## 2011 Addendum: An Assessment of

Environmental Problems Associated with Recycling of

Hazardous Secondary Materials

June 30, 2011

U.S. Environmental Protection Agency

Office of Resource Conservation and Recovery

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DISCLAIMER

Mention of trade names, products or services in this document does not convey, and should not be interpreted to convey, official EPA app roval, endorsement, or recommendation, or lack

thereof.

ACKNOWLEDGEMENTS

This addendum was funded and managed by the U.S. Environmental Protection Agency. Data collection and presentation were conducted by ICF International under contract to the

En vironmental Protection Agency.

Staff members of the Recycling and Generator Branch , Office of Resource Conservation and Recovery , EPA Headquarters were responsible for p roviding objectives of the addendum

, reviewing the methodology, helping to identify ca ses for further investigation, reviewing draft

write

- ups and drafting portions of the study . The EPA Work Assignment Manager wa s Amanda

Geldard

.

EPA was responsible for identifying potential cases, including those submitted through public

comment as part of the Definition of Solid Waste Rulemaking process. Staff of ICF International were responsible for investigating potential case s , assembling relevant information, contacting persons with knowledge of selected cases, and drafting descriptions of each cas e

.

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2011 Addendum: 

### An Assessment of Environmental Problems Associated with

Recycling of Hazardous Secondary Materials

I. Introduction

In January 2007

, U.S. Environmental Protection Agency (EPA) published An Assessment of Environmental Problems Associated with Recycling of Hazardous Secondary Materials (also know as the “environmental problems study” or “study”)

. This study was conducted as part of

EPA ’s effo rt to revise the current “definition of solid waste” under the Resource Conservation and Recovery Act (RCRA), as it pertains to recycling of hazardous wastes and other hazardous secondary materials

. In particular, t he information in this study was compiled to assist the Agency in making decisions as to the scope and substance of these regulatory revisions. Since the study was published in 2007, EPA has continued to assess new reports of environmental problems associated with the recycling of hazardous secon dary materials. A first addendum to the study was published in July 2008. Th is 2011 Addendum is EPA’s second update to the study.

II. Scope of the Study

The general goal of th e study is to identify and characterize cases of environmental damage that have been attributed to some type of hazardous material recycling activity, and that are relevant for the purpose of evaluating the impacts of th e DSW rulemaking e ffort. In this 2011 Addendum, EPA evaluated nine potential damage cases that were identified after the 2008 DSW final rule was published.

III. Methodology

The nine potential damage cases were collected from news media and from recent

enforcement cases th at were forwarded to us by state and EPA regional staff. For this addendum, we did not conduct a general search for additional damage cases and instead only e valuated those

that have been brought to our attention since we published the last addendum to the study in

2008.

EPA used the same methodology to evaluate the nine potential damage cases as we used for the 2007 environmental problems study and its 2008 addendum. Detailed information regarding EPA’s methodology can be found in the 2007 Environmental Problems Study

.

IV. Summary

Of the nine potential damage cases considered, five are determined to be new recycling damage cases fit to be included in this sec ond addendum to the study. Additionally, one potential damage case was already included in the 2007 study and we are providing an update to this damage case in this Addendum.

This Addendum includes the following Appendices :

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Appendix I : Additional Damag e Cases from Recycling of Hazardous Secondary Materials

This 2011 Addendum adds five new damage case site s and one update to a damage case included in the 2007 study. These damage cases were found to meet the scope of the original environmental problems st udy

. A summary of the a dditional damage case s and individual profiles are located in the Addendum’s Appendix I.

Appendix II : Additional Sites Considered But Not Included in the Damage Case Analysis In preparing the 20 11 Addendum, EPA identified and revi ewed t hree additional, potential damage cases, but decided they would not be included in the environmental problems study because the damage in each case was determined to be unrelated to recycling of hazardous secondary materials

. The Addendum ’s Appendix II contains a summary of sites considered but not included in the study.

