.,_ ... 

)t ~Ill~ 

Fic>ss Incineration SeNices. Inc. 

Hazardous Waste lnstallaUon & Operation Pennlt Renewal 

Page 30 of 101 

Additionally, the Permittee has three surface impoundments that were 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 Chapter 37 45-66 but, for various 

reasons, have not yet achieved final closure. The purpose of this condition is to put 

the Permittee on schedule to complete closure of these units. 

Surface 

Impoundment 2 

orSWI2; 

Surface 

lmpoundm.ent 6 

orSWI6;and 

Surface 

Impoundment 7 

orSWI7 

SCIUbber water and 

sCIUbber water sludge 

composed primarily of 

incinerator ash 

A Closure Plan to close SWI6 arid SW17 with waste """';'""" u 

and oonsoidale the waste and unit liner from SWI2 in 

was received by Ohio EPA on 9/7/2000. On 11120/2000, Ohio 

EPA issued a NoUce of Deficiency (NOD) on this Closure 

Plan. The NOD response leiter dated 111212001 requested 

additional meeUnss With Ohio EPA and proposed a sequential 

response to the NOD with Ohio EPA approval olintennedlate 

plan elements. A TreatabUity 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 

accordance with the approved closure plan revisions located in Section I of the 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 1-39 through 1-46. 

Upon completion of Ohio EPA's review of the proposed changes to the Permittee's financial 

assurance obligations, proposed revisions to the Permittee's financial 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). 

VES016600 
Ross lnclneraUon SeNicea, Inc. 

Hazardous Waste Installation & Operation Permit Renewal 

Pa9e 31 of 101 

8.29 Content of C!o§ure Plan , 

OAC Rule 3745-55-12 

The Permittee shall maintain the closure plan at the facility which contains the 

elements set forth In OAC Rule 3745-55-12 and all elements required by the terms 

and conditions of this permit. 

B.30 Notification of Closure 

OAC Rule 3745-55-12 

The Permittee shall notify the Director In writing at least 45 days prior to the date on 

which he expects to begin final closure of a facility as required by OAC Rule 37 45-

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, or treat or dispose of on-site, all hamrdous 

waste In accordance with the approved closure plan. The Director may 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 37 45-55-14, 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 

. --------------

VES016601 
Ross 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 engineer shall 

certify that each hazardous waste management un~ or the facility has been closed 

in accordance with the specifications in the approved closure plan and the terms and 

conditions of this permit, as required by OAC Rule 37 45-55-15. 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 later than the submission of certification of closure of each unit that 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 Permittee must begin post-closure care for surface impo!Jndment SWI-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 Request dated March 1, 2004 and amended by 

a supplemental response dated June21, 2004). The approved Post-Closure 

Plan does not include •p;-ase "ajcording to a 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 

VES016602 
Ross 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 later than 60 days after certification of closure of each hazardous 

waste disposal unit, the Permittee must submit to the director and the 

local zoning authority records of the 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 of certification of-the last unit that 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 of the document in 

which the Permittee placed the notation. 

VES016603 
Ross Incineration ServicBB, Inc. 

Hazardous Waste lnotallallon & OpetaUon Penntt Renewal 

?ago 34 of 101 

(3) The Permittee -request and obtain a permit modification 

prior to post-closure rem011al of hazardous wastes, hazardous 

waste residues, liners, or contaminated sons, in accordance 

With OAC Rule 3745-55-19(C). 

(e) Certification of Completion of PostcCJosure Care 

established post-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 37 45-55-

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 of the 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 of the establishment of 

the financial instrument(s) used to comply with OAC Rule 3745-55-43 and 

37 45-55-45 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 

VES016604 
Ross Incineration Services, Inc. 

Haardoua Waste Installation & Operation Permit Rene_wal 

Page 35 of 101 

B.37 financial Assurance for facility Closure and post-Closure 

the facility the latest 

req~1ired by OAC 

The Permitteeli'Dmaintain continuous compliance with OAC Rule 3745-55-43 and 

maintain continuous compliance With OAC Rule 55-45 or55-46. 

iilllrProvide documentation of financial assurance, which meets the requirements 

of OAC Rule 3745-55-51, in at least the amount of the cost estimates required by 

Permit Condition 8.36. 

8.36 Liability Requirements 

The Permittee shall maintain continuous eompllance with the requirement of OAC 

Rule 37 45;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 compliance with OAC Rule 37 45-55-47(8) by 

maintaining liability coverage for non-sudden accidental occurrences in the amount 

of at least $3 million per occurrence, with an annual aggregate of atleast $6 million, 

exclusive of legal defense costs. 

B.39 lncapacitv of owners or Operators. Guarantors. or Financjallnstitutions 

OAC Rule 3745-55-46 

The Permittee shall comply with requirements set forth in OAC Rule 37 45-55-48 

regarding the incapacitY of owners, operators, guarantors or financial institutions. 

OHIO EPADHWM 

. MAR 0 2 2005 

VES016605 
Rooa 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 37 45-270 and as set forth 

in Seatlon C of the Part B permit application. 

·. 

' 

OHIO EPADHWM 

Sttl 3 0 2003 

------------------· 

VE5016606 
Ross lncinerstion Services, lnc. 

Hazardous Waste Installation & Operation Permit Renewal 

Page 37 of 1 01 

OHIO E!'ll DIMM 

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 hazardous waste without free liquids in roll-offs and other containers. It can 

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 of oxidizer 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 by 60 feet that is used forstorage of containers of wastes from off -site 

generators and certain on-site generated wastes. Containers stored in the Container Storage 

Facility include various types of steel, plastic and composite drums, pails, buckets and boxes 

as well as bulk containers such as roll-offs and truck tankers. Containers with and without free 

liquids may be stored in the Container Storage Facility. The Container Storage Facility has 

adequate secondary containment. 

T)'pical hazardous waste types received at the facility in containers include: halogenated and 

non-halogenated spent solvents, paint wastes, off-specification commercial chemical products 

and spill residues. Waste generated at the facility and stored in containers consists primarily 

of treatment residuals from the incineration process. 

The Container Storage Facility includes 18 separate 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 truck tankers, 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 carry waste codes that the facility is permitted to store, but not to incinerate. 

Containers of hazardous waste may be repackaged at designated locations within the facility 

into alternate containers to facilitate management of the waste. Liquid wastes received in 

tanker trucks may be transferred to tankers operated by the facility (i.e., yard tankers) for direct 

feeding from a tanker into the incinerator. 

VES016601 
Ross Incineration Services, Inc. 

Hazardous Waste Installation & Operation Pennil Renewal 

Page 38 of 101 

C.1 Process CapacitviAnnual Quantity Limitation 

OAC Rules 37 45-50-43(A)(7) 

OHIO EPA DHWM 

NOV 16 2.1107 

(a) The Permittee shall not store more than 457,031 gallons of containerized 

waste at any given time in the permitted container areas (Container Storage 

Facility, Bulk Storage Area, and Oxidizer Storage Building). At no time 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 apply to 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 37 45-52-34(A), the Permittee shall not, 

for the total amount of hazardous waste stored and accumulated, exceed the 

maximum container storage inventory established under this Condition. 

(d) The Permittee shall not treat wastes in containers, except by processing in 

the incineration unit. 

(e) The Permittee may receive and store wastes in containers without intending 

to treat said wastes. The Permittee may ship these wastes to another 

permitted facility for treatment, storage or disposal. The Permittee will handle 

said wastes in accordance with the practices and procedures in Sections C 

and D of the 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 of the Part B permit application. The Permittee 

is prohibited from storing wastes in containers inconsistent with the restrictions and 

prohibitions in Table CH of Section C of the Part B permit application. '· 

VES016608 
Ross lncileration Services, Inc. 

Hazardous Waste Installation & Operation Perm~ Renewal 

Page 39of 101 

C .3 Condition of Containers 

OAC Rule 3745-55-71 

If a container 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 of Waste 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 container storage shall be conducted within the container storage units as 

described in Condition C.1. of this permit and Section D of the Part B permit 

application. 

The Permittee shall keep all containers closed during storage, except When 

it is necessary to add or remove waste, and. shall not .open, handle, or .store 

containers in a manner which may rupture the container or cause it to leak. 

Lab-pack wastes received at the facility shall be handled in compliance with 

applicable storage requirements and Sections C and D of the Part B permit 

application. 

The Permittee shall conduct the following container management activities 

in accordance with the procedures and practices specified in Section D of the 

Part B permit application: container storage and receiving, repackaging of 

wastes, transportation of wastes through the facility and special handling of 

containers. Repackaging of wastes 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 of the old process dock; 

OHIOEPADHWM 

ww 16 ZOG7 

(iii} Concrete pads east or west of the process dock; 

(iv} Concrete pad at the staging areas In the Container Storage Facility; 

(v) The concrete loading/unloading area by the closed loop scrubber water 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 of the 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 percent of the total 

volume of the containers or the volume of the 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 D of the Part B permit 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 inspect the 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 other factors. The Permittee shall note the results of these 

inspections in the inspection log along with any remedial action taken in accordance with the 

procedures contained in Section F of the Part B permit application. Each container in storage 

for six months or more 

VES016611 
Ross Incineration Services, Inc. 

OHIO EPA DHWM 

Hazardous Waste ~m" , (\ zaa1 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 comply with all recordkeeping requirements of OAC Rule 3745-

54-73 as part of the facility operating record and any other 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} of the facility's property line . 

. (b) The Permittee shall take precautions to prevent accidental ignition or 

reaction of ignitable or reactive waste and shall folloW the 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 not store incompatible waste except in accordance with 

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 of the Part B permit application. 

C.12 Reserved. 

VES01661 
Ross 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 of the Part B permit application. 

(b) If the Permittee demonstrates that all contaminated soils cannot be 

practically removed or decontaminated in accordance with the Closure Plan 

in Section. I of the Part B permit 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 

storage tanks and 4 tanks that are both storage and treatment tanks. All tanks are 

above-ground tanks. All of the tanks have been provided with a secondary 

containment system constructed of a reinforced concrete liner external to the tanks 

and a reinforced concrete retaining wall around the perimeter. All containment 

systems have an impermeable coating \O make the secondary containment system 

Impervious to the waste stored. The sec;ondary containment system for all tanks 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 of the off-site generated 

wastes managed in these tanks are transferred from tank trucks, but some wastes 

are transferred from containers into tank storage. Wastes managed in these tanks 

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 treatment tank treats residuals from the incineration process Including fly ash, 

sludges and scrubber water. Three treatment tanks are part of the vacuum pump 

system for transferring wastes, including high and/or low BTU wastes, halogenated, 

flammable and/or ignitable wastes, from drums, tank trucks and other contai.ners to 

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 a total 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 4 tanks, subject to the terms of this Permit and as follows: 

', 

' 

OHIO EPA OHWM 

S£tl 3 0 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' ~-~i'-"-'-..l._ ·~ ~~~ j - Dl::iil;.: Jilt::W~.tS ~ ( . '"( " lt _: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 lroatmenl 

tankCondenaation 

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 ·In place 

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 or low 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 

(New tanks 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 lank for 

OACChepter 

3745-55) 

OHIO El'P. OHWM 

Str 3 0 Z003 

........ 

VES01661 
Roaa lnclnera1lon Services, Inc. 

Hazardous Waste Installation & Operation Permit 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 ·In place High and/or low December, 

Hozardous gallons for 10.5 fl. Bl\J-. 1g87 

-storage· atarage; . halogllllllWd, (Now lllnka tor 

andb'aalment (Combined ftammable OACChepter 

lanka-Vac:uwn llaalmont end/or lgnitabla 3745-66) 

Tanka ·capaclly a! 

-70,73 

and741a 

-

72,000 gallons 

""r day.) · .. 

Tank79 58,<102 gallons 20ft. (dlam) x 24 Y oa ·In place Fly 8lh sludge, 1988 

Hazardous for storage; . fl. aaubberwater, (New1anktor 

waste 111l>raga (Traalment and/or sludge OACChap!Br 

and lraatmant capadtyla genaraladcn- 3745-55) 

tank- Surge 50,000 ~;"'" site for= ltank · ,.,. dav. treatment 

. 

(b) The Permittee shall store in tanks only the hazardous waste codes specified 

in Section A of the Part B application with process code S02. The Permittee 

shall treat In tanks only the hazardous waste codes specified In Section A of 

the Part B permit application with process code T01. 

(c) The Permittee ls prohibited from storing or treating in tanks haZardous waste 

that is not identified in this permit condition. The Permittee Is prohibited from 

any storage or treatment of wastes in tanks inconsistent with the restrictions 

and prohibitions In Table C1-1 of Section C of the Part B permit application. 

