFR §264.1063. III.B.13 Recordkeeping and Reporting Requirements (40 CFR 

### §§ 264.1064 and 264.1065) You must comply with the recordkeeping and reporting requirements of40 CFR § 264.1064 and 264.1065.

SECTION 

### IV-- AIR EMISSION STANDARDS FORTANKS AND CONTAINERS (40 CFRPart 264, Subpart CC) IV.A GENERAL IV.A.l Ifa hazardous waste management unit is equipped with and operating air emission controls in accordance with the requirements ofan applicable Clean Air Act regulation under 40 CFR Part 60, 61, or 63, you may elect to exempt the unit from overlappingregulation under Section IV ofthis permit (except as specified in this Section N.A) ifyou provide a certification satisfying the requirements of40 CFR § 264.1080(b)(7) thatthe hazardous waste managementunit is equipped with and operating air emission controls in accordance with such requirements. Such



### VES016698OHD 980 613 541 

### Page 16 of 28 certi.fication must

### berenewed annually and shall specify

### the regulations under 40 CFR Part 60, 61, or 63 that require the air emission controls. ( 40 CFR § 

### 264.1080(b)(7)) IV.A.l.a As required by40 CFR § 

### 264.10890), you must retain at the facility for each such unit a copy ofthe current certification. Such certification must be provided to U.S. EPA's representative or designee upon request. These documents shall be retained in the manner and for the period specified in 40 CFR § 

### 264.1089(a). IV.A.l.b Ifthe hazardous waste managementunit to be exempted under IV.A.l is a tank for which the air emission control includes an enclosure, such as tanks S-1 and S-2, the tank must be in compliance with the requirements of40 CFR § 

### 264.1084(i) or§ 264.1082(c)(5), as required by40 CFR § 264.1080(b)(7). IV.A.2 Each tank or container in which hazardous wastes are placed must comply with the terms and conditions ofthis Section IV, unless you make the election in, and satisfY all the requirements of, Condition N.A.l above for the tank or container. IV.A.3 You must complywith the terms and conditions ofthis Section N 

### for any tank or container, notwithstanding any election and 

### certification under Condition N.A.l above, in the following circumstances: IV.A.3.a the regulation under 40 CFR Part 60, 61, or 63 on which the election and certification under Condition N.A.l depend is no longer applicable to the tank or container; or 

### IV.A.3.b the regulation under 40 CFR Part 60, 61, or 63 on which the election and certification under Condition N.A.

### I depend, although applicable to the tank 

### or container, does not orno longer requires that air emissions from the tank or container be controlled. When either condition in Condition N.A.3.aor IV.A.3.b occurs, you must immediately comply with the terms and 

### conditions ofthis Section N 

### for such tank or container, and continue compliance until neither condition in Condition N.A.J.a or N.A.3.b applies for the tank or container and the conditions in Condition N.A.l are again satisfied. IV.B WASTE DETERMINATION 

### IV.B.l You must determine the average volatile organic (VO) concentration of: (!) 

### generated hazardous waste at the point oforigination, and (2) treated hazardous waste, in 

### accordance with the procedures specified in40 CFR §264.1083. IV.B.2 You must determine the maximum organic vapor pressure ofahazardous waste in

VES016699OHD 980 613 541 Page 17 of 28

a 

### tank is as-specified in 40

### CFR §§ 264.1084(c) and 265.1084(c)(2) through (c)(4). 

### IV.B.3 The procedure for determining no detectable organic emissions must be conducted in accordance with 40 CFR § 265.1084(d). 

### IV.C TANKS IV.C.1 

### General IV.C.l.a You

### must control airpollutant emissions from eachhazardous waste storage tank in accordance with standards specified in 40 

### CFR §§ 264.1080 through 1082,264.1084 and 264.1087 through 264.1090, except as specificallyprovided otherwise in this permit The tanks used for storage ofhazardous wastemustbe designed, constructed, and maintained consistent with applicable industrial standards to ensure theirintegrity and safety. 