Appendix III : Analysis of Recycling Damage Case F acilities that Are Also Intermediate

Facilities The analysis identified a total of two intermediate facilities out of seven included in

the 2011 addendum

. Although these facilities are intermediate facilities, both a lso manage some waste on site. EPA used the same methodology for determining intermediate facilities as

we did in the 2008 addendum

. The 2011 Addendum’s Appendix III includes a table of these

intermediate facilities.

# Addendum: A n Assessment of

Environmental Problems Associated with Recycling of

Hazardous Secondary Materials

Appendix 1: Additional Damage Cases from Recycling of

Hazardous Secondary Materials

### June 2011

i 

## Appendix 1 Contents Additional Damage Cases from Recycling of Hazardous Secondary Materials

Site Name State

Romic Environmental Technologies Arizona

Romic Environmental Technologies California

Hassan Barrel Company, Inc. * Indiana

American Iron Oxide Company (AMROX) Pennsylvania

Horsehead Re source Development Corporation Pennsylvania

Blue Ridge Solvents and Coatings, Inc. Virginia

* Damage cases are cited in An Assessment of Environmental Problems Associated with Recycling of Hazardous Secondary Materials (2007) and updated with new informa tion.

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

2 Site Name: Romic Environmental Technologies, Chandler (Romic Southwest)

EPA ID No.: AZD009015389

Address: 6760 West Allison Road, Chandler, AZ 85226

County: Maricopa

NPL Site: No

In CERCLIS Database: No

Site History and Description of Recycli ng Operation : Romic Environmental Technologies (Romic) operated an approximately three

- acre hazardous waste storage, treatment, and recycling facility in the

Lone Butte Industri al Park near Chandler Arizona. This industrial park is located within the Gila River Indian Community (GRIC), on lands held in trust for GRIC.

The facility began operation in 1975 under ownership of Southwest Solvents. In 1988, Romic purchased the facility from Southwest Solvents and continued operations, which were primarily sol vent recycling through distillation. The facility received on average about 13,000 tons of waste per year,

about half of which was cons idered hazardous by the USEPA. Wastes received by the facility came from a variety of industries, including dry cleaning, paint manufacturing, aerospace, and automotive industries. The facility also received household hazardous was tes from collection events. In addition to solvent recycling, the facility acted as an intermediate facility, including consolidating solids for o ff

- site transfer and disposal and conducting fuel blending. Other site activities included antifreeze recycling and other management methods. No wastes were disposed on site; all wastes were transferred off site for disposal or re

- use.

In 1981, Southwest Solvents submitted Part A of a RCRA hazardous waste permit application and was granted interim status by the USEPA. The facility continued to operate under interim status until Romic acquired the facility in 1988. At that time, Romic submitted a revised Part A application as well as the

more extensive Pa rt B application for a permit. The facility remained under interim permit status pending further review by the USEPA. During this period, Romic complied with a number of RCRA requirements including complet ion of a number of remediation activities to clean up contamination, and conducted a remedial investig ation (RI) in 2004. In 2005, Romic was fined $67,888 for multiple hazardous waste violations related to improper storage and labeling of hazard ous waste a nd other

violation. The company corrected the violations and also spent $100,800 on life

- saving equipment for the Gila River Indian Community Fire Department and air monitoring and meteorological equipment for the Gila River Indian Community Department of Environmental Quality.

Also in 2005, Romic submitted a fin al revised Part B application. However the landowner, GRIC, would not sign the application and therefore the permit application was denied in 2007. Romic then submitted a facility closure plan , w hich was approved in 2008. Romic is currently conducting site cleanup activities.

Description of Contamination: In 2007, the USEPA issued an Administrative Order of Consent
(AOC) to Romic to investigate contami nation on and around the site. It is believe d that the groundwater

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

3 contamination at the Romic facility may be related to the operations of Southwest Solvents, which
operated the facility prior to 1988 (3).