The Permittee shall not store characteristically corrosive wastes or wastes 

with a corrosion rate greater than 50 mUs per year in tanks. 

0.2 Desian and Installation of New Tank Svstems or Components 

OAC Rule 3745-55-92 

(a) The Permittee shall construct any future new tank systems in accordance 

with Section D-2c of the Part B permit application. 

(b) Prior to the operation of any newly constructed tank system, the Permittee 

shall submit to Ohio EPA the certification of installation of the tank system 

in accordance with OAC Rule 3745-55-92(8) to ensure that proper handling 

procedures were adhered to in order to prevent damage to the system ·during · 

installation. , 

. ' •, 

OHIO.EPADHWM 

Sl:.r 3 o 2003 · 

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VES01661 
Ross 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) New Tank 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 of the Part B permit application. 

New tanks at the 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'dance with the requirements of OAC Rule 37 45-55·93{8) through (F), 

the detailed design plans and descriptions contained in the Part B permit 

application and Sections D and F of the Part B application. 

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 not place hazardous wastes or treatment 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 comply with 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 all tank systems listed in Condition 

D .1 in accordance with the procedures, practices and design conditions 

Identified in Section 0 of the Part B permit application. 

'· ' 

OHIO EPAOHWM 

S[r a o zo03 

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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 of the Part B permit application and shall 

complete the items in permit Conditions 0.5(b) and 0.5(c) as part of those 

inspections. 

(b) The Permittee shall inspect the overfill controls In accordance with the 

procedure and schedule in the 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 of the tank system, if any, to detect corrosion 

·. or releases of waste; · 

Data gathered from monitoring and leak detection equipment (e.g~. 

pressure or temperature gauges,monitoring wells) to ensure that the 

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 

secondary containment system, to detect erosion or signs 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 of the facility . 

. (e) The Permittee shall monitor and testthe tank systems in accordance with the 

Tank Corrosion Inspection Plan in Appendix 0-1 of Section D of the 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 of the tank. The applicable design minimum wall thickness for the 

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 for the upper portion of the 

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 of the release. 

(li) ·If the release was from the tank system, the owner/operator must, 

within twenty-four hours after detection of the leak, or, if the 

.. ·-·-·--· ·---·- - ------------ -----------·- --··--

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Rooa Incineration SON!cot, Inc. 

Hazardou• WubllnataUatlon & Opllfllllon Penn~ Renewal 

Paga49 of 101 ·. 

owner/operator demonstrates that It is not possible, at the earliest 

practicable time,· remove as much of the waste as is necessary to . prevent further release of hazardous waste to the environment and to · allow inspection and repair of the tank system to be performed. 

If the material released,was to a secondary containment system, all 

released materials must be removed within twenty-four hours or In as 

timely a manner as possible to prevent harm to 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 of the 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 37 45-55-97 and its Closure Plan if there has been a leak or spiff 

from the tank system, from a secondary containment system or if a system 

becomes unfit for continued use. 

·(I) For a release caused by a spill that has not damaged 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 leak from the primary tank system to the 

secondary containment system, the Permittee shaH repair the 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 be visually inspected, the Permittee shall repair 

the tank system before returning It to service. 

(IV) If the Permittee replaces a component of the tank system to eliminate 

the leak, that component must satisfy the requirements for new tank 

systems or components in OAC Rules 3745-55-92 and 3745-55-93. 

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OHIO Ef>ADHWM 

Sl:.t' 3 0 2003 

VES01661 
RosslnclnetaUon 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 of the 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 of detection, when 

a leak or spill occurs from the tank system or secondary containment system 

to the. environment. (A .leak or spill of one pound or less of hazardous waste, 

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 of migration 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. If the Pennittee finds it will be impossible to meet this 

time period, the Pennittee should provide the Director with a schedule 

of when 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 of response actions taken or planned. 

•. 

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Ross 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 

of the 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 of the Part B pennit application. 

(b) If during closure of any tank system, the Permittee concludes that not all 

contaminated soils can be practicelly removed or decontaminated In 

accordance with the Closure Plan, the Permittee shall submit a written 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) Ilia Permittee 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 37 45-50-11. 

(c) The Permittee shall follow the 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 EPA DHWM .. 

SE~ 3 0 Z003 

VES01662 
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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 

Incompatible wastes and materials, in the same tank system. The tanks will 

be emptied and thoroughly rinsed and visually inspected before wastes that 

are incompatible with the previous contents of the tanks 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 not place hazardous waste in a tank system that has not 

been decontaminated and that previously held an Incompatible waste or 

material unless the requirements of permit Condition 0.1 O(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 of the 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 of the 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 the date of the it iSpeetion. 

VES01662 
-- Ross Incineration Servlcos, Inc. 

Hazanloua Waatelnatalla1lon & 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 at which 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, or other waste (as those terms are 

defined in ORC Chapter 6111 ), has been, placed at any time, irrespective of whether 

the unit was Intended for the management of waste or hazardous 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 any waste management units (WMUs) at the Facility, regardless 

of the time.atwhlch waste was placed in such units. 

E.2 Correct!ye Ac!ion Bevond the Facilitv Boundarv 

OAC Rules 37 45-55-011 

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 is denied. On-site measures to address such releases will be 

addressed under the RFI, CMS, and CMI phases, as determined to be necessary 

on a case-by-case basis, 

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OHIO EPA DHWM 

S!:.P 3 0 2003 

VES01662 
Rosa Incineration Setvloes, Inc. 

Hazardous Waste lnstaRaUon & Operation Pennft Renewal 

Page 54 ot 101 · 

E.3 Jgent!ficatlon of WMVs · 

. OAC Rules.37 45-50-44(d) & 3745-55-011 

USEPA prepared an RFA (RCRA Facility Assessment) report for the Permittee's 

faciUty dated July 21, 1987. The RFA identified potential releases and potential 

release pathways including groundwater, soils, surface water and air. Based on the 

results of the RFA. the Permittee was required to implement anRFI. Consequently 

a Corrective Action Program requirement was added to SecUon VI of the U.S. EPA 

RCRA Part B Permit issued to the Permittee on September 8, 1988. 

The Permittee began Implementation of the RFI by preparing the Facility 

Background Report that was 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 of ownership, facility 

operation, a. site descript!on, a summmy of solid waste management units (SWMU) 

and the volume and types of wastes handled, and a chronology of the waste 

management practices that have been conducted throughout the life of the facility. 

The environmental setting provided an initial description of the hydrogeological, 

geological and meteorological characteristics of the 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 of operation and an abbreviated list 

of wastes managed in the urilt, is provided In Table J3-1 of Section J of the Part B 

permit application. Detailed SWMU descriptions are found In the Permittee's 

Facility Background Report, Section 2.4 "Chronology of Known Waste Management 

Practices" (Pages 2c 18 through 2-42). Past waste management practice areas are 

represented spatially in Figure J..1 In Section J of the Part B permit application. 

E.4 Reserve!f. 

E.5 · BEl . OAC Rule 3745-55-011 

The PeflYlittee began implementation of the RFI required by Section VI, of the U.S. 

EPA RCRA Part B Permit issued to the Permittee on September 8• 1988 by 

OHIO EPADHWM 

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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 

multimedia sampling and analytical data collected in and around SWMUs from 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 of multimedia 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 of the 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 of the RFI. Characterization under the 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 

water bodies, further analysis of groundwater characteristics, groundwater modeling 

and an assessment of human health and ecological risk. The Permittee conducted 

the activities identified in the November 3, 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 have worked with the Permittee since 1997 to define the 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 a letter dated March 30,2004, Ohio EPA stated: "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 of the 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 a quarterly basis. Upon completion 

ofthe Phase Ill work, Permittee will prepare a revised RFI Report, which is expected 

. to be the Final RFI Report, and submititto Ohio EPA in accordance with the revised 

Phas!!!.tl( Work Plan S¢hedUI!!! {Augvst7, 2004). 

The Permittee must conduct 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 

major tasks 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 US EPA prior to the effective date of this permit, or for newly 

Identified waste managements units identified in Condition E.1 0, in the RFI section 

of the 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 accordance with workplans submitted and approved under U.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 of a 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 EPA will approve or modify and approve, in writing, the amended 

or new RFI Workplan. The RFI Workplan, as approved or as 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. 

VES01662 
Ross Incineration Services, inc. 

Haz.ardous Waste Installation & Operation Permlt Renewal 

Page 57 o!101 

(b) RFIImplementation 

The Permittee must implement the RFI Workplan according to the terms and 

schedule in the approved RFI Workplan. 

The Permittee shall implement any RFI Workplan approved pursuant to 

Condition E.5(a) according to the 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 

to the terms and schedule iri the approved RFi Workplan Addenda dated July 

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

of Section J of the permit application. 

For any 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 of the RFI. 

The Final Report for the work completed pursuant to the RFI Workplan 

approved by U.S. EPA and for work completed 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 of the 

RFI. The RFI Final Report shall describe the procedures, methods, and · 

results of the 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 of receipt of Ohio EPA's comments, the Permittee shall . 

submit either an amended or new RFI Report that incorporates Ohio 

EPA's comments. 

VES01662 
, .... ,. 

-- Rcaa Incineration SeMces. Inc. 

Haurdoua Waste lnalallat!on & Operallon Ponnll Renewal 

Page 58 of 101 

' (iiQ Ohio EPA shall approve or modify and approve, In writing, the amended or 

new RFI Report. The RFI Report, as approved or as modified and approved, 

, shall be incorporated into this permit and become an enforceable condition 

of this 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 to the !!nvlronment, Ohio EPA may require (or the 

Permittee may propose) the developme,nt and Implementation of an 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 a time frame established by Ohio EPA. 

E.7 Peterrnina!IOn of No Furtber Action 

{a) Permit Modification 

Based on the results of the completed RFI and other relevant information, 

the Permittee may submit an application to Ohio EPA for a permit 

modification under OAC Rule 37 45-50-51 to terminate the Corrective Action 

, tasks that the Permittee is obligated by this permit to complete. This permit 

modification application must conclusively demonstrate that there are no 

releases of hazardous waste or constituents from WMUs at the Facility tllat 

pose an unacceptable risk to human health and the environment. 

If,, based upon review of the Permittee's request for a permit 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 EPA will 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. 

' ' 

OHIO EPA DliJII-'1 

, St.r 3 0 Z003 

VES01662 
Rosa 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 at a later date, if new 

information or subsequent analysis Indicates that a release or potential 

release from a WMU at the 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 of the permit to 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 EPA approval 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 or as 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 EPA within 90 

days from the notification by Ohio EPA of the requirementtoconducta CMS. 

Slrl 3 0 Z003. 

VES01662 
Rcaslnclneratlon SelVIces, Inc. 

Hazan:lous Waste Installation & OperaUon Permit Renewal 

Page eo of 101 

(1) 

(2) 

(3) 

If necessary, 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 CMS Workplan. 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 

changes to the approved CMS Workplan must be 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 after the completion of the 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 an amended 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 or as 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 

VES01663 
Ron lncineraUcn Setvlcas, Inc. 

Hazardous Waste lnslallsllon & OperaUon Pennft Renewal 

Page61 of 101 

E.9 Correc!!ve Measures Implementation lCMD 

The Peonitlee must Implement one or more of the Corrective Measures authorized 

by Ohio EPA. Ohio EPA shall authorize one or more of the Corrective Measures 

In the c.MS Report as approved by Ohio EPA pursuant to Condition E. a (c), and will 

notify the Permittee In writing of the 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. 

If two or more of the Corrective Measures studied meet the threshold 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, mobility orvolume of 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 implement the 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 new WMU identified at the Facfllty:OHIO EPA OHWI 

S£P 3 0 200: 

VES01663 
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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 of unit; 

(Ill) General dimensions and structur;ll description (supply any available 

drawings); 

(iv) When the unit was 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 accordance with timeframes estabHshed by 

Ohio EPA. 

' ' 

OHIOEPAOHWM .. · 

SEt' 3 0 2003 

VES0166~ 
Ross lncineratton Services, Inc. 

Hazardous Waste lnstaUfjotlon & Operation Permit Renewal 

Page 53 of 101 

MODULE F ·TREATMENT IN MISCELLANEOUS UNIT 

F. MODULE HIGHLIGHTS 

The filter press treats scrubber water from the closed loop scrubber water 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 

offsite treatment or disposal facility. The liquid filtrate is recycled back to the closed 

loop scrubber water system. The filter press is located in the Filter Press Building. 