### lV.C.l.b You are authorized to store hazardous wastes with an average VO concentration atthepoint oforigination ofequal or greaterthan 500 ppmw in the following tanks, in accordance with the provisions ofthis permit: (I) Tank Farm (T-1 through T-18, PT-1 through PT-5) (2) Process Water Tanks (W-6 through W-8) (3) BulkFeed Tanks (S-1 and S-2) (4) Laboratory waste (L-1) 

### lV.C.2 Tank Farm The hazardous wastetank farm shall consist ofthe following tanks. Tank No. T-1 T-2 T-3 T-4 T-5 T-6 T-7 T-8 T-9 T-10 T-11 T-12 T-13 T-14 T-15 T-16 T-17 Identification 04-1220 04-1302 04-1385 04-1303 04-1301 04-1202 04-1201 04-1105 04-ll02 04-1.212 04-1211 04-1216 04-1215 04-1210 04-1207 04-1206 04-1205 Description Fuel Oil Tank (mixed with aqueous waste) Blending Tank No. 3 Overflow Tank OOF08 BlendingTankNo. 2 BlendingTank No. 1 Sludge Tank No.2 Sludge TankNo.I Solvent Tank (Formerly Liquid Reception Tank) Solvent Tank (Formerly Sludge ReceptionTank) Organic Liquid Tank No.2 (Soluble Waste) Organic Liquid Tank No. I (Soluble Waste) Aqueous Liquid TankNo.2 Aqueous Liquid TankNo. 1 Organic Liquid TankNo.2 (Insoluble Waste) Organic Liquid Tank No. 1(Insoluble Waste) Organic Liquid Tank No.2 (Chlorioated Waste) Organic Liquid TankNo. I (Chlorinated Waste)



### VES016700T-18 PT-1 PT-2 PT-3 PT-4 PT-5 

### 04-1380 02-1231 02-1232 02-1233 02·1102 02..0660 Overflow Tank Pwnpout Tank No. I Pwnpout TankNo. 2 Pwnpout Tank No. 3 Sludge Reception Tank Overflow T264{) 

### IV.C.2.a Air Emission ControlRequirements OHD 980 613 541 Page 18 of 28

(I) The tanks in thehazardous waste tank fann must meet the Level 2 tank standards as stipulated under40 

### CFR §§ 264.1084(d)(3) and 264.I084(g)(l) through (3), includingbut not limited to therequirements to inspect andmonitor the air emission equipment for the tank and keep records ofthe inspections. Youmust comply with the requirements of40 

### CFR § 264.1084(j). You must comply with the applicable requirements of40 

### CFR §§ 264.1088, 264.1089, and 264.1090 for such tanks. (2} All tanks mustmeet the industrial standards established for such tanks by the American SocietyofMechanical Engineers (ASME), American Petroleum Institute (API), or other equivalent standards. (3) Each vent pipe from a storagetank must be connected to a common vent header, which is connected to the vaporrecoveryheader. The combined vent stream is discharged via a ventilation headerblowerin the vaporrecoveryheader to the air inlet plenum for the kiln primary combustion air fan and/or an activated carbon adsorption system for emission control. (4) Vent piping system from the tanks to the vaporrecoveryheader mustmeet the requirements ofa closed-vent system as defined in 40 

### CFR § 264.1084(d)(3) and as hereinafter specified. IV.C.2.b OperationalRequirements (I) Toprevent overflow ofhazardous waste from the 300-gallon overflow tank PT5 (T2640) to the vent header, the overflow tankmust be monitored by a liquid level element and switch (LS-2640). When liquid is detected in the tank, the pumpout pump and the slurry feed pump shall stop and the inlet valves to thepumpout tanks and sludgereception tank shall automatically close. (2) The temperature, pressure, and liquid level in each storage tank equipped with a mechanical agitator must be monitored through an instrumentation and control system with a high liquid level and a high temperature alann. (3) Theinstrumentation and control system must be maintained as necessary to accuratelymonitor the tank operational parameters (i.e., temperature, pressure, and



### VES016701

### level). OHD 980 613 541 Page 19 of 

### 28

(4) 

### The tanks identified in Condition IV.C.2 must be provided with a nitrogen blanketing system to reduce organic vapors in the tank

### head spaces. The nitrogen blanketing system must beproperly maintained and be.operational to prevent overloading ofthe control devices. In the event ofa system malfunction, you must repair the system as quickly as practicable and maintain the repair record in the facility operatingrecord. IV.C.3 

### Process WaterTanks (W-6 through 8) IV.C.3.a 

### The process water tanks W-6 through W-8 shall be as follows: W-6: 30,000-gallon Scrubber Water Holding Tank W-7: 30,000-gallon Scrubber Water Holding Tank W-8: 6,000-gallon Backwash Settling Tank IV.C.3.b 