In accordance with a 1988 Consent Agreement, Romic conducted extensive soil cleanup upon

purc hasing the facility. However, a 2004 Remedial Investigation Report completed for the GRIC Department of Environmental Quality (DEQ) indicated that trichloroethylene (TCE), tetrachloroethylene (PCE), and 1,1

- dichloroethylene (1,1

- DCE) contamination in groun dwater was

above U

. S

. EPA Maximum Contaminant Levels (MCLs) close to and down gradient from the facility. Although the facility operated in an industrial park, its location is approximately 200 meters from a public drinking water well and up

- gradient from irrigation wells.

Due to the RCRA permit denial, Romic prepared a closure plan in 2008 for clean up of surface

contamination. Under this plan, Romic will remove all remaining wastes, clean and decontaminate remaining equipment and structures, a nd send the resulting waste off site for treatment and disposal. The estimated cost of this portion of the site cleanup is $900,000 (8). Information about the costs of earlier site remedial activities is not available from the sources used for this damage case. Ro mic is working with U.S. EPA and GRIC DEQ to further investigate and implement corrective actions to address ground water contamination (8).

Sources of Information:

1. USEPA. Facility Registry System, Facility Detail Report. Romic Environmental Technologies
Corporation Southwest. Accessed Online. May 2011:
http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_s ys_id_in=AZD009015
389&pgm_sys_acrnm_in=RCRAINFO

2. USEPA. Envirofacts, Multisystem, Romic Environmental Technologies Corp Southwest.
Accessed Online. May 2011:

htt p://iaspub.epa.gov/enviro/multisys2_v2.get_list?facility_uin=110000471249

3. USEPA. Region 9, Waste Programs. Romic Environmental Technologies Corporation
Southwest Hazardous Waste Storage and Treatment Facility. Accessed Online. May 2011:
http://www.epa.gov/region09/waste/romic/index.html#correctiveaction

4. USEPA. “Permit Series List.” RCRAInfo. May 2011.

5. USEPA. Region 9: Administrative Order On Consent. Romic Environmental Technologies
Corporation. Accessed Online. May 2011:
http://www.epa.gov/region09/waste/romic/index.html#correctiveaction

6. USEPA. Notice of Intent to Deny a RCRA Permit A pplication for Romic Environmental
Technologies Corporation

– Southwest. August 2007. Accessed Online. May 2011:
http://www.epa.gov/region9/waste/romic/pdf/proposed

- per mit

- decision.pdf

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

4 7. USEPA. News Release: EPA fines hazardous waste company on Arizona tribal lands $67,888.
August 2005. Accessed Online. May 2011:
http://yosemite.epa.gov/opa/admpress.nsf/9e50770d29adb32685257018004d06fd/9da557d9afa
35dde852570d8005e178a!OpenDocument&Highlight=0,romic

8. Romic Environmental Technologies Corp. Romic Southwest Facility. Closu re Plan. Submitted
to US Environmental Protection Agency Region 9. August 2008. Accessed Online. May 2011:
http://www.epa.gov/region09/waste/romic/pdf/RSW

- Cl osure

- Plan

- final

- August

- 2008.pdf

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

5 Site Name: Romic Environmental Technologies, E. Palo Alto, CA

EPA ID No.: CAD009452657

Address: 2081 Bay road, East Palo Alto, CA, 94303

County: San Mateo

NPL Site: No

In CERCLIS Database: CAN000908403

Site History and Description of Recycling Operation : The Romic Environmental Technologies (Romic) facility in East Palo Alto, California, is a 12.6

- acre former hazard ous waste management facility. It is located in an industrial area approximately half m ile we st of San Francisco Bay. The facility fence line borders tidal marshes and other industrial facilities. The nearest residences are about 2,000 feet to the west, with the closest school being about a half mile.

The site first began operation as a chemical storage facility under previous owners in 1956. Romic began operating the facility in 1963, purchased it in 1979, and continued to opera te it until it closed in

2007. Romic performed a combination of hazardous waste storage, treatment, and recycling oper ations and received hazardous waste from a number of industrial business, including wastes such as paint thinner and paints, antifreeze, oils, inks, adhesives, and solvents. Waste management methods included storage, solvent recycling using distillation, i nci neration, and other treatment. In addition, waste management method information included in the facility’ s biennial hazardous waste reports indicate that the facility also served as an intermed iate facility for some wastes. Prior to closure, the facilit y managed an estimated 35,000 tons of waste per year.