The filter press has a 2.4 cubic yard per batch capacity. Secondary containmentfor 

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 

scrubber water system carrying the hazardous waste codes specified in Section A of 

the Part B permit application under the process codes o!T04 and T03 and lor which 

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. 

Hazardous Waate lnolallaUon & Operatlon.Pormlt Renewal 

Page 64 of 101. 

F.5 Containment System 

OAC Rule 37 45-57-91 

(a) 

(b) 

(c) 

Secondary containment must be designed, installed and operated to prevent 

any migration of waste or accumulated liquid out of the system to soil, 

groundwater or surface water. 

Secondary containment must be capable of detecting and collecting releases 

and accumulated liquids until the collected material is removed. 

The secondary containment mus\meetthe requirements of OAC Rule 37 45-

55-93, 

F.6 General Olll!rat!ng Requirements 

OAC Rule 3745-57-91 

(a) Hazardous waste ortreatment reagents shall not be placed in the filter press 

system if they could cause the filter press, its ancillary equipment, or the 

secondary containment system to rupture, leak, corrode or otherwise fail, 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 

if a leak or spm occurs in the filter press system. 

F. 7 Inspections 

OAC Rule 37 45-57-92 

(a) The Permittee shall inspect the 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 F of the Part B permit application. ' ' ' 

OHIO EPA DHWM 

SEP 3 0 2003 

VES01663 
· ........ •" 

Ron Incineration SeMc:es, Inc. 

Hazan!oua Waste lnstellaUon & Oper11!on Permit Renewal 

Page 85 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 hazardous waste filter press 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 press system or secondary containment system and inspect the system 

to determine the ceuse of the release. 

(b) Removal of Waste From the Miscellaneous Unit or 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 prevent further release of hazardous waste to 

the environment and to allow inspection and repair of the filter press 

system to be performed. 

{iij If the material released was to a secondary containment system, all 

released materials must be removed within twenty-four hours of the 

release to prevent harm to human health and the environment 

(c) Containment of Visible Releases to the Environment 

The Permittee shall immediately conduct a visual inspection of the release 

and, based upon that inspection, prevent further migration of the leak or spill 

to soU or surface water and remove, and properly dispose of, any visible. 

contamination of the soU or surface water. 

OHtOEPADHWM 

SEI' 3 0 Z003 

VES01663 
Rosa Incineration Services. Inc. 

Hazardous Wasta lnslaRa11on & Operation Parmft Renewal 

Page 68 of 101. 

(d) Notitlcatlons 

Any release to the environment. except as provided in OAC Rule 37 45-55-96 

(0)(2), must be reported to the director of Ohio EPA within 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 a filter press system that 

previously held an incompatible waste 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 l of the Part B permit application In accordance with OAC Rules 37 45-55-10 

through 37 45-55-40. 

' ' ' 

OH!OEPADHWM 

SEi' 3 0 2003 

VES016631 
Ross 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 

Permit and OAC Chapter 55,subject to the terms and conditions of this permit, and 

as described IIIII: • , 

OHIOEPAOHWM 

MAR 0 2 2005 

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VES01663
Ross 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 of the 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 Permittee shall maintain and monitor the groundwater monitoring system 

and comply with all other applicable requirements of OAC Rules 37 45-54-90 

thru 99 and OAC Rule 3745-55-01 during the post-closure period. 

(c) The Permittee shall comply with the requirements for surface 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 comply with all security requirements, as specified in the 

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 of the 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 0 2 2005 

VES016631 
Rosa Incineration Sen/lcea, Inc. 

Hazardous Wasts lnstallallon & Operation Permit Renewal 

Page 69 of 101 

G.4 InSPections 

_ OAC Rule 3745-55-17 

The Permittee shall inspect the components, structures, and equipment at the 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 

hazardous waste 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 

hazardous wastes disposed of before January 12, 1981, the Permittee shall 

identify the type, location, and quantity of the hazardous wastes to the best 

of his knowledge and In accordance with any records he has kept 

Within 60 days of certification of closure of the 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 of the 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 plat and record of the type, location, and quantity of 

hazardous wastes disposed of within each cell or other 

hazardous waste disposal unit of the factlity have been flied 

with the Director and the Lorain County zoning authority. 

(ii) Submit a certification to the Director, signed by the 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 EPA DHWM 

SEJ' 3 0 2003 

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VES016639 
Rooslnclnatatlon Services, Inc. 

Hazardous Waste Installation & Opatatlon Permit Renewal 

Page 70 of 101 

(c) If the Permittee or any subsequent owner or operator of the land upon which 

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 Chapter 3745-50. The Permittee or any 

subsequent owner or operator of the land shall demonstrate that the removal 

of hazardous wastes will satisfy the criteria of OAC Rule 37 45-55-17(C). 

(d) No later than 60 days after completion of the established post-closure care 

period for ~:~ach hazardous waste disposal unit, the Permittee shall submit to 

the Director, by registered mail, S. certification that the 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 

request until the Director releases the Permittee from the financial assurance 

requirements for post-closure care under OAC Rule 37 45-55-45. 

G.6 Financial Assurance 

OAC Rule 3745~5-45 

The Permittee shaH continuously maintain financial assurance during the postclosure period and comply with all applicable requirements of OAC Rules 37 45-55-

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 of the 

proposed amended Post-Closure Plan for approval by the Director. The Permittee 

shall request a permit modification whenever changes in operating plans or facility 

design affect the approved Post-Closure Plan, there is a change in the expected 

year of final 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 later than 60 days after an unexpected event has 

occurred which has affected the Post-Closure Plan. ., 

' 

OHIO EPA DHWM 

S£1' 3 0 2003 

VES01664 
Rou lnclneraUon Servl..,., Inc. 

Hazardous Waate lnslallallon & OpetaUon Pennlt Renewal 

Page 71 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 system for removing the ash remaining afterthe combustion 

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 chamber for the rotary kiln. 

Flue gases pass from the main chamber to the air pollution control equipment which 

consists of a quench/cyclone chamber, a radial scrubber, a gas/tiquid contector, two 

serially-oper;ited wet electrostatic precipitators (WESPs), an Induced draft fan and 

a stack. This series of air pollution control equipment removes contaminants 

(primarily particulates and acid gases) contained in the flue gas prior to discharge 

through a stack to the atmosphere. 

Stack emissions are monitored by Continuous EmisSion Monitor$ (CE.Ms) for carbon 

monoxide, oxygen and nitrogen oxides. Carbon monoxide is the primary indicator 

of combustion efficiency and destruction efficiency of hazardous constituents In the 

wastes. 

Operation of the incineration system is monitored and controlled by a Honeywell 

TDC 3000 distributed control system (DCS). Critical process parameters are 

continuously monitored by the DCS and are accessible to the control rooQ1 operator. 

The control system maintains key process parameters within permitted ranges. The 

OHIO EPA 

SEt' 31 

VE.S01664 
Ro .. 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. 

Except for changes required by the recently installed air pollution 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 a performal)ce test in October of 2000 to demonstrate 

that current system performance is consistent with performance during the -1992 

trial bum. The Permittee submitted the results of the 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 

under a Shakedown 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 only feed 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 hazardous wastes 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 of the 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 under the 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 

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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 of the 

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 of Module I( A) to this permit and Table 05-6 of 

Seption 0 of the Part B permit application. 

System total halogen daily average in waste feed shall not exceed 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. 

The viscosity of waste fed to the incinerator burners shall not exceed 

the limits in Table 05-6 of Section 0 of the 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 is within the physical and chemical composition limits specified in 

this permit · 

The Permittee shall conduct waste analysis of the 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 of Section D 

of the Part B permit application. Records of this activity shall be kept at the 

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 of the Part B 

permit application. 

All waste streams fed into the incinerator shall be within the characteristics 

set forth in Table 05-6 of Section 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 not feed wasti!S through the kiln aerosol can feeder and 

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 shall operate-and maintain all components of the 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, in accordance with the design plans, performance 

specifications and maintenance practices contained in Section D-5 of the 

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, it will 

meet the performance standards specified in permit Conditions I(A).3(d) 

through I(A).3(f). 

(d) The incinerator shall achieve a destruction and removal efficiency (ORE) of 

99.99 percent for each of the following principal organic hazardous 

constituents (POHC) for each waste feed. The designated POHcs pursuant 

to OAC Rule 3745-57-42(8) are carbon tetrachlod,de and 

. ' 

OHIO EPADHWM 

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 using the method 

specified in OAC Rule 3745-57-43(A)(1}. 

The Permittee shall control hydrogen chloride (HCI) emissions, such that the 

rate of emissions is no greater than the larger of either 1.8 kilograms per hour 

(4 pounds/hour) or one percent of the 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 cubic foot) 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 for the amount of oxygen 

in the stack gas, shall not exceed 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 volumetric flow, 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. 

The mass feed rates of toxic 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 Permit Renewal 

Page 76 of 101 

(n) 

(o) 

(p) 

(q) 

(r) 

The Permittee shall control fugitiVe 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 

Attachment A of Module I(A) of this 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) of the Part B permit 

application, shall be fed into the incinerator until the minimum temperature 

conditions in Attachment A of Module 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) of the 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 

A of Module I(A) while hazardous waste remains in the combustion chamber 

(i.e., hazardous. waste residence time has not transpired prior to the 

hazardous waste feed cutoff) during a rolling 60-day block period, submit to 

the Director of Ohio EPA a written report within 5 calendar days of the 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, D and F of the Part B permit 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) of the permit application When feeding waste 

into the Main Chamber through the side door feed mechanism. 

(iiQ The Permittee shall follow the procedures and practices identified in 

Section D of the Part B permit application for operation of the tanker 

and drum direct feed systems, the side door feed system and the 

direct feed areas. 

' ·. 

'· 

OHIOEPADHWIII 

SE~ 3 0 Z003 

. i 

VES016646 
Ross Incineration Selvlcea, Inc. 

Hazardous Waste lnetallatlan & Operation Permh Renewal 

Page 71 of 101 

(iv) The Pennittee shall comply with the following general operating 

requirements .for operation of the direct feed systems and the direct 

feed areas: 

The direct transfer of hazardous waste to the incinerator shall be 

conducted so that it does 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 or the 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 of the 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 of the 

Part B permit application. 

The Pennittee shall conduct inspections of the direct feed 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 least three years from the date of the inspection. 

' ' 

OHIO EPAOHWM 

St. I' 3 0 2003 

VES01664
Ross. Incineration Services., Inc. 

Hazardous Waste Installation & Operation PennK Renewal 

Page 78 of 101 

(s) 

(t) 

(u) 

(v} 

(v) Reserved. 

(vi) The Permittee shall not feed empty containers through the side door 

feed mechanism unless the provisions applicable to empty containers 

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 comply with all the applicable requirements for 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, evidence that compliance with these operating conditions 

. is insufficient to ensure compliance with the aforementioned performance 

standards may be. •information" justifying modification, revocation, or 

reissuance of the permit pursuant to OAC Rule 3745-50;-51. 

Wastes may be fed during the periods for Short-Term Incineration under the 

Shakedown Period, Trial Bum Period, and Post-Trial Burn Period without 

meeting permit Conditions I(A).3(g) through (v) only if such 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 of these inspections: 

VES01664S 
Ross Incineration Services, Inc. 

Hazardous Waste Installation & Operation Permit Renewal 

"- Page 79of101 

(a) 

(b) 

(c) 

The Permittee shall thoroughly visually inspect he incinerator and associated 

equipment (including pumps, valves, conveyor, , pipes, etc.) for leaks, spills, 

fugitive emissions, and signs of tampering, 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 least weekly to verify ope· bility, and document the 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-off system 

testing is perfonned weekly to verify operabilitY The emergency waste feed 

cut-off test will be conducted once during each ' lendar week, except for any 

calendar week in which the waste is not fed to~ e incinerator for 48 hours or 

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. ms listed 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 at t 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 

parameter listed under'Parameter and Monitoring Location" at the frequency 

specified under ·caubration Frequency" as listed in Attachment C of 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 equipment shall 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% of full scale readings, Whichever is greater. 

The Pennlttee shall document the 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 of viscosity tests on liquid wastes and bypass fuels 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 37 49-57-45 

· (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 3 0 ZODJ 

' ; 

VES016650 
--

Rosa Incineration Services, Inc. 

Hazardous Waala lnataUatlon & Operation Pennlt Renewal 

Page 81 of 101 

(b) In case of a malfunction of the automatic waste feed cut-off systems, the 

Permittee shall perform manual shutdowns in accordance with the approved 

procedures In the Part B permit application. The Permittee shall not rvstart 

the Incinerator until the problem causing the malfunction has been located 

and corrected. 