### Tank W-6, W-7 and W-8 must meet the Tank Level I standards specified in 40 CFR §§ 

### 264.1084(b) and (c), includingbut not limited to the inspection requirements and the requirement to keep records ofthe inspections. You must comply with the requirements of40 CFR § 

### 264.10840) for such tanks. You must comply with the applicable requirements of40 CFR §§ 

### 264.1088, 264.1089, and 264.1090 for such tanks. IV.C.3.c 

### Other process water tanks and filters, not identified above, must not contain hazardous wastes with an average VO concentration of500 ppmw (parts per million weight) at the point oforigination or greater as determined using the procedures specified in 40 CFR § 

### 264.1083(a) and 

### in accordance with 40 CFR § 

### 264.1 082(c)(l). You must satisfY the requirements ofCondition IV.F, below, for each such tank in which hazardous waste is placed. IV.C.4 

### BulkFeed Tanks (S-1 and S-2) IV.C.4.a 

### Hazardous solid wastes delivered to the bulk feed tanks mustbe placed within the storage pits based on design factors such as angle ofrepose to prevent overflow. Hazardous wastes that are spilled or tracked inside the enclosure mustbe colJected and stored in thepits ormanaged in accordance with the state-issued permit. IV.C.4.b 

### No hazardous wastes containing free liquids (as defined in 40 CFR §260.10) ortreated with free liquids maybe stored in Tanks S-1 or S-2. The presence offree liquids is determined bythe paint filter test (40 CFR § 

### 264.314, SW-846 Method 90958), a visual examination, or other appropriate means. IV.C.4.c 

### The tanks must be located inside an enclosure and vented to a control

VES016702OHD 980 613 541 

### Page 20 of 28 device (the incinerator and/or carlxm adsorption system) 

### meeting the requirements of40 CPR Part 61, Subpart PP- National Emission Standards for Benzene Waste Operations for a facility at which the total annual benzene quantity from the facility waste is equal to or greaterthan I

### 0 megagrams peryear, as specified in 40 CPR § 

### 264.1 082(c)(5). The enclosure and control devices must have been installed and commenced operating before November25, 1996. IV

### .C.4.d The enclosure mustbe designed and operated in 

### accordance with the criteria for apetmanent total enclosure as specified in " 

### Procedure T- Criteria for and verification ofa Permanent orTemporary Total Enclosure" under 40 CPR § 

### 52.741, Appendix B. 

### (40 CFR § 

### 264.!082(c)(5)) IV.C.4.e You must perform the verification procedure for the enclosure as specified in Section 5.0 to "Procedure T- Criteria for and Verification ofa Permanent orTemporary Total Enclosure" annually. IV.C.4.f You mustmeetthe requirements of40 CFR §§ 

### 264.1088 through I

### 090 for Tanks S-1 and S-2. IV.C.SLaboratoryWaste Tank (L-1) 

### IV.C.S.a The following waste shall not be placed in the 1,000-gallon laboratory tank (Tank L-1 ): Hazardous waste with an average VO concentration atthepoint ofwaste generation equal orgreater than 500 ppmw. The average VO concentration shall be determined using the procedures specified in 

### 40 CFR § 

### 264.1 083(a). IV.C.S.b You must review and npdate, as necessary, tlris determination at least once every 12 months following the initial determination for the hazardous waste entering this tank. IV.C.S.c Yon must meet the requirements ofCondition IV.F ofthis permit. IV.D CONTAINERS IV.D.l Requirements for Levell Container Standards Except as specified in Conditions IV.D.2 and IV.D.4 below, you must manage hazardous waste placed in containers having a design capacity greater than 0.1 m3 

### in accordance with the Container Level I standards, as stipulated under 40 CFR § 

### 264.1 086(c). A level I container must be one ofthe following: IV.D.l.a meets the applicable U.S. Department ofTransportation (DOT) regulations as specified in 

### 40 CFR § 

### 264.1 086{1),.



### VES016703OHD 980 613 541 Page 21 of 28 IV.D.l.b 

### be equipped with a cover and closure devices With an acceptable tightness and construction materials in accordance with 40 CFR § 264.!086(c)(l)(ii), or IVD.l.c be an open-top container with organic vapor suppressing barrier to prevent hazardous waste from being exposed to the atmosphere as specified in 40 CFR § 264.!086(c)(l)(iii).