The Romic facility has a history of violations and incidents including a 2006 tanker truck spill, employee burn incidents in 2004 and 2006, an d a 2007 transporter incident. The 2006 spill involved
4,00 0 gallons of used, mixed organic solvents, including hydroxylamine, monoethanolamine, tol uene, and acetronitrile. The solvents began reacting inside the tanker truck resulting a release of a fine mist that settled over an empty lot owned by Romic, portions of Bay Road, and adjacent parcels that included a Pacific Gas and Electric (PG&E) subst ation and nearby wetlands. In both of the burn incidents, employees were burned by ignitable vapors that were not properly draine d from tanks other equipment. In the 20 07 transporter incident, a highway exit ramp in Bakersfield, California, was shut down for several hours due to leakage from a truck containing drums shipped from the Romic facility.

The facility also was subject to a 2005 settlement with the California De partment of Toxic Substances Control (DTSC) for a number of violations that occurred from 1999 to 2004. Because of this history of violations, in 2007 the DTSC ordered Romic to close the facility a nd implement its cleanup plan. The facility stopped accepti ng waste in 2007, and all stored hazardous waste was removed from the site that

year.

Description of Contamination: DTSC and U

. S

. EPA site investigations concluded that Romic’s operations contaminated soil and groundwater across most of the site and to a depth of at least 80 feet. The primary contaminants are volatile organic compounds (VOCs), such as the solvent trichloroethene. The soil and groundwater contamination is primarily attributed to the spills, overflows, flooding events,

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

6 and other acciden tal releases around the central process area. A groundwater extraction and treatment system was operated as a site remediation strategy from 1993 until 2005. From 2003

– 2005 Romic conducted enhanced reductive dechlorination to remediate groundwater.

Fol lowing closure in 2007, the DTSC, U

. S

. EPA, and Romic agreed to a closure and cleanup plan for the facility consisting of two phases. Phase 1, which was overseen by DTSC and was completed in 2010, involved the closure, cleaning, and removal of the abovegr ound waste management units and equipment, as well as and cleanup of surface contaminatio n. Phase 2, which is underway with U

. S

. EPA supervision, addresses the remediation of subsurface soil and groundwater. The Final Remedy to address soil and groundwater contamination will use enhanced biological treatment, monitored natural attenuation, excavation

, and removal of contaminated soils, land use restrictions, and maintenan ce of the existing site cover. The estimated cost for closure and c leanup of the facili ty is $2.5 m illion.

Sources of Information:

1. USEPA. Facility Registry System, Facility Detail Report. Romic Environmental Technologies
Corporation. Accessed Online. May 2011:
http://iaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=CAN000908
403&pgm_sys_acrnm_in=CERCLIS

2. USEPA. Superfund Site Information. Romic East Palo Alto. Accessed Online. May 2 011:
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0908403

3. USEPA. Pacific Southwest, Region 9, Waste. Romic Environmental Technologies, East Palo

Alto, CA. Acce ssed Online. May 2011: http://www.epa.gov/region9/waste/romic

eastpaloalto/#moreinfo

4. USEPA. “Permit Series List.” RCRAInfo. May 2011.

5. California Department of Toxic Substance C ontrol. Fact Sheet. Romic’s Draft Closure Plan
Open for Public Comment. April 2008. Accessed Online. May 2011:
http://www.dtsc.ca.gov/HazardousWaste/Projec ts/upload/Romic_FS_DClosurePlan_0408.pdf