(c) The waste feeds to the incinerator shall be automatically cutoff whenever any 

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) to this permit is exceeded. 

The Pennittee shall test the automatic waste feed cut-off system weekly and 

document the test using pages 42 and 42.1 of 45 in Appendix F-2 of Section 

F of the Part B permit application. · 

(d) Unless the Pennittee can show otherwise per OAC Rule 3745-51-03(0), 

residue from the incinerator is hazardous waste, the Permittee Is a generator 

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 under the requirements 

of this 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 of the automatic waste feed shut-off 

systems and corrective actions taken. 

.OHIO EPA DHWM . 

SE.I' 3 0 ZOD3 · 

VES016651 
Roaa Incineration Serllcos, Inc. 

Hazardous Waate lnatallallon & Operation Pormft Renewal 

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 (pursuant to OAC Rules 3745-57-47 (B) and (D)). 

The Permittee shall document all emergency process termination (EP'T) 

incidents at the facUlty and promptly report the occurrence of the EPT, cause 

of the EPT and associated emissions to Ohio EPA. 

I(A) .9 Compliance Scbedule 

(a) No later than one year after the effectiVe date of this permit, the Permittee 

shall submit a plan to reduce the frequency of emergency process 

termination incidents (EPTs) at the facility to the Ohio.EPA. The plan shan· 

include a listing of all EPT incidents in the five year period 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 EPA will review the EPT frequency reduction plan as submitted by the 

Penriittee, and If necessary, notify Permittee of deficiencies. If necessary, 

Ohio EPA will request that the Permittee submit a permit modification 

request to 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 highly volatile and flammable liquid wastes (e. g. Class 1A, 18 

and 1C liquids). 

For those wastes possessing flammabDity properties that are not~onsistent 

with using the trench as part of the containment system, the Pemiittee shall 

Include the following options In its evaluation: 

OHIOEPADHWM 

SEr 3 0 2003 

~------ ··-------· -· -

VES016652 
Ross Incineration Services, Inc. 

Hazardous Waste Installation & Operation Permit Renewal 

Page83 ol101 

(i) Do not tanker direct feed, or 

(ii) Feed at tanker direct feed location number 3, or 

(iii) Modify the 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 

highly volatile and flammable liquid wastes from incineratortanker direct feed 

· locations Number 1 and 2. Ohio EPA will either approve the plan, issue a 

notice of deficiencies 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 

approve the evaluation, issue a notice of deficiencies or a revised evaluation. 

If any,changes to tanker direct feed eontainment or operations are required 

as a result of the evaluation, Ohio EPA will request that the 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 

insufficient time 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 at Taitker Direct Feed Site 

Number 3 so that no portion of any direct feed 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:fqrmmg tanker direct feeding at . 

Site Number 3. 

The Permittee shall construct the paving to the same standards as the paving 

proposed for former OCSA 1 and described in the Permittee's letter to 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 construct the 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 letter to Ohio EPA dated June 13, 1995, Permittee shall submit 

a permit modification request prior to installation which includes appropriate 

drawings and construction standards. The Permittee shall submit the 

required permit modification request no later than ~onths after the date 

of this permit. The Permittee shall complete construction no later than six 

months after Ohio EPA approval of the construction drawings.· 

If the Permittee believes th.at any of the preceding schedules provide 

insufficient time 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; 

VES016654 
Ross Incineration Services, Inc. 

Hazardous Waste Installation & Operatlpn Permit Renewal 

Page 85 of 101 

(ii) The Permittee has submitted to Ohio EPA a permit modification 

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 

Performance Test Plan and each succeeding three years. The performance 

test plan shall be submitted to Ohio EPA at least six months prior to 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 

submit to Ohio EPA the report documenting performance test activities and · 

results within 6 month of conducting eaCh performance test. 

VES016655 
Ross 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) 

T ota\ 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 main chamber, 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 

667 

I 

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 

1,1oo

1 

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 

VES016656 
Rosa 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 Effect Of Carcinogenic Metals 

b 1.74lbJhd 

3,59lbl_!lb 

4.20 lbJh8 . 47.2lbJh 

Ohio EPA has limited the combined risk effect of the carcinogenic metals to be less . -5 

than 1.0 x 10 . • . . 

. Therefore, the carcinogenic metals will also be restricted by the following equation: 

AKMIK + AMcf'NMC + BKIXK + BMcfXMC + Cl(IYK + CMciY MC + 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 of beryUium 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 of cadmium to the main chamber 

HK = actual 24-h rolling average, lblh of total chromium to the klln 

HMc = actual24-h rolling average, lblh of total chromium to the main chamber 

WK = 18.91blh (maximum) of arsenic to 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. 0 x 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 

OHIO EPA 0HWM 

SFtl ~ n ?nm 

VES016657 
Ross 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 in spike 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 chamber burner waste 

feed atomization pressure may be .zero during periods when the main chamber burner is not 

in use. 

j) Total induction fans amps applicable only when 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 at the outlet of the 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 of Atomization 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 of operating parameters for 5 minutes. 

c Waste feed cutoff following deviation of operating parameters for 30 seconds .. 

d Waste feed cutoff following deviation of operating 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 Cutoff Actuating Events and Settings (Cont) 

CO Concenlratjon - Waste feed cutoff shall be actuated to kiln and main-chamber when 

the operation limits specified in Attachment A, Item 8 of this permit application are· 

exceeded. 

Loss of Atomjzatjon 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 

Attachment A, 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 of WESP 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 of the scrubber liquor from the 

gas liquid contactor rundown drops below the limits specified in Attachment A, item 7. 

Scrubber Water Flow rate- An alarm will be actuated when the water flow rate to the radial 

flow scrubber or gas liquid contactor falls outside the operating range specified in 

Attachment A, 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 stack falls 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 chamber will be automatically cutoff whenever the following conditions are 

sensed: 

- Low Btu from Tank Farm Ill or direct feed flow rate of 5000 lbslhr for 10 seconds; 

- Low Btu from Tank Farm Ill or direct feed flow rate of 13000 lbslhr following the first 30 

seconds of waste feed. 

Ar alarm will be actuated whenever the 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 cutoff system not actuate when exceeding one of the 

liquid feed cutoff limits above, the Operator will take corrective measures to assure that waste 

....... ·• 

'••(:_,~:-~) 

feed is cutoff at the location .of the upset condition. · OHIO Ef'A Dl-!1.:;,: 

S£t' 3 0 2003 

VES016660 
Ross lncinera.. .:1rvices. Inc. 

Hazanlous Waste Installation & Operation Pennll Renewal 

Attachment C-Module I{A) 

Incinerator Operating Parameter Monitoring Systems and Frequencies 

Indicator 

Discharge 

amps 

Hourly 

transducer HoWiy 

Backup 

Oiilo£11l!.~ 

VES016661 
Ros9 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 during the post-closure period that 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 ground water monitoring wells as shown on 

Figure 1 In Section E of the approved pemnit application, which is part of the 

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 of the approved permit application and 

· in conformance with the following list: 

.. -- --. --··------'--------

VES016662 
RosslnclneraUon 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 ground water monitoring system must: yield samples in upgradient wells 

that represent the quality of the background ground water unaffected by 

leakage from any regulated unit(s}, and in downgradient wells 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 based on site-specific hydrogeologic characterization. 

(b) The Permittee shall remove or replace any monitoring well identified in permit 

Condition J.2(a) in accordance with the permit modification process set forth 

in OAC Rule 3745-50-51. must 

map as specified 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 ofthe wells specified in permit Condition J.2(a) are replaced, 

the Permittee must demonstrate to Ohio EPA that the ground water quality 

at the replacement well meets the criteria in permit Condition J.2(a) within a 

two year period of the 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 a table of unique identifiers for 

each well (both upgradientlbackground and downgradienU compliance wells), 

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 

VES016663 
Ross 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 

meet the 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 by OAC Rule 37 45-54-98(A) for which 

no background values are established at the time the permit is issued, the 

Permittee shall establish background values in accordance with the following 

procedures: 

(i) During each sampling event, the Permittee shall take a minimum of 

one sample from each well(background and compliance point wells), 

and analyze for eacti parameter or constituent specified in the permit. 

Background ground water quality for a monitoring parameter or 

constituent may be based on a sequence of four samples, taken at a 

quarterly interval that assures,. to the greatest extent technically 

feasible, that an independent sample is obtained of the background 

well{s), or 

OHIO EPA DHWM 

MAR 0 2 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 EPA OHWM 

MAR 0 2 2005 

· following: 

(i) Background is not updated with less than 4 new data points at any 

onetime; 

Oi) The new background (previous background data plus new background 

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 permit Condition J.3(c)(ii), the identified trends would have 

to be adequately demonstrated to not be the result of a release from . 

the regulated unit otherwise the background update would not be 

permitted; and 

(iv) When a trend 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. 

-----·-------

VES016665 
Ross 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!!:!~ analysis techniques and procedures in . 

are In accordance with the rec,uirem,enlts 

E). The Permittee shall use the techniques and 

procedures when obtaining and analyzing samples from the groundwater monitoring 

wells identified in J.2(a): 

(b) The well shall be checked for the presence of immiscible layers prior to 

purging in any monitoring well or wells where the presence of dissolved 

concentrations of any 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 0 2 2005 

VES016666 
Ross Incineration SeMces, Inc. 

Hazardous Waste Installation & Operation Permit Renewal 

Page 91 of 101 

(I) Chain of custody procedures, including standardized field tracking reporting 

forms, and sample labels, shall be implemented in accordance with Section 

E of the approved permit application. 

J.5 Elevation of the Ground-Water Surface 

(a) . 

{b) 

(c) 

The Permittee shall determine the elevation of the 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 of the approved permit application for surveying the ground surface 

elevation of all monitoring wells included in Permit Condition J.2(a). 

The Permittee shall record the total depth of any wells installed in accordance 

with permit Condition J.2 and the surveyed elevation of the 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 evaluating the monitoring results in accordance with Permit Condition 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 procedure for determining 

whether a statistically significant change has occurred. 

Any statistical method that is chosen must comply with the following 

performance standards as appropriate: 

VES016667 
Ross Incineration Services, Inc. 

Hazardous Waste lnstellaUcn & Oporatlcn Pennll Renewal Pa~ 92of101 · 

(Q The statistical method shall utilize a sample size appropriate for the 

form of statistical test employed and large enough to ensure with 

reasonable confidence that a contaminant release to the ground water 

from the facility will be detected. 

(li) The statistical procedure must be protective of human health and the 

environment and provide reasonable confidence that the migration of 

hazardous constituents from a regulated unit into and through the 

aquifer will 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 for the 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 probabirtty of falsely Identifying a non-contaminating regulated unit 

and the probability of failing to Identify a 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 Any practical quantltation limit 

(PQL) approved in the permit that Is used In the statistical method 

shall be the 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) If necessary, the statistical method ~hall include procedures to control 

or correct for seasonal and spatial variability as well as temporal 

correlation in the data. · 

(viiQ If a 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 EPA DHWM ·-. · •. 

SEJ' 3 0 2003 

----------·-··---···---·-···-·· 

VES016668 
Ross Incineration Services, Inc. 

Hazardous Waste Installation & Operation Penn~ Renewal 

Page 93 of 101 

after considering the number of samples in the 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 of the last background sampling event 

. J.7 Monitoring Program and Data Evaluation 

(a) 

(i) In addition to the 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. If a 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: If elevated chloride concentrations are found to act as 

a laboratory interfering agent, then no further response will be 

necessary by the Permittee. However, if chloride ·is determined not to 

be an interfering agent, the Permittee shall 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 

no further response will be necessary by the Permittee. However, if 

chloride is determined not to be an interfering agent, the Permittee 

OHIO EPA DHVt'M 

MAR 0 2 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. If a statistical increase in TOC is confirmed 

through a resample, then the Pennittee shall immediately sample and 

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. If the results are non-detect 

for the VOCs/SVOCs or do not indicate a statistically significant 

difference for the 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 Penn it Condition J .4. 

(ii) The Permittee shall determine ground water quality at each monitoring 

well annually during the post-closure care period of the regulated 

units, exceptthat sampling and analysis for new monitoring wells MW32 and MW-33 shall be conducted on the following schedule: quarterly 

for the first two years, then semi-annually for five years, then annually. 

VES016670 
Ross Incineration Services, Inc. 