Containers that do not meet the DOT regolations as specified in 40 CFR § 264.1086(£) mustbe equipped with covers and closure devices suitable for the physical and chemical characteristics ofhazardous waste in contalners, for malntaining container integritythroughout the life ofthe container, and for the environments under which the containers are placed in the storage facility. Any chemical used for vapor suppression must not generate heat and/or fume and must be compatiblewith thehazardous waste 

### in the container. Vapor suppression chemicals must act as an acceptable and stable barrierto the hazardous waste, thus preventingrelease ofVOinto the environment. Thebarrier shall not chemically react to the hazardous waste. (40 CFR § 264.1.086(c)(2)) IV.D.l.d All covers and closure devices must bein the closed positionwhenever hazardous waste is in a container. Openingofa closuredevice or cover is allowed ifit meets thepurposes and operates as provided in 40 CFR § 264.!086(c)(3)(i) through (v). IV.D.l.e You must inspect and repairthe containers and their covers and closure devices in accordance with 40 CFR § 264.1086(c)(4). IV.D.l.f For any container with a capacity of0.46 m3 orgreater that you are managing under the Levell container standards in the Condition !V.D.l and that does not meet the requirements in Condition !V.D.!.a above, you must maintain at the facility a copy oftheprocedure that you used to detennine that the contalner is notmanaging hazardous waste in "lightmaterial service," as defined in 40 CFR §§ 264.1081 and 265.1081. (40 CFR § 264.1086(c)(5)) IV.D.2 Requirements for Level2 Container Standards IV.D.2.a Containers with a design capacity greaterthan 0.46 m3(122 gallons) and in light material service as defined in 40 CFR § 265.1081 must be managed in accordance with Container Level 2 standards as stipulated under 40 CFR 

### §264.1086(d). A Level2 containermust be one ofthe following: (I) meets the applicable U.S. Department ofTransportation (DOT) regulations as specified 

### in 40 CFR § 264.1086(£),



### VES016704OHD 980 613 541 

### Page 22 of 

### 28 (2} 

### operates with no detectable organic emissions as defined in 40 CFR §

### 265.1081 and determined in accordance with the procedure specified in 40 CFR §

### 264.1 086(g), or {3) 

### be vapor tight as demonstrated withln the preceding 12 months by using 40 CFR Part 60, Appendix 

### A, Method 27 in accordance with the procedures specified in 40 CFR § 264.!086(h). (40 CFR § 

### 1086(d)(l)(iii)) IV.D.2.b Transfer ofhazardous waste in orout ofa 

### contaioermust be conducted using an engineered method generally accepted and practicedbythe industry, or its equivalent.method to minimize the release oforganics into the atmosphere. (40 CFR § 

### 264.1086(d)(2)) IV.D.2.c All covers and closure devices must be in closed position whenever hazardous waste is in a container. Opening ofa 

### closure device or cover is allowed ifit meets the purposes and operates as provided in 40 

### CFR § 264.!086(d)(3)(i) through (v). IV.D.2.d You must inspect and repair the containers and their covers and closure devices in accordance with 40 CPR § I 

### 086(d)(4). IV.D.3 

### You mustmeet the applicable requirements of40 

### CFR §§ 

### 264.1088 through 264.1090 for containers described in Conditions IV.D.l and IV.D.2. IV.D.4 

### You are not authorized totreat any hazardous waste in any container whose design capacity is greater than 0.1 m3 

### bywaste stabilization process. IV.E CLOSED-VENT SYSTEM AND 

### CONTROL DEVICES IV.E.I Closed-vent System IV.E.l.a The closed-vent system used to satisfy the requirements ofthis pennit shall meet all the requirements of40 CFR Part 264, Subpart CC that are applicable to closed-vent system, includingbut not limited to 40 CFR § 

### 264.1087(b), and shall consist of: (I) a ventilation header blower, (2) vent piping from the hazardous waste storage tanks and the vaporrecovery ductwork, (3) secondary vent blowers for the carbon adsorption systems, and (4) instrumentation and monitoring system. IV.E.l.b The ventilation headerblower shall have a minimum capacity of34,500 cubic feet per minute (CFM) at 9"static pressure. IV.E.l.c Each secondary vent blower shall have a minimum capacity of9,775 CFM at 22" static pressure. IV.E.l.d The closed-vent ductwork must be fabricated in accordance with the