6. USEPA. US EPA Selects Final Cleanup Plan for Former Romic East Palo Alto Facility. July

2008. Accessed Online. May 2011: http://www.epa.gov/region9/waste/romic

eastpaloalto/pdf/Romic

- Final

- Decision

- FactSheet

- Eng

- 0708.pdf

7. Final Draft: Comprehensive Site

- Wide Sampling and analyses Plan, Former Romic
Environmental Technologies Corporation Facility. Pre pared for Bay Enterprises, Prepared by

Iris Environmental. March 2011. Accessed Online. May 2011:
http://www.epa.gov/region9/waste/romic

- eastpaloalto/pdf/ romic

- epa

- samp_anal

- plan.pdf

8. California Department of Toxic Substance Control. Romic Environmental Technologies
Corporation, Enforcement Order. 2007. Accessed Online. May 2011:
http://www.dtsc.ca.gov/HazardousWaste/Projects/upload/ROMIC_ENF_EO_2007.pdf

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

7 9. Official Announcement and Shut

- down order on Romic. Palo Alto Online. May 2007.
Accessed Online. May 2011: http://www.paloaltoonline.com/news/show_story.php?id=5146

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

8 Site Name: Hassan Barrel Company Inc

EPA ID No.: IND078902202

Address: 1605 Summer Street, Fort Wayne, IN, 46857

County: Allen

NPL Site: No

In CERCLIS Database: INN00050994 2

Site History and Description of Recycling Operation : From 1954 to 2003, the Hassan Barrel Company in Fort Wayne, Indiana, operated as a barrel recycling facility that cleaned and repa inted used

industrial barrels. During its years of operation, the seven

- acre facility received barrels, many containing hazardous wastes , from at least 400 companies. The facility closed in 2003 and the facility

owner abandoned thousands of barrels and other hazardous waste on the site.

Management of waste at the site included disposal in open pits and manmade lagoons, both in drums and discharges of liquids (l). The company did not have a RCRA Treatment, Storage and Disposal permit, and the State of Indiana had cited the company for a number of state viol ations be tween 1982

and 2003. Citations had been issued by the state for improper records, lack of emergency planning, and improper container marking or labeling, among other issues.

Description of Contamination: The facility was located in a residential area, surrounded primarily by private homes and two sc hools only a few blocks away. EPA’s site investigation found hazardous wastes at locations around the site, including wastes in leaking barr els, dumpsters, and open pits. EPA testing of soil and water in an onsite ditch that flowed to a nearby stream were contaminated with a number of hazardous materials including barium, cadmium, chrom

ium, lead, and traces of PCBs. EPA also determined from seized records that testing on the site while still in operation had found dichloroethene, tetrachloroethan e and

trichloroethene in soil. EPA commenced emergency cleanup of the facility under C ERCLA authority, spending $1.7 m

illion between 2004 and 2008, and removing 10,000 barrels, about half of wh ich

contained hazardous w aste. As of 2008 EPA expected at least another $1.3 m illion to removing up to 10,000 cubic yards of contaminated soil and other waste.

In 2008 Alan Hersh, the president of Hassan Barrel Company, pleaded guilty to one felony RCRA violation for the illeg al storage and management of hazardous wastes on the site. This sentence included 15 months in prison and a $1.7 m illion dollar fine for the EPA for cleanup costs. In addition, EPA is seeking additional funding for cleanup costs from about 400 companies th at sent materials to the facility.

Sources of Information:

1. Iacone, Amanda. Waste has property over a barrel: County Not Jumping to buy Chemically

Tainted Site . The Journal Gazette. May 24 2009. Accessed Online. May 2011:
http://www.journalgazette.net/article/20090524/LOCAL/305249918/1002/LOCAL

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

9 2. Stockman, Dan. Used

- barrel business leaves Toxic L egacy. The Journal gazette. March 8 2009.
Accessed Online. May 2011:
http://www.journalgazette.net/apps/pbcs.dll/article?AID=/20090308/LOCAL10/303089920

3. Fort Wayne Recycler Gets Jail Time. Wane.com. March 3 2009. Accessed Onlin e. May 2011:
http://www.wane.com/dpp/news/local_ap_toxic_waste_sentencing_200903030725_rev1