Hazardous Waste lnslaUatlon & OperaUan Pennlt Renewal 

Page 95 of 101 

(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 at the complia'llce poinl In determining whether such an 

increase has occumed, the Permittee must compare the ground water 

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) or other statistical limit approved by the director, in accordance 

with the statistical procedures specified in permit Condition J.6. If 

there Is a confirmed detection of any of 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.1 0 regarding 

statistical evidence of contamination. 

The Permittee shall perform the evaluations described in permit 

Condition J.7(c)(v) within 90 days after completion of sampling. 

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 of the full Quality Assurance/Quality Control 

(QA/QC) report for a particular sampling event if circumstances warrant, but 

in general QA/QC data will not be required except as described below. The 

Permittee shall enter all of the 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 laboratory sheets for the full volatile and semi~ 

volatile analyses (must include method codes, detection,limits, and · 

units of measurement); \ 

OHIO EPA DHWM 

SEt' 3 0 2003 

VES016671 
Ross 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 of deviation from the procedures in the 

Part B permit application or the Sampling and Analysis Plan (SAP), 

including documentation of parameter omissions during the sampling 

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's verification of the accuracy and precision of the 

analytical data and determined its quality. This review shall 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, data qualifiers Including their definitions, 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 of the field parameters; 

(x) All chains of custody; 

(xi) The date the 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 of statistical tests) 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 0 2003 

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 of the annual determination of the ground water flow 

rate and direction as required by OAC Rule 3745-54-73(8)(6); and 

(xvi) The results of the last three yeani of all 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 

statistical calculations within 90 days ofthe completion of the last background 

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 day thereafter if this falls on a weekend. The annual report 

must reference the titles and dates of any other periodic reports required by 

the permit or any updates to those reports (for example, due to confirmation 

sampling, comments by Ohio EPA, etc.), but generally do 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), the ground water elevation data required by permit Condition 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 of all ground water and blank data must 

be submitted electronically in the format supplied by the Director, a hard copy 

of well-specific information (location [latitude and longitude], depth, 

construction, etc.) for any new/replacement wells, and any other information 

specified in the instructions for the annual report not addressed in this permit 

Condition must be submitted by March 1 .. of the subsequent year as required 

by OAC Rule 3745-54-75. 

OHIO EPADHWM 

MAR 0 2 2005 

VES016673 
Ross 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 of these 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 assure the Director that during the term of the permit the ground 

water monitoring program will ensure the earliest possible detection of 

contamination leakage from the regulated units, that any contamination leakage will 

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 Permit Condition J.3(a) in accordance with statistical procedures 

specified In Pennit Condition J.S and J. 7, ora detection above the method detection 

limit for any VOCs or SVOCs Identified in Permit Condition J.7(a)(lv) and J.7(a)(v), 

the Penilittee must 

(a) Notify the Director in writing, within seven (7) days of that 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 

Condition J.2(a) and determine the concentration ofwell-speclficparameters 

listed In Permit Condition J.10(a). 

(c) If the results of the 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 EPA DHWM 

. SEP 3 0 Z003 

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results are non-detect for the VOCs/SVOCs or do not indicate a statistically 

significant difference for the metals, then the Pennittee may remain In 

Detection Monitoring. 

(d) Within 90 days of confirming a statistically significant Increase in metals or 

a VOC/SVOC detection above method detection limits, submit to the Director 

an application for a pennit modification to establish a compliance monitoring 

(e) 

· program. The application must include the following infonnation: 

(i) An identification of the cqncentration of each metal, VOC or SVOC 

detected in the ground water at each monitoring well at the point of 

compliance . 

. (ii) Any proposed changes to the ground water monitoring system at the 

facility necessary to meet the requirements of compliance monitoring 

under OAC Rule 3745-54-99. 

(iii) Any proposed changes to the monitoring frequency, sampling and 

analysis procedures or methods or statistical procedures used at the 

facility necessary to meet the requirements of compliance 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 at the next regularly scheduled sampling event following 

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 of all hazardous constituents 

identified underpennit Condition J.1 O(b) do not exceed the respective values 

fisted in Table 1 of OAC Rule 3745-54-94 (or their respectiveMCLs), or the 

Pennittee has sought an ACL variance for every hazardous constituent 

identified under pennit Condition J.1 O(b). If the Pennittee's ACL request is 

· denied, Ohio EPA will specify a time frame for submittal of the EFP. 

'· 

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OHIO EPA Dff.\':,1 

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(f) If the Permittee determines, pursuant to Permit Condition J. 7( c)(V), that there 

Is a statistically significant increase above the background values for the 

hazardous parameters specified in Permit Condition . J.3(a), he may 

demonstrate that a source other than a regulated unit caused the Increase 

or that the 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 report to the Director which successfully demonstrates that 

a source other than a regulated unit caused the increase, or that the 

. increase resulted from error in sampling, analysis, or evaluation. 

(iiO Within 90 days of determining a statistically significant increase, 

submit to the Director an application for a permit modification to make 

any appropriate changes to the detection monitoring program at the 

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) 

If the Permittee or the Director determines the detection monitoring program no 

longer satisfies the requirements of the regulations, the Permittee must, within 90 

days of the determination, submit the date of that determination and an application 

OHIO EPA Oh'WM 

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for a penn it modification to make any appropriate changes to the program which Will 

satisfy the 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 

OHIO EPA Oh'Vf.w 

SEr 3 0 2003 

VES016677 
VES016678-016711.pdf 

OHD 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. EPA Identification 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 in the second person 

as "you") in connection with the hazardous waste treatment, storage, and disposal facility in East 

Liverpool, Ohio. 

This permit is issued under the Solid Waste Disposal Act, as amended by the Resource 

Conservation and Recovery Act of 1976, and the Hazardous and Solid Waste Amendments 

(HSWA) of 1984 (42 USC§ 6901 et seq.) (collective1yreferred to as RCRA) and EPA's 

regulations promulgated thereunder (codified, and to be codified, in Title 40 of the Code of 

Federal Regulations (40 CFR)). 

'I 

VES016678 
OHD 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 RCRA permit conditions. The Permittee also has a state RCRA 

pepnit which contains conditions issued by the State of Ohio's RCRA program authorized under 

40 CFR Part 271. Any hazardous waste activity which requires a RCRA permit and is not included 

either in this permit or the state RCRA permit is prohibited. 

Permit Approval: 

On June 30, 1989, the State of Ohio received final authorization pursuant to Section 3006 of 

RCRA, 42 USC§ 6926, and 40 CFR Part 271, to administer the pre-HSWA RCRA hazardous 

waste program. The State of Ohio 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 of Ohio to admiriister certain regulations, including air emission 

standards for eqnipment leaks, tanks and containers, and air emission standards associated with 

miscellaneous units, and certain other regulations, the U.S. EPA Region 5 is issning the RCRA 

pennit reqnirements for operations at the Permittee's facility which fall under these regulations. 

You must comply with all tenns and conditions contained in this permit. This permit 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 of RCRA. 

This permit is based on the assumptions that the 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. 

Any inaccuracies in the submitted information may be grounds for the U.S. EPA to terminate, 

revoke and reissue, or modifY 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 of any deviation from, or 

changes in, the information in the Application that might affect your ability to comply with the 

applicable regulations or conditions of this permit. 

ii 

VES016679 
OHD 980 613 541 

Opportunity to Appeal: 

Petitions for review must be submitted within 30 days after EPA serves notice of the final permit 

decision. Any person who filed comments on the draft permit or participated in the public hearing 

may petition the Environmental Appeals Board to review any condition of the permit decision. 

Any person who failed to file comments or failed to participate in the public hearing on the draft 

permit may file a p~tition for review only to the extent of the 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 of May 1. 2009 and will remain in effect until May l. 2019, unless 

revoked and reissued under 40 CFR § 270.41, terminated under 

40 CFR § 270.43, or continued in accordance with 40 CFR § 270.51(a). 

By:f-.,~~4- . are! M. Guernero 

uector 

Date: vVl M. 81 2IJD j 

Land and Chemicals Division 

iii 

VES016680 
OHD 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 of Construction ..................................................................... 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 of Permit ............................................................................................ 9 

I.J ATTACHMENTS AND DOCUMENTS INCORPORATED BY 

REFERENCE .......................................................................................................... 9 

I.K COORDINATION WITH THE CLEAN AIR ACT ............................................ 10 

iv 

VES016681 
OHD 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 CFR Part 264, Subpart BB) ................................................................ ! 0 

liLA General ................................................................................................................... I 0 

III.B Equipment Leaks ................................................................................................... !! 

III. B.! Waste Determination and Equipment ....................................................... 11 

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

III.B .3 Pressure Relief Devices in GasN apor Service ......................................... 12 

III.B A Sampling Connection Systems ......................................•......................... 12 

III.B.5 Open-Ended Valves or Lines .................................................................. 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 of Repair ...................................................................................... 14 

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

III.B.l 0 Alternative Standards for Valves in Gas!Y.apor Service or in 

Light Liquid Service; Percentage of Valves 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 CFR PART 264, 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 Bulk Feed Tanks (S-1 and S-2) ............................................................... 19 

IV.C.5 Laboratory Waste Tank (L-1) ................................................................. 20 

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

v 

VES016682 
OIID 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 of Ventilation Header Blower and Secondary Vent Blower .. 23 

IV.E.3 Control Devices ............................................... : ....................................... 24 

IV.E.4 Disposal of Spent Carbons ......................................................................... 26 

IV.E.5 Compliance with Consent Decree .............................................................. 26 

IV.F Tanks and Containers Exempt Under 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 

VES016683 
OHD 980 613 541 

Page I of 28 

SECTION I-- STANDARD PERMIT CONDITIONS 

[.A EFFECT OF PERMIT 

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 storage and treatment ofRCRA hazardous waste must 

comply with all terms and conditions in this permit. Other aspects of the storage and 

treatment of RCRA'hazardous wastes are subject to the conditions in the state-issued 

portion of the RCRA permit. Any hazardous waste activity which requires a RCRA permit 

and is not included either in this permit or the state RCRA pennit is prohibited. 

Subject to 40 CFR § 270.4, compliance with the RCRA permit during its term constitutes 

compliance for purposes of enforcement with Subtitle C ofRCRA except for those 

requirements not included in the permit which: (I) become effective by statute; (2) are 

promulgated under 40 CFR Part 268 restricting the placement of hazardous waste in or on 

the land; (3) are promulgated under 40 CFR Part 264 regarding leak detection systems; or 

( 4) are promulgated under subparts AA, BB, or CC of 40 CFR Part 265 limiting air 

emissions. ( 40 CFR § 270.4) 

This permit does not: (I) convey any property rights or any exclusive privilege (40 CFR § 

270.30(g)); (2) authorize any injury to persons or property, or invasion of other private 

rights; or (3) authorize any infringement of state or local law or regulations. Compliance 

with the terms of this 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 of the 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 

USC§§ 9601 et seq. (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 may review and modifY, revoke and reissue, or terminate this permit for 

cause, as specified in 40 CFR § 270.41, § 270.42, and§ 270.43. The U.S. EPA may also 

review and modifY this permit, consistent with 40 CFR § 270.41, to include any terms and 

conditions it determines are necessary to protect human health and the environment under 

Section 3005(c)(3) ofRCRA. The filing of a request for a permit modification, revocation 

and reissuance, or termination, or a notification of planned changes or anticipated 

noncompliance on your part will not stay the applicability or enforceability of any permit 

condition. (40 CFR § 270.30(f)) 

VES016684 
OIID 980 613 541 

Page 2 of 28 

You may request a modification of this permit llllder the procedures specified in 40 CPR § 

270.42. You must not perform any construction associated with a Class 3 permit 

modification request lllltil such modification request is granted and the modification 

becomes effective. You may perform construction associated with a Class 2 permit 

modification request beginning 60 days after submission of the 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 Permit Renewal 

This permit may be renewed as specified in 40 CFR § 270.30(b) and Condition I.E.2 of this 

permit. In reviewing any application for a permit renewal, the U.S. EPA will consider 

improvements in the state of control and measurement technology, and changes in 

applicable regulations. ( 40 CFR § 270.30(b) and RCRA Section 3005( c)(3)) 

I.C SEVERABILITY 

This permit's provisions are severable; if any permit provision, or the application of any 

permit provision to any circumstance, is held invalid, such provision's application to other 

circumstances and the remainder of this permit will not be affected. Invalidation of any 

statutory or regulatory provision on which any condition of this permit is based does not 

affect the validity of any other statutory or regulatory basis for that condition. (40 CFR § 

124.16(a)) 

I.D DEFINITIONS 

The terms used in this permit will have the same meaning as in 40 CFR Parts 124, 260 

through 266, 268 and 270, unless this permit specifically provides otherwise. Where 

neither the regulations nor the permit define a term, the term's definition will be the 

standard dictionary definition or its generally accepted sc~entific or industrial meaning. 