## ..

VES016705OHD 980 613 541 Page 23 of 28**standard~** <lfSMACNA (SheetMetal and AirConditioning Contractors' National Association, Inc.), American Society ofHeating, Refrigeration, and Air Conditioning Engineers (ASHRAE), orequivalent. Flexiblehoses/connectors of adequate strength are allowed for making connection to equipment. IV.E.l.e For a closed-vent operating at a negative pressure (i.e., suction ductwork ofthe ventilationheaderblower), a pressure measurement devicemust be installed in each closed-vent ductwork at an accessible location to verify that a negative pressure is beingmaintained when the control device is operating. N.E.l.f For a closed-vent operating under positive pressure (i.e., discharge ductwork ofthe ventilation header blower, including the ductworkbetween the carbon adsorption system to the stack), the closed-vent system shall operate with no detectable emissions, as indicated by an instrument reading ofless than 500 ppmv above background as determinedbythe procedure in 40 CPR§ 264.!034(b), and by visual inspections. 

### N.E.l.g The combustible concentrations in the vent streams mustbe maintained at less than 60% ofthe Lower Explosion Limit (LEL) ofthe vent stream to prevent fire and/orexplosion. 

### N.E.l.h You must monitor and inspect each closed-vent system in accordance with 40 CPR§ 264.1033(1). IV.E.l.i Youmust prepare and maintain records for the closed-vent system as specified in40 CPR§ 264.1089 and shall make reports as specified in 40 CPR § 264.1090. IV.E.l.j You must operatethe closed-vent system in accordance with40 CPR § 264.1087(c)(2)(vi). IV.E.2 Operations ofVentilation Header Blower and Secondary Vent Blowers IV.E.2.a The ventilationheaderblower shall deliver the vent streams from each emissionpoint to the carbon adsorption systems and/or the rotarykilnprimary combustion air fan inlet plenum. IV.E.2.b Flow control valves, pressure indicating controllers, temperature elements and alarms, vent stream analyzer must be incorporated into the operations ofthe blowers. · IV.E.2.c Electrical interlockings must beprovided to preventpotential fire and/or explosion due to high temperature and/or VO concentrations within the closed-vent system.



### VES016706

### IV.E.3 Control Devices OHD 980 613 541 Page 24 of 28



### IV.E.3.a The control devices used to meet the requirements ofthis permit shall include: (I) a carbon adsorption system (Modules A & B), and (2) the rotarykiln

. combustion system. Therotary 

### kiln combustion system shall complywith the requirements of 40 CPR § 264.I087( c), as applicableto enclosed combustion devices. 

### IV.E.3.b The carbon adsorption system shall consist of2 modules (Module A and B). Each module shall have 2 carbon boxes connected in series. Each carbon box shall have a face area ofI86 square feet and be designed for a maximum flow of I2,500 CFM. 

### IV.E.3.c Each carbon box shall contain approximately 12,500 pounds ofgranular activated carbon or425 cubic feet in volume. Each carbonbox shall be designed and operated to reducebyat least 95 %byweightthe total volatile organic concentration ofthe inletvent stream to thecarbon adsorption system. Each carbon adsorption module must meet therequirements of40 CPR § 264.1087(c), as applicableto carbon adsorption systems. Prior to placing a carbon box back in service after the spent carbonhas been removed, the Permittee shall ensure the carbon box contains fresh carbon in the quantity orvolume identified in this Condition. IV.E.3.d Design ofthe carbon box shall be epoxy coated steel and gas-tight construction, or equivalent, capable ofwithstanding an air pressure of22" water column. All flexible connections for the carbon boxes mustbe designed and operated under air-tight condition based on the maximtun workingpressure ofthe vent streams inside the carbon box. IV.E.3.e The activated carbon box used in the carbon adsorption systems shall have a minimum temperaturerating of 150 °F. Theminimum pressure rating for the carbonbox shall be 0.5 psig without causing structural damages. IV.E.3.f Each carbon adsorption system must bemonitored on a continuous basis byuse ofa continuous emission monitor system, as specified in Paragraph 17 through 19 ofthe Consent Decree between U.S. EPA and Von Roll America in U.S. 