4. USEPA. Superfund Site Information. Hassan Barrel Site. Accessed Onl ine. May 2011:
http://cumulis.epa.gov/supercpad/cursites/cactinfo.cfm?id=0509942

5. USEPA. Region 5 Enforcement and Compliance. March 2009 Significant cases. Accessed

Online. May 2011: http://www.epa.gov/region5/enforcement/cases/cases200903.html#fort

6. USEPA. “Permit Series List.” RCRAInfo. May 2011.

7. USEPA. On Scene Coordinator, Pollution Report Profile. Hassan Barrel Company. Accessed
Online. May 2011:
http://www.epaosc.org/site/polrep_profile.aspx?site_id=1136&counter=1846

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

10 Site Name: American Iron Oxide Company (AMROX)

EPA ID No: PAR000008367

Address: 2 Wheeling Pittsburgh Steel Drive, Allenport, PA 15412 County: Washington

NPL Site: No

In CERCLIS Database No

Site History and Description of Recycling Operation: The AMROX facility in Allenport,

Pen nsylvania, began recycling spent pickle liquor from steel manufacturing in 1995 and the facility

curre ntly continues this operation. Pickle liquor contains hydrochloric acid and is used in steelmaking to remove iron scale buildup from the surfa ce of the st eel. AMROX recycles spent pickle liquor into hydrochloric acid and iron oxide.

AMROX uses a pyrohydrolysis to generate an 18% by weig ht hydrochloric acid solution. AMROX also uses an IROX process to remove silica and metals from the spent pickle liquor i n order to produce a higher purity iron oxide.

From 1995 until 1999, AMROX accepted spent pickle liquor under two regulatory mechanisms: Spent pickle liquor from designated generators that met certain chemical parameters was deemed a 'co

product' and was exempt from Pennsylvania Department of Environmental Protection’s (PADEP) requirements pertaining to solid and hazardous waste. Spent pickle liquor that was not deemed a co

product, either because it did not meet the designated chemical parameters or was not produced by a designated generator, was accepted by AMROX as a hazardous waste pursuant to a 'hazardous waste storage permit

- by

- rule.'

PADEP adopted most of the EPA RCRA regulations in 1999, eliminating the regulations under w hich AMROX had been ope rating. At that point, PADEP allowed AMROX to continue recycling spent pickle liquor under a variance authorized under 40 CFR 260.31(b).

Although the PADEP believes that the facility would qualify as a recycler of hazardous secondary materials, AMROX has not submitted a noti fication for this designation. However, the variance only allows AMROX to accept spent pickle liquor from specific generators , rather than any "h azardous secondary materials." The variance requires that to qualify as legitimate recycle r AMROX must demonstrate that it sells the produced iron oxide and returns the regenerated acid back to the steel plants.

Description of Contamination: In September 1997, AMROX allowed hazardous waste sludge from their IROX process to spill onto the gro und. Instead of properly containing and collecting this release, AMROX washed the waste into an adjacent railroad bed. PADEP fined AMROX $55,000 for this

violation. In 2004, AMROX's two storage tanks failed and spilled the spent pickle liquor into the

surr ounding asphalt

- paved area and into the storm drain. The storage tanks are located only 50 feet from a playground (see Figure 1). DEP was also concerned about air pollution from metals in the spent pickle liquor which is why the variance contains limits on metal concentration in the spent pickle liquor

. PADEP entered into a consent order and agreement with AMROX in August 2005 under which AMROX agreed to resolve various tank and waste issues, including establishing an inspection/repair

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

11 schedule the remai ning acid tanks. In 2006, PADEP fined AMROX $150,000 for outstanding air,
waste, and water violations involving the release of acid and iron oxide into the environment

.

On Aug. 11, 2009, PADEP discovered a 32,000

- gallon discharge of pickle liquor during a routine site visit. The discharge mixed with process water and stormwater to flood the conta inment unit beneath

the tanks. Tests taken around the tanks at the time of the discovery indicated pH levels ranging from zero to one, a range consistent with hyd rochloric acid, which is a major component of the pickle liquor AMROX manages.