I.E DUTIES AND REQUIREMENTS 

l.E.l Duty to Comply 

You must comply with all conditions of this permit, except to the extent and for the 

duration for which an emergency permit authorizes such noncompliance ( 40 CFR 

§ 270.61 ). Any permit noncompliance, except under the terms of an emergency permit, 

constitutes a violation ofRCRA and will be grounds for: enforcement action; permit 

termination; revocation and reissuance; modification; or denial of a permit renewal 

application. (40 CFR § 270.30(a)) 

VES016685 
I.E.2 Duty to Reapply 

OHD 980 613 541 

Page 3 of 28 

If you wish to continue the permit regulated activities after the 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 before the permit expiration date, unless the Director grants 

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 Permit Expiration 

Unless revoked or terminated, this permit and all conditions herein will be effective until 

the expiration date of this permit. This permit and all conditions herein will remain in 

effect beyond the permit's expiration date if you have submitted a timely, complete 

application (40 CFR § 270.10 and§§ 270.13 through 270.29), and, through no fault of your 

own, the Director has not made a final determination regarding permit reissuance. ( 40 CPR 

§§ 270.50 and 270.51) 

I.E.4 Need to Halt or Reduce Activity Not a Defense 

In an enforcement action, you are not entitled to a defense that it would have been 

necessary to halt or reduce the permitted activity to maintain compliance with this permit. 

(40 CFR § 270.30(c)) 

I.E.S Duty to Mitigate 

In the event of noncompliance 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 and maintain all facilities and treatment and control 

systems (and related appurtenances) that you install or use to comply with this permit. 

Proper operation and maintenance 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 Duty to Provide Information 

You must provide the Director, within a reasonable time, any relevant information that the 

Director requests to determine whether there is cause to modify, revoke and reissue, or 

VES016686 
OHD 980 613 541 

Page 4of 28 

terminate this permit, or to determine permit compliance. You must also provide the 

Director, upon request, with copies of any records this penni! requires. The information 

you must maintain under this penni! is not subject to the Paperwork Reduction Act of 

1980, 44 USC §§ 3501 et seq. (40 CFR §§ 264.74{a) and 270.30{b)) 

J.E.8 Inspection and Entry 

Upon the presentation of credentials and other legally required documents, you must allow 

the Director or an authorized representative to (40 CFR § 270.30{i)): 

I.E.S.a Enter at reasonable times upon your premises where a regulated activity 

is located or conducted, or where records must be kept under the conditions of this 

permit; 

I.E.S.b Have access to and copy, at reasonable times, any records that you must 

keep under the conditions of this permit; 

I.E.8.c Inspect, at reasonable times, any facilities, equipment {including 

monitoring and control equipment), practices, or operations regulated or reqnired 

under this permit; and 

I.E.8.d Sample or monitor, at reasonable times, any substances at any location to 

ensure permit compliance or as RCRA otherwise authorizes. 

Notwithstanding any provision of this 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 of the monitored activity. The methods used to obtain a 

representative sample of the wastes, contaminated media, treatment residue, or 

other waste to be analyzed must be the appropriate methods from Appendix I of 40 

CFR Part 261, or the methods specified in the state-approved and/or U.S. EPAapproved waste analysis plan, or an equivalent method approved by the Director. 

Laboratory methods must be those specified in Test Methods for Evaluating Solid 

Waste: Physical/Chemical Methods (SW-846, latest edition), Methods for Chemical 

Analysis of Water and Wastes (EPA 600/4-79-020), or an equivalent method, as 

specified in the referenced 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. 

VES016687 
OHD 980 613 541 

Page 5 of 28 

I.E.9.d You must retain all reports, records, or other documents, required by this 

permit, and records of all data used to complete the application for this pennit, for a 

period of at least 3 years from the date of the reports, records, or other documents, 

unless a different period is specified in this penni!. The 3-year period may be 

extended by request ofthe Director at any time and is automatically extended 

during the course of any unresolved enforcement action regarding this facility. ( 40 

CPR§§ 270.30(j), 270.31, and 264.74(b)) 

I.E.lO Reporting Planned Changes 

You must notifY the Director as soon as possible of any planned physical alterations or 

additions to the permitted facility. (40 CFR § 270.30(1)(1)) 

I.E.ll Reporting Anticipated Noncompliance 

You must notifY the Director, in advance, of any planned changes in the permitted facility 

or activity that may result in pennit noncompliance. Advance notice will not constitute a 

defense for any noncompliance. ( 40 CPR § 270.30(1)(2)) 

I.E.l2 Certification of Construction 

Subject to the requirements of40 CPR§ 270.32(b)(2) and§ 270.42 AppendiX I, you must 

not operate any RCRA 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 of this penni!, until you have submitted to the Director, by certified mail or 

hand-delivery, a letter signed both by your authorized representative and by a registered 

professional engineer. That letter must state that the portions of the facility covered by this 

permit (including ail air eruission control devices required by this permit) have been 

constructed in compliance with the applicable conditions of this penni! (40 CFR § 

270.30(1)(2)). In addition, you must not operate the pennitted control devices, or any 

hazardous waste management uuits that rely on such devices to meet the requirements of 

this permit, until either: 

I.E.l2.a The Director or his/her representative has inspected those portions of the 

facility and finds them in compliance with the conditions of the permit; or 

I.E.12.b The Director waives prior inspection and the Permittee may commence 

treatment, storage, or disposal of hazardous waste if the Permittee has not received 

notice from the Director of his or her intent to inspect within 15 days of the date of 

submission of the letter discussed in I.E.l2 above, as specified in 40 CFR 

§ 270.30(1)(2)(ii)(B). 

VES016688 
I.E.13 Transfer of Pennits 

OHD 980 613 541 

Page 6 of 28 

This pennit is not transferable to any person, except after notice to the Director. You must 

inform the Director and obtain prior approval of the Director before transferring ownership 

or operational control of the facility (40 CFR § 270.42, Appendix 1). Under 40 CFR § 

270.40, the Director may require pennit modification, or revocation and reissuance to 

change the Permittee's name and incorporate other RCRA requirements. Before 

transferring ownership or operation of the facility during its operating life, you must notify 

the Director and obtain prior approval and notify the new owner or operator in writing of 

the requirements of this permit and the requirements of 40 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 You must report to the Director any noncompliance with this penni! that 

may endanger human health or the environment. Any such information must be 

promptly reported orally, but no later than 24 hours after you become aware of the 

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 of any 

hazardous waste that may endanger public drinking water supplies; (2) release or 

discharge of hazardous 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 or human health outside 

the facility. You must include the following information: 

(1) Name, title and telephone number of the person making the report; 

(2) Name, address and telephone number of the facility; 

(3) Name, address and telephone number of owner or operator; 

(4) Date, time and type of incident; 

(5) Lacation and cause of incident; 

(6) Identification and quantity ofmaterial(s) involved; 

(7) Extent of injuries, if any; 

(8) Assessment of actual or potential hazards to the environment and human 

health outside the facility, where applicable; 

(9) Description of any emergency action taken to minimize the threat to human 

VES016689 
health and the enviromnent; and 

OHD 980 613 541 

Page 7 of 48 

(I 0) Estimated quantity and disposition of recovered 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 of this permit, a written report must also be provided within 5 calendar 

days after you become aware of the circumstances. The written report must 

include, but is not limited to, the following: 

(I) Name, address and telephone number of the person reporting; 

(2) Incident description (noncompliance including any nil ease or discharge of 

hazardous waste), including cause, location, extent of injuries, if any, and an 

assessment of actual or potential 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 of hazardous waste) occurred, including exact dates and times; 

(4) Whether the incident'sresults continue to threaten human health and the 

environment, which will depend on whether the noncompliance has been 

corrected and/or the release or discharge of hazardous waste has been 

adequately cleaned up; and 

(5) If the noncompliance has not been corrected, the anticipated period for 

which it is expected to continue, and the steps taken or planned to reduce, 

eliminate, and prevent the recurrence of the noncompliance. 

The Director may waive the requirement that written notice be provided within 5 calendar 

days; however, you will then be required to submit a written report within 15 calendar days 

of the day on which you must provide oral notice, in accordance with Conditions l.E.l4.a 

and I.E.14.b of this permit. (40 CPR§ 270.30(1)(6)) 

I.E.15 Other Noncompliance 

You must report all instances of noncompliance not reported under Condition I.E.I4 of this 

permit, when any other reports this permit requires are submitted. The reports 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 you become aware that 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 

VES016690 
OHD 980 613 541 

Page 8 of 28 

promptly notify the Director of any incorrect information or previously omitted 

information, submit the correct facts or information, and explain in writing the 

circumstances of the incomplete or inaccurate submittal. (40 CFR § 270.30(1)(11)) 

I.E.16.b All other requirements contained in 40 CFR § 270.30 not specifically 

described in this permit are incorporated into this permit and you must comply with 

all those requirements. 

I.F SIGNATORY REQUIREMENT 

You must sign and certify all applications, reports, or information this permit requires, or 

which are otherwise submitted to the Director, in accordance with 40 CFR § 270.11. (40 

CFR § 270.30(k)) 

I.G REPORTS, NOTIFICATIONS AND SUBMITTALS 

Except as otherwise specified in this permit, all reports, notifications, or other submittals 

that this permit requires to be submitted to the Director, the Regional Administrator, or to 

U.S. EPA should be sent by certified mail, 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 West Jackson 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 of submittal in the manner prescribed on the application form or 

instructions, or, in the case of other submittals, by stamping the words "Confidential 

Business Information" on each page containing such information. If you made no claim at 

the time of submittal, the Director may make the information available to the public 

without further notice. If you assert a claim, the information will be treated in accordance 

with the procedures in 40 CFR Part 2. (40 CFR § 270.12) 

1.1 DOCUMENTS TO BEMAINTAINED AT THE FACILITY 

You must 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 Operating Record 

OHD 980 613 541 

Page 9 of 28 

You must maintain in the facility's operating record the documents required by this permit, 

and by the applicable portions 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 

If you receive hazardous waste(s) from off-site generator(s), you must maintain 

notifications from generators accompanying initial incoming shipment of wastes subject to 

40 CFR Part 268 Subpart C, that specify treatment standards, as required by 40 CFR §§ 

264.73, 268.7, and this permit. 

1.1.3 Copy of Permit 

You must keep a copy of this 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, if any, 

including all plans and schedules are, upon the Director's approval, incorporated into this 

permit by reference and become an enforceable part of this permit. Since required items 

are essential elements of this permit, failure to submit any of the required items or 

submission of inadequate or insufficient information may subject you to enforcement 

action under Section 3008 ofRCRA. This action may include fines, or permit suspension 

or revocation. 

LJ.2 This permit also includes the documents attached hereto, all documents crossreferenced in these documents, and the applicable regulations contained in 40 CFR Parts 

124, 260, 261, 262, 264, 268, 270, and the applicable provisions ofRCRA, all of which are 

incorporated herein by reference. 

I.J.3 Any inconsistency or deviation from the approved designs, plans and schedules is a 

permit noncompliance. The Director may grant written requests for extensions of due dates 

for submittals required in this permit. 

I.J.4 If the Director determines that actions beyond those provided for, or changes to 

what is stated herein, are warranted, the Director may modify this permit according to 

procedures in Condition I.B of this permit. 

I.J .5 If any documents attached to this permit are found to conflict with any of the 

Conditions in this permit, the Condition will take precedence. 

VES016692 
LK COORDINATION WITH THE CLEAN Am ACT 

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 of the RCRA 

permit, you may handle the newly listed hazardous wastes, promulgated under the HSW A, 

at your facility ouly if you have processed a Class 2 permit modification in accordance 

with 40 CFR § 270.42(g). All handling of these wastes must comply with the provisions of 

the state-issued portion of the 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 of these wastes must also comply with ail provisions of the federally-issued 

portion of the RCRA permit. 

Hazardous Waste Numbers: Kl81 

SECTION III·- Am EMISSION STANDARDS FOR EQUIPMENT LEAKS 

(40 CFR Part 264, Subpart BB) 

III.A GENERAL 

III.A.l In accordance with 40 CFR § 264.1 064(m), if equipment 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 either by 

documentation pursuant to 40 CFR § 264.1064 of this subpart, or by documentation 

of compliance with the regulations at 40 CFR Part 60, 61, or 63. The 

documentation of compliance under 40 CPR Part 60, 61, or63 shall be kept with or 

made readily available with the facility operating record. 