### v. VonRoll America. Inc., No. 4:06CV2893 (N.D. Ohio), effective February 2, 2007 ("Consent Decree"); whichparagraphs are incorporated herein byreference. The existing carbon must be replaced with fresh carbon immediately when carbon breakthrough is indicated, as specified in Paragraphs 21 through 22 ofthe Consent Decree; which paragraphs are incorporated herein byreference. Carbon breakthrough is indicated as described in Paragraph 18 and 22 ofthe Consent Decree and is summarized as follows: (I) Breakthrough ofcarbonbetween ·each primary and secondary carbon



### VES016707OHD 980 613 541 Page 25 of 28 box is deemed to occur whenever Inter-Box Continuous Emission Monitor (CEMS) data equal to or greaterthan 50 ppmtotal hydrocarbons (THC) on a 60-minute rolling average occurs. (2) Wheneverbreakthrough between a primaryand a secondarycarbon box occurs, you must change out theprimarybox within the 12 hour and 48 hour time limitations set forth in the applicable paragraphs ofthe current ormost recent version ofthe Routine Maintenance Procedure that became effective under the terms of the Consent Decree; which paragraphs are incorporated herein by reference. Ifwithin I 5 days afterhaving completed a change-out ofa primary box, you experience an Inter-Box CEMS reading equal to or greater than 50ppm THC on a 60-minute rolling average on the train that has been changed out, you are not required immediatelyto initiate and complete a new change-out ofthe primary box. Instead, as expeditiously as possible, you must initiate and complete an investigation ofthe cause(s) ofthe elevated Inter-Box CEMS reading to determine ifthe carbon within the primarybox actually is spent or otherwise not functional and take the actions specified in Paragraph 22 ofthe Consent Decree, as incorporated hereinbyReference. 

### IV.E.3.g For each Module, a flow meter/transmitter at the inlet ductwork to the carbon adsorption box and an inter-box Continuous Emission Monitors for total hydrocarbons must beused to continuouslymonitor and record the flow rate and the THC concentration. 

### IV.E.3.h The performance specifications for the THC Continuous Emission Monitoring system shall be 

### as stipulated in paragraphs 33 and 34 ofthe Consent Decree which are incorporated hereinby reference. 

### IV.E.3.i You must maintain a copy ofthe activated carbon specifications in the operatingfile. When you decide to change the supplier ofthe carbon, the new carbon's physical and chemical characteristics must be comparable or equal to the current activated carbon which has been tested. 

### IV.E.3.j All spent carbons mustbehandled, disposed of, orregenerated as hazardous waste. 

### IV.E.3.k Recordkeeping ofthe control devices shall bein accordance with 40 CFR § 264.1089.



### VES016708OHD 980 613 541 

### Page 26 of 28 IV.E.4 Disposal ofSpent Carbons IV.E.4.a On-Site Disposal (1) 

### The Pennittee may dispose ofthe spent carbon removed from the carbon box modules by transferring the carbon box and dumping the spent carbon into the solid waste feed tank(s) S-1 or S-2. The bulk feed tanks must meet the requirements of National Fire Protection Association (NFPA) Codes. (2) 

### Ifa vacuum truck is utilized, the exhaust from the vacuum blower shall be treated bya mechanical cyclone with a dust filter, or an equivalent device, having a total dust removal efficiency of85 %based on ASTM, National Bureau Staodards Atmospheric Dust Test Method, ASHRAE Method, or an approved method. (3) 

### The area utilized for mechanical removal ofspent carbon shall be so designated and designed to preventrun offfrom the spills ofspent carbon. The Pennittee may propose an alternative.method equivalent to those described above. (4) 

### The Permittee maypropose an alternative method equivalent to those described above, subject to the approval ofU.S. EPA. IV.E.4.b Off-Site Regeneration/Disposal ofSpent Carbons 

### The Pennittee maydispose ofor regenerate the spent carbons off-site as hazanlous waste in accordance with the provisions of40 CFR § 

### 264.1 033(n) and all federal and stateregulations relating to transportation, regeneration, or disposal of hazardous waste. IV.E.4.c 

### The Permittee shall document that all carbon removed from the carbon adsorption system is managed in accordance with either Condition IV.E.4.a or IV.E.4.b above. The Pennittee shall retain such documentation in the facility' operating record for a minimum of3 years. IV.E.S Compliance with the ConsentDecree