Figure 1. Ruptured Tank at the AMROX Facility and Nearby Community Playground

PADEP reviewed the company’s inspection records and learned of multiple and persistent leaks from five of the ten tanks in operation from May 23 to August 6, 2009. These issues were in addition to defects that have required repair over the previous four years, including interior and exterior cracks and patch failures.

On or about April 18, 2011 , an aboveground storage tank at the facility split open, releasing approximately 27,300 gallons of regenerated hydrochloric acid solutio n, with a pH of less than 1.0. At the time of the release, the emergency containment area at the facility contained acc umulated water and was not able to contain the released volume of hydrochloric acid, and hydrochloric acid overflowed from the emergency containment area.

PADEP issued an Administrative Order on April 27, 2011, requiring AMROX to evaluate several acid

tan ks at the facility. Among other things, the April 27, 2011 Administrative Order required AMROX to

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

12 reduce the volume by half within eight remaining tanks, and demonstrate that it would be safe to allow

the t anks to continue in operation. AMROX did reduce th e contents of the tanks to 50% of their capacity, but failed to document the integrity and fitne ss for operation of the tanks. On May 11, 2011, PADEP and a retained expert inspected the failed tank and could not identify an obvious cause for the

fai lure. O n May 5 and May 11, 2011, the PADEP observed acid continuing to leak from various tanks, as well as deteriorated concrete supports benea th one or more of these tanks. On May 12, 2011 PADEP

ordered AMROX to empty several older acid tanks. AMROX subsequently provided an engineering analysis that with the installation of additional reinforcing bands around each tank that the tanks would remain structurally sound at 50% capacity. PADEP issued a third order on May 18, 2011 requiring an

accelerated series of tank inspections and a failure analysis of the damaged tank.

Sources of Information:

1. AMROX Commonwealth Court Decision. Excerpt provided by EPA.

2. AMROX EHB decision. Excerpt provided by EPA.

3. Commonwealth of Pennsylvania Department of Environmental Protecti on. “American Iron Oxide to Pay $150,000 to Settle Outstanding Violations.” 24 October 2006.

http://www.portal.state.pa.us/portal/server.pt/community /newsroom/14287?id=1040&typeid=1

4. Commonwealth of Pennsylvania Department of Environmental Protection. “DEP Orders
AMROX to Allow Independent Above Ground Tanks Inspections.” 31 August 2009.
http://www.portal.state.pa.us/portal/server.pt/community/newsroom/14287?id=2348&typeid=1

5. Commonwealth of Pennsylvania Department of Environmental Protection. Order in the matter
of American Iron Oxide Company, Allenport Borough, Washington County, Storage Tank and
Spill Prevention Act, Enf. Id No. 270438. 12 May 2011.

6. Leadbetter, Honorable Bonnie Brigance. Opinion in the Commonwealth Court of
Pennsylvania, Wheeling

- Pittsburgh Steel Corporation and American Iro n Oxide Company,
Petitioners v. Department of Environmental Protection. 6 August 2009.
http://www.aopc.org/OpPosting/Cwealth/out/1297CD08_8

- 6

- 09.pdf

7. Spadaro, Carl. Commonwealt h of Pennsylvania Department of Environmental Protection.

Personal communication (email) with Amanda Geldard, U.S. Environmental Protection
Agency, March 12, 2010.