III.A.2 If the Permittee elects to determine compliance with the regulations at 40 CFR Part 

264 Subpart BB by documentation of compliance 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 for periods 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 of equipment used in your facility would otherwise 

be subject to the requirements of 40 CFR Part 264, Subpart BB, and during which: 

VES016693 
OHD 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 equipment be operated 

monitored, and repaired in accordance with the standard; or 

III.A.3.c the standard does not require that appropriate records of such equipment 

be prepared and maintained; then: 

you must comply with and keep documentation of compliance in accordance with 

the requirement of 40 CFR Part 264 Subpart BB. 

III.A.4 The Permittee shall provide annually to the Director a certification describing the 

Permittee's election of compliance. 

III.B EQUIPMENT LEAKS (40 CFR Part 264, Subpart BB) 

The Permittee must process a permit modification and have it approved by the Director, 

prior to installation and operation of a compressor(s) which is (are) in contact with 

hazardous waste with organic concentrations of at least I 0 percent by weight. 

III.B.l Waste Determination and Equipment 

The Permittee must determine each hazardous waste stream for which (I) the hazardous 

waste is "In light liquid service" as defined in 40 CFR § 264.1031 and (2) the hazardous 

waste has an organic concentration of at least l 0 percent by weight. 

You must comply with all applicable requirements of 40 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 by the methods specified in 40 CFR § 264.1 063(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 § 

264.1 064(g)(2), for no detectable emissions, as indicated by an instrument reading 

ofless than 500 ppm above background, and for which the requirements of 40 CFR 

§ 264.1052(e) are satisfied, or (3) equipped with a closed vent system complying 

with the requirements of 40 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. 

VES016694 
OHD 980 613 541 

Page 12 of 28 

-III.B.2.c A leak is detected if. (1) an instrument reading of!O,OOO ppm or greater 

is measured, or (2) there is an indication ofliquid dripping from the pump 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. I 059 • Standards: Delay of repair. The frrst attempt at repair must be made no 

later than 5 calendar days after eacb leak is detected. 

III.B.3 Pressure Relief Devices in GasNapor Service (40 CFR § 264.1054) 

III.B.3.a Except during pressure releases, each pressure relief device in gas/vapor 

service shall be operated with no detectable emissions, as indicated by an 

instrument reading ofless than 500 ppm above background, based on the method 

specified in 40 CFR § 264.!063(c). (40 CFR § 264.1054(a)) 

III.B.3.b After each pressure release, the pressure relief device shall be returned to 

a condition of no detectable emissions (i.e., less than 500 ppm above background 

based on the method specified in 40 CFR § 264.1 063(c)), as soon as practicable, but 

no later than 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 of no detectable emissions, as 

indicated by an instrument reading of!ess than 500 ppm above background, as 

measured by the 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 relief device that is equipped with a closed-vent system 

capable of capturing and transporting leakage from the pressure relief device to a 

control device as described in 40 CFR § 264.1060 is exempt from the requirements 

in Condition III.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 without purges, shall collect the sample purge for return to the process or 

for routing them to the appropriate treatment system, and shall be equipped with a 

closed-purge, closed-loop, or closed-vent system which meets one of th<> following 

requirements: 

III.B.4.a Return the purged process fluid directly to the process line; 

IU.B.4.b Collect and recycle the purged process fluid; or 

IU.B.4.c Be designed and operated to capture and transport all the purged process 

VES016695 
OHD 980 613 541 

Page 13 of 28 

fluid to a waste management unit that complies with applicable sections of 40 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 line must 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 or line. 

m.B.S.b When a double block and bleed system is used, the bleed valve or line 

may remain open during operations that require venting the line between the block 

valves but shall seal the open end at all other times. 

III.B.S.c Each open-end valve or line equipped with a second valve shall be 

operated in a manner such that the valve on the hazardous waste stream eud is 

closed before the second valve is closed. 

m.B.6 Valves in GasNapor Service or in Light Liquid 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 If an instrument reading of I 0,000 ppm or greater is measured, a leak is 

detected. When a leak is detected, it must be repaired as specified in 40 CPR§§ 

264.1057(d) and (e). 

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 

(40 CFR § 264.1058) 

III.B.7 .a Pumps and valves in heavy liquid service, pressure relief devices in light 

liquid or heavy liquid service, and flanges and other connectors must be monitored 

within 5 days by the method specified in 40 CFR § 264.1063(b) if evidence of a 

potential leak is found by visual, audible, olfactory, or any other detection method. 

If an 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, 

but not later than 15 calendar days after it is detected, except as provided in 40 CFR 

§ 264.1059. The first attempt at repair shall be made no later than 5 calendar days 

after each leak is detected. 

III.B. 7 .c First attempts at repair include, but are limited to, the best 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 

exempted from monitoring and recordkeeping requirements, as specified in 40 CFR 

§ 264.1058(e). (40 CFR § 264.1058(e)) 

lll.B.S Delay of Repair (40 CFR § 264.1059) 

III.B.S.a Delay of repair of equipment for which leaks have been detected will be 

allowed if: (I) the repair is technically infeasible without a hazardous waste 

management unit shutdown (in such cases, repair of this equipment shall occur 

before the end of the next hazardous waste management unit shutdown); or (2) the 

equipment is isolated from the hazardous waste management unit and does noi 

continue to contain or contact hazardous waste with organic concentrations at least 

10% by weight. 

IIJ.B.S.b Delay of repair for valves will be allowed if: (1) emissions of purged 

material resulting from immediate repair are greater than the emissions like] y to 

result from delay of repair; and (2) when repair procedures are effected, the purged 

material is collected and destroyed or recovered in a control device complying with 

40 CFR § 264.1060. 

III.B.S.c Delay of repair for pumps will be allowed if: (I) repair requires the use of 

a dual mechanical seal system that includes a barrier fluid system; and (2) repair is 

completed as soon as practicable, but not later than 6 months after the leak was 

detected. 

III.B.S.d Delay of repair beyond a hazardous waste management unit shutdown 

wiJI be allowed for a valve only if provisions of40 CFR § 264.1059(e) are met. 

III.B.9 Closed-Vent Systems and Control Devices ( 40 CFR § 264.1060) 

Closed-vent systems and control devices used to meet the requirements of this 

Section III shall comply with the provisions of 40 CFR §§ 264.1033 and 264.1060. 

III.B.lO Alternative Standards for Valves in GasNapor Service or in Light Liquid 

Service; Percentage of Valves 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 other hazardous waste management unit) 

comply with an alternative standard that allows no greater than 2% of the valves to 

leak. If you elect to comply with this alternative standard, you must comply with 

the provisions of 40 CFR §§ 264.106l(b)and (c). 

VES016697 
OHD 980 613 541 

Page 15 of 28 

III.B.ll Alternative Standards for Valves in Gas/Vapor Service or in Light Liquid 

Service: Skip Period Leak Detection and Repair (40 CFR § 264.1062) 

You may elect for all valves subject to the requirements of 40 CFR § 264.1057 

within a hazardous waste management unit to comply with one of the alternative 

work practices specified below. If you elect to comply with one of the alternative 

work practices, you must comply with all the requirements for valves as described 

in III.B.6 of this 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 

of valves leaking equal to or less than 2 %, you may begin to skip one of the 

quarterly leak detection periods for the valves. 

III.B.U.b After 5 consecutive quarterly leak detection periods with the percentage 

of valves leaking equal to or less than 2 %, you may begin to skip 3 of the quarterly 

leak detection periods for the valves. 

You must monitor valve leaks monthly in accordance with 40 CFR § 264.1057, if 

the percentage of valves leaking is greater than 2 %, but you may again elect to use 

the alternative standards after meeting the requirements of 40 CFR 

§ 264.1057(c)(l). 

III.B.12 Test Methods and Procedures (40 CFR § 264.1063) 

The leak test methods and procedures must be 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 of 40 CFR 

§ 264.1064 and 264.1065. 

SECTION IV-- AIR EMISSION STANDARDS FOR TANKS AND CONTAINERS 

(40 CFR Part 264, Subpart CC) 

IV.A GENERAL 

IV.A.l If a hazardous waste management unit is equipped with and operating air emission 

controls in accordance with the requirements of an applicable Clean Air Act 

regulation under 40 CFR Part 60, 61, or 63, you may elect to exempt the unit from 

overlapping regulation under Section IV of this permit (except as specified in this 

Section N.A) if you provide a certification satisfying the requirements of 40 CFR § 

264.1 080(b )(7) that the hazardous waste management unit is equipped with and 

operating air emission controls in accordance with such requirements. Such 

VES016698 
OHD 980 613 541 

Page 16 of 28 

certi.fication must be renewed annually and shall specify the regulations under 40 

CFR Part 60, 61, or 63 that require the air emission controls. ( 40 CFR § 

264.1 080(b )(7)) 

IV.A.l.a As required by 40 CFR § 264.1 0890), you must retain at the facility for 

each such unit a copy of the 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 If the hazardous waste management unit 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 of 40 CFR § 

264.1084(i) or§ 264.1082(c)(5), as required by 40 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 of this 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 comply with the terms and conditions of this 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 or no longer requires that air emissions from the tank or 

container be controlled. 

When either condition in Condition N.A.3.a or IV.A.3.b occurs, you must 

immediately comply with the terms and conditions of this 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 of origination, and (2) treated hazardous 

waste, in accordance with the procedures specified in 40 CFR § 264.1083. 

IV.B.2 You must determine the maximum organic vapor pressure of a hazardous waste in 

VES016699 
OHD 980 613 541 

Page 17 of 28 

a tank is as-specified in 40 CFR §§ 264.1 084(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 air pollutant emissions from each hazardous 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 specifically provided 

otherwise in this permit The tanks used for storage of hazardous waste must be 

designed, constructed, and maintained consistent with applicable industrial 

standards to ensure their integrity and safety. 

lV.C.l.b You are authorized to store hazardous wastes with an average VO 

concentration at the point of origination of equal or greater than 500 ppmw in the 

following tanks, in accordance with the provisions of this permit: 

(I) Tank Farm (T-1 through T-18, PT-1 through PT-5) 

(2) Process Water Tanks (W-6 through W-8) 

(3) Bulk Feed Tanks (S-1 and S-2) 

(4) Laboratory waste (L-1) 

lV.C.2 Tank Farm 

The hazardous waste tank farm shall consist of the 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 

Blending Tank No. 2 

Blending Tank No. 1 

Sludge Tank No.2 

Sludge Tank No.I 

Solvent Tank (Formerly Liquid Reception Tank) 

Solvent Tank (Formerly Sludge Reception Tank) 

Organic Liquid Tank No.2 (Soluble Waste) 

Organic Liquid Tank No. I (Soluble Waste) 

Aqueous Liquid Tank No.2 

Aqueous Liquid Tank No. 1 

Organic Liquid Tank No.2 (Insoluble Waste) 

Organic Liquid Tank No. 1 (Insoluble Waste) 

Organic Liquid Tank No.2 (Chlorioated Waste) 

Organic Liquid Tank No. I (Chlorinated Waste) 

VES016700 
T-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 Tank No. 2 

Pwnpout Tank No. 3 

Sludge Reception Tank 

Overflow T264{) 

IV.C.2.a Air Emission Control Requirements 

OHD 980 613 541 

Page 18 of 28 

(I) The tanks in the hazardous waste tank fann must meet the Level 2 tank 

standards as stipulated under 40 CFR §§ 264.1 084(d)(3) and 264. I084(g)(l) 

through (3), including but not limited to the requirements to inspect and monitor the 

air emission equipment for the tank and keep records of the inspections. You must 

comply with the requirements of 40 CFR § 264.1 084(j). You must comply with the 

applicable requirements of40 CFR §§ 264.1088, 264.1089, and 264.1090 for such 

tanks. 

(2} All tanks must meet the industrial standards established for such tanks by the 

American Society of Mechanical Engineers (ASME), American Petroleum Institute 

(API), or other equivalent standards. 

(3) Each vent pipe from a storage tank must be connected to a common vent 

header, which is connected to the vapor recovery header. The combined vent 

stream is discharged via a ventilation header blower in the vapor recovery header 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 vapor recovery header must meet the 

requirements of a closed-vent system as defined in 40 CFR § 264.1084(d)(3) and as 

hereinafter specified. 

IV.C.2.b Operational Requirements 

(I) To prevent overflow of hazardous waste from the 300-gallon overflow tank PT5 (T2640) to the vent header, the overflow tank must 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 the pumpout tanks 

and sludge reception 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) The instrumentation and control system must be maintained as necessary to 

accurately monitor 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 be properly maintained and be. operational to prevent 

overloading of the control devices. In the event of a system malfunction, you must 

repair the system as quickly as practicable and maintain the repair record in the 

facility operating record. 