### ' The Pennittee must comply with the tenns and conditions stipulated in the final Consent Decree between the United States and Von Roll America, Inc. in U.S. vs. Von Roll America. Inc., No.4:06CV2893(N.D. Ohio), which became effective on February 2, 2007. After the Conseot Decree is tenninated, the Permittee may submit a Class 1permit modification request to deletethis Condition. IV.F 

### TANKS AND CONTAINERS EXEMPT UNDER 40 CFR §264.1082(c)(l) FROM THE STANDARDS lN 40 CFR §§ 264.1084 THROUGH 264.1087 

### IV.F.l Under this penni!, for each container or tank you claim to be exempt under 40 CFR

VES016709OHD 980 613 541 Page 27 of 28 § 264.1082(c)(l), you mustdemonstrate bydirectmeasurementor approved method that the average VO concentration for all hazardous waste entering the container or tank has an average VO concentration, as determined in accordance with 40 CFR §§ 264.1083(a) and 265.1084(a)(2) through (a)(4), is less than 500 ppmw at the point oforigination. IV.F.2 For each such tank or container, you must review and update the determination in Condition IV.F.l in accordance with 40 CFR § 264.1082(c)(1) at least once every 12 months following the date ofthe initial determination.

IV.F.3 For each such tank or container, you are subject to the requirements of40 CFR § 264.1082(d) and you must satisfY the applicable requirements of40 CPR §§ 264.1088 through 264.1090. IV.G INSPECTION, RECORDKEEPING AND REPORTING REQUIREMENTS ThePermittee shall complywith 

### all applicable inspection, recordkeeping and reporting requirements described in40 CPR §§ 264.1088, 264.1089 and 264.1090.

SECTION V --AIREMISSION STANDARDS FORMISCELLANEOUS UNITS UNDER 40 CFRPART 264, SUBPARTX V.A GENERAL The following SubpartX units 

### are permitted under the State ofOhio Environmental Protection Agency's permit. These units, ifinstalled and operated, are regulated under 40

.CPR Part 264, Subparts 

### X, BB, and CC. V.A.l 

### Drum Extruder (2 units) V.A.2 Pusher(1 unit) V.A.3 Filter Presses (2 units) V.A.4 Shredders (4 units) You must not place hazardous waste in any unit described 

### in Conditions V.A.I through V.A.4 other than the Drum Extruder Pu!perUnit described in Condition V.B. below unless you first request and receive a modification to this permit to incorporate the requirements of40 CFR Part 264, Subparts BB and CCthat are appropriate for such unit, as required by 40 CFR 

### § 264.601. 

### V.B DrumExtruder Pulper Unit V.B.l The drum extruderpulperunit consists of(I) a loading chamber, (2) a process chamber for extrusion and crushing ofdrums, (3) a crushed 

### drum discharging chute



### VES016710OHD 980 613 541 Page 28 of 28 with double airlocks, and (4) a wastepulpingtank with a mechanical pulper. All components shall be designed and operated as a unit. V.B.2 The process chamber (extruder/crusher) unit shall be provided with a nitrogen blanket and vented through a closed-vent system that meets the requirements of Conditions IV.E.l and JV.E.2 ofthis permit to a control device(s) that meets the requirements ofConditions IV.E.3 through IV.E.5 ofthis permit. The Permittee must ensure that there is no leak to the atmosphere when the unit is operating under a positivepressure. V.B.3 The drum to beprocessed shall enter the seal chamber and moveto the processing chamber after the seal chamber door is positively closed. The crushed drums shall be discharged through a discharging chute equipped with double airlocks (i.e., knife gate valves). V.B.4 Theprocessing chamber and thepulping tank shall beprovided with nitrogen to reduce the oxygen concentration in the chamber at orbelow 5 %. Oxygen sensors, or equivalent monitoring equipment, must be operated and maintained. V.B.5 Temperature and liquid level in the pulping tank must be continuouslymonitored. Whenhigh liquid level is detectedin the blending tank, operations ofthe extruder/ crusherunit shall stop. V.B.6 The drum extruderpulperunit must meet all applicable industrial safety standards. V.B.7 Youmust inspect and monitor the extruderpulper unit in accordance with 40 CFR §§ 264.602 and 264.1088. V.B.8 Recordkeeping ofthe extruderpulperunit shall be in accordance with 40 CFR § 264.1089.



### VE5016711