IV.C.3 Process Water Tanks (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), including but not limited to the inspection 

requirements and the requirement to keep records of the inspections. You must 

comply with the requirements of40 CFR § 264.10840) for such tanks. You must 

comply with the applicable requirements of 40 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 of 500 ppmw (parts 

per million weight) at the point of origination 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 of Condition IV.F, below, for 

each such tank in which hazardous waste is placed. 

IV.C.4 Bulk Feed Tanks (S-1 and S-2) 

IV.C.4.a Hazardous solid wastes delivered to the bulk feed tanks must be placed 

within the storage pits based on design factors such as angle of repose to prevent 

overflow. Hazardous wastes that are spilled or tracked inside the enclosure must be 

colJected and stored in the pits or managed in accordance with the state-issued 

permit. 

IV.C.4.b No hazardous wastes containing free liquids (as defined in 40 CFR 

§ 260.1 0) or treated with free liquids may be stored in Tanks S-1 or S-2. The 

presence of free liquids is determined by the 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 

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Page 20 of 28 

device (the incinerator and/or carlxm adsorption system) meeting the requirements 

of 40 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 greater than I 0 megagrams per year, as specified in 40 CPR 

§ 264.1 082( c)(5). The enclosure and control devices must have been installed and 

commenced operating before November 25, 1996. 

IV .C.4.d The enclosure must be designed and operated in accordance with the 

criteria for a petmanent total enclosure as specified in " Procedure T- Criteria for 

and verification of a Permanent or Temporary 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 of a 

Permanent or Temporary Total Enclosure" annually. 

IV.C.4.f You mustmeet the requirements of 40 CFR §§ 264.1088 through I 090 for 

Tanks S-1 and S-2. 

IV.C.S Laboratory Waste 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 at the point 

of waste generation equal or greater 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 of Condition IV.F of this 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 of the following: 

IV.D.l.a meets the applicable U.S. Department of Transportation (DOT) 

regulations as specified in 40 CFR § 264.1 086{1),. 

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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 

IV D.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(£) must be equipped with covers and closure devices suitable for the 

physical and chemical characteristics of hazardous waste in contalners, for 

malntaining container integrity throughout the life of the 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 compatible with the hazardous waste in the container. Vapor suppression 

chemicals must act as an acceptable and stable barrier to the hazardous waste, thus 

preventing release ofVO into the environment. The barrier 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 be in the closed position whenever 

hazardous waste is in a container. Opening of a closure device or cover is allowed 

if it meets the purposes and operates as provided in 40 CFR § 264.!086(c)(3)(i) 

through (v). 

IV.D.l.e You must inspect and repair the 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 m

3 

or greater 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 of the procedure that you used to detennine that the contalner is 

not managing hazardous waste in "light material 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 greater than 0.46 m

3 (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 container must be one of the following: 

(I) meets the applicable U.S. Department of Transportation (DOT) regulations as 

specified in 40 CFR § 264.1086(£), 

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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 of hazardous waste in or out of a contaioer must be conducted 

using an engineered method generally accepted and practiced by the industry, or its 

equivalent.method to minimize the release of organics 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 of a closure device or cover is allowed 

if it 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 must meet the applicable requirements of 40 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 to treat any hazardous waste in any container whose design 

capacity is greater than 0.1 m3 by waste 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 of this pennit 

shall meet all the requirements of 40 CFR Part 264, Subpart CC that are applicable 

to closed-vent system, including but not limited to 40 CFR § 264.1 087(b), and shall 

consist of: (I) a ventilation header blower, (2) vent piping from the hazardous waste 

storage tanks and the vapor recovery ductwork, (3) secondary vent blowers for the 

carbon adsorption systems, and ( 4) instrumentation and monitoring system. 

IV.E.l.b The ventilation header blower shall have a minimum capacity of 34,500 

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 .. 

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standard~ <lf SMACNA (Sheet Metal and Air Conditioning Contractors' National 

Association, Inc.), American Society of Heating, Refrigeration, and Air 

Conditioning Engineers (ASHRAE), or equivalent. Flexible hoses/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 

of the ventilation header blower), a pressure measurement device must be installed 

in each closed-vent ductwork at an accessible location to verify that a negative 

pressure is being maintained when the control device is operating. 

N.E.l.f For a closed-vent operating under positive pressure (i.e., discharge 

ductwork of the ventilation header blower, including the ductwork between 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 determined by the procedure in 40 CPR§ 264.!034(b), and by 

visual inspections. 

N.E.l.g The combustible concentrations in the vent streams must be maintained at 

less than 60% of the Lower Explosion Limit (LEL) of the vent stream to prevent 

fire and/or explosion. 

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 You must prepare and maintain records for the closed-vent system as 

specified in 40 CPR§ 264.1089 and shall make reports as specified in 40 CPR 

§ 264.1090. 

IV.E.l.j You must operate the closed-vent system in accordance with 40 CPR 

§ 264.1087(c)(2)(vi). 

IV.E.2 Operations of Ventilation Header Blower and Secondary Vent Blowers 

IV.E.2.a The ventilation header blower shall deliver the vent streams from each 

emission point to the carbon adsorption systems and/or the rotary kiln primary 

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 of the 

blowers. · 

IV.E.2.c Electrical interlockings must be provided to prevent potential fire and/or 

explosion due to high temperature and/or VO concentrations within the closed-vent 

system. 

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Page 24 of 28 

IV.E.3.a The control devices used to meet the requirements of this permit shall 

include: (I) a carbon adsorption system (Modules A & B), and (2) the rotary kiln . 

combustion system. The rotary kiln combustion system shall comply with the 

requirements of 40 CPR § 264. I 087( c), as applicable to 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 of I86 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 of granular 

activated carbon or 425 cubic feet in volume. Each carbon box shall be designed 

and operated to reduce by at least 95 %by weight the total volatile organic 

concentration of the inlet vent stream to the carbon adsorption system. Each carbon 

adsorption module must meet the requirements of 40 CPR § 264.1 087( c), as 

applicable to carbon adsorption systems. Prior to placing a carbon box back in 

service after the spent carbon has been removed, the Permittee shall ensure the 

carbon box contains fresh carbon in the quantity or volume identified in this 

Condition. 

IV.E.3.d Design of the carbon box shall be epoxy coated steel and gas-tight 

construction, or equivalent, capable of withstanding an air pressure of22" water 

column. All flexible connections for the carbon boxes must be designed and 

operated under air-tight condition based on the maxim tun working pressure of the 

vent streams inside the carbon box. 

IV.E.3.e The activated carbon box used in the carbon adsorption systems shall 

have a minimum temperature rating of 150 °F. The minimum pressure rating for the 

carbon box shall be 0.5 psig without causing structural damages. 

IV.E.3 .f Each carbon adsorption system must be monitored on a continuous basis 

by use of a continuous emission monitor system, as specified in Paragraph 17 

through 19 of the Consent Decree between U.S. EPA and Von Roll America in 

U.S. v. Von Roll America. Inc., No. 4:06CV2893 (N.D. Ohio), effective February 

2, 2007 ("Consent Decree"); which paragraphs are incorporated herein by reference. 

The existing carbon must be replaced with fresh carbon immediately when carbon 

breakthrough is indicated, as specified in Paragraphs 21 through 22 of the Consent 

Decree; which paragraphs are incorporated herein by reference. Carbon 

breakthrough is indicated as described in Paragraph 18 and 22 of the Consent 

Decree and is summarized as follows: 

(I) Breakthrough of carbon between ·each primary and secondary carbon 

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Page 25 of 28 

box is deemed to occur whenever Inter-Box Continuous Emission Monitor 

(CEMS) data equal to or greater than 50 ppm total hydrocarbons (THC) on a 

60-minute rolling average occurs. 

(2) Whenever breakthrough between a primary and a secondary carbon box 

occurs, you must change out the primary box within the 12 hour and 48 hour 

time limitations set forth in the applicable paragraphs of the current or most 

recent version of the Routine Maintenance Procedure that became effective 

under the terms of the Consent Decree; which paragraphs are incorporated 

herein by reference. 

If within I 5 days after having completed a change-out of a primary box, you 

experience an Inter-Box CEMS reading equal to or greater than 50 ppm 

THC on a 60-minute rolling average on the train that has been changed out, 

you are not required immediately to initiate and complete a new change-out 

of the primary box. Instead, as expeditiously as possible, you must initiate 

and complete an investigation of the cause(s) of the elevated Inter-Box 

CEMS reading to determine if the carbon within the primary box actually is 

spent or otherwise not functional and take the actions specified in Paragraph 

22 of the Consent Decree, as incorporated herein by Reference. 

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 be used to continuously monitor 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 of the Consent 

Decree which are incorporated herein by reference. 

IV.E.3.i You must maintain a copy of the activated carbon specifications in the 

operating file. When you decide to change the supplier of the 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 must be handled, disposed of, or regenerated as 

hazardous waste. 

IV .E.3.k Recordkeeping of the control devices shall be in accordance with 40 CFR 

§ 264.1089. 

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Page 26 of 28 

IV.E.4 Disposal of Spent Carbons 

IV.E.4.a On-Site Disposal 

(1) The Pennittee may dispose of the 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 (NFP A) Codes. 

(2) If a vacuum truck is utilized, the exhaust from the vacuum blower shall be 

treated by a mechanical cyclone with a dust filter, or an equivalent device, having a 

total dust removal efficiency of 85 %based on ASTM, National Bureau Staodards 

Atmospheric Dust Test Method, ASHRAE Method, or an approved method. 

(3) The area utilized for mechanical removal of spent carbon shall be so designated 

and designed to prevent run off from the spills of spent carbon. The Pennittee may 

propose an alternative .method equivalent to those described above. 

(4) The Permittee may propose an alternative method equivalent to those described 

above, subject to the approval of U.S. EPA. 

IV.E.4.b Off-Site Regeneration/Disposal of Spent Carbons 

The Pennittee may dispose of or regenerate the spent carbons off-site as hazanlous 

waste in accordance with the provisions of 40 CFR § 264.1 033(n) and all federal 

and state regulations 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 Consent Decree 

' 

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 1 permit modification request to delete this 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 

VES016709 
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Page 27 of 28 

§ 264.1082(c)(l), you must demonstrate by direct measurement or 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 of origination. 

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 of the initial determination. 

IV.F.3 For each such tank or container, you are subject to the requirements of 40 CFR 

§ 264.1082(d) and you must satisfY the applicable requirements of 40 CPR §§ 

264.1088 through 264.1090. 

IV.G INSPECTION, RECORD KEEPING AND REPORTING REQUIREMENTS 

The Permittee shall comply with all applicable inspection, recordkeeping and reporting 

requirements described in 40 CPR §§ 264.1088, 264.1089 and 264.1090. 

SECTION V --AIR EMISSION STANDARDS FOR MISCELLANEOUS UNITS UNDER 

40 CFR PART 264, SUBPART X 

V.A GENERAL 

The following Subpart X units are permitted under the State of Ohio Environmental 

Protection Agency's permit. These units, if installed 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!per Unit described in Condition V.B. below unless 

you first request and receive a modification to this permit to incorporate the requirements 

of 40 CFR Part 264, Subparts BB and CC that are appropriate for such unit, as required by 

40 CFR § 264.601. 

V.B Drum Extruder Pulper Unit 

V.B.l The drum extruder pulper unit consists of (I) a loading chamber, (2) a process 

chamber for extrusion and crushing of drums, (3) a crushed drum discharging chute 

VES016710 
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with double airlocks, and ( 4) a waste pulping tank 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 of this permit to a control device(s) that meets the 

requirements of Conditions IV.E.3 through IV.E.5 of this permit. The Permittee 

must ensure that there is no leak to the atmosphere when the unit is operating under 

a positive pressure. 

V.B.3 The drum to be processed shall enter the seal chamber and move to 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 The processing chamber and the pulping tank shall be provided with nitrogen to 

reduce the oxygen concentration in the chamber at or below 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 continuously monitored. 

When high liquid level is detected in the blending tank, operations of the extruder/ 

crusher unit shall stop. 

V.B.6 The drum extruder pulper unit must meet all applicable industrial safety standards. 

V.B.7 You must inspect and monitor the extruder pulper unit in accordance with 40 CFR 

§§ 264.602 and 264.1088. 

V.B.8 Recordkeeping of the extruder pulper unit shall be in accordance with 40 CFR 

§ 264.1089. 

VE5016711