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

13 Site Name: Horsehead Corporation

EPA ID No: PAD004372363, PAD981110570

Address: 300 Fr ankfort Road, Monaca, PA 15061 County: Beaver

NPL Site: No

In CERCLIS Database PAD981110570 (Archived site)

Site History and Description of Recycling Operation: The Horsehead Corporation’s facility in Monaca, Pennsylvania, operates as a secondary zi n c smelter. Located 28 miles north of Pittsburgh, the electrothermic zinc smelter at this facility began operation in the 1920's to produce zinc metal and zinc oxide, including recycling materials containing zinc. For several years to the present, this faci lity only uses secondary zinc materials such as dross and skims from galvanizing operations as well as recycled K061 electric arc furance dust as feedstock for zinc smelting. In 1996, PADEP clarified that these zinc secondary materials would be classified as coproducts under the current PADEP waste regulations. At present, those secondaries that might exhibit a hazardous characteristic for lead or cadmium leachability would be classified as by

- products being reclaimed (40 CFR 261.2(c)(3)). Horsehead’s zinc secondaries outdoor storage area has been subject to periodic wind dispersal and contaminated run

- off problems.

Description of Contamination: On July 22, 2010, there was an explosion at the zinc refinery resulting

in the death of two people

. No fire or offsite contamination has been document ed as result of this

incident. The cost of repairs and cleanup totaled $6.8 million for the refinery explosion. Following the explosion, the zinc refinery was shut down for repairs and an investigation and assessment of the damage. The cause of the explosion is still under investigation. Each of the ten columns used to produce zinc oxide and refined zinc metal in the refining facility have since been redesigned and rebuilt, and production resumed in the fou rth quarter of 2010. As stated above, Horsehead’s zinc secondaries storage area has had periodic wind dispersal and run

- off problems.

Sources of Information:

1. Horsehead Corporation. Monaca, PA. Retrieved May 24, 2011, from
http://www.horsehead.net/facility_content.php?ID=12

2. SEC Filings. (2011, March 16). Horsehead Holding Corp. Retrieved May 24, 2011, from
http://www.sec.gov/Archives/edgar/data/1385544/000095012311025813/l42109e10vk.htm

3. WTAE. (2010, July 26). Explosion at Horsehead Zinc Plant Kills 2; Victims Identified.

WTAE.com. Retrieved May 24, 2011, from http://www.wtae.com/r/24357952/detail.html

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

14 Site Name: Blue Ridge Solvents and Coatings, Inc.

EPA ID No: VAR000503656

Address: PO Box 759, Henry, Virginia 24102 County: Franklin

NPL Site: No

In CERCLIS Database No

Site History a nd Description of Recycling Operation: Established in 2002, Blue Ridge Solvents & Coatings, Inc., manufactures and delivers industrial chemicals, paints, lacquers, thinners, powder coating, and water treatment chemicals. The company also recycles solvent s using distillat ion and thin film evaporation. The facility contains storage and mixing tanks and solvent recovery equipment.

On April 7, 2010 the Commonwealth of Virginia Department of Environmental Quality (VADEQ) conducted a compliance evaluation of the facility, and found that the facility had failed to maintain

reco rds required under its permit. These records include monthly inspections for the fabric filter, logs of monitoring device observations for the thin film evaporator and microwave distilla tion unit, monthly and annual Hazardous Air Pollutant and Volatile Organic Compound (VOC) emissions, and scheduled

and non

- scheduled maintenance and operator traini ng. The facility agreed to pay a $7,826 fine to settle

the violations. A fire occurred at th e facility on June 4, 2010, causing property damage and requiring the evacuation of nearby homes.

Description of Contamination: On June 4, 2010 a fire started occurred in a mixing room, resulting in explosions from pr opane cylinders and chemicals. Fire fighters extinguished the blaze within two hour s. No injuries were reported. The fire was contained to the mixing room, which is a block and concrete building with a steel roof. A portion of the roof collapsed, but the storage tanks inside the room held

t heir contents. Adjacent sections of the building sustained smoke and water damage.

Twenty residents who lived within a quarter

- mile of the facility were evacuated from their homes and taken to emergency shelters for about two hours while firefighters ba ttled the fire.

USEPA Region III and VADEQ are considering whether additional information or sampling at the facility is required or if corrective action is required by the facility.

Sources of Information:

1. Commonwealth of Virginia Department of Envi ronmental Quality. State Air Pollution Control

Board Enforcement Action

– Order by Consent Issued to Blue Ridge Solvents & Coatings, Inc.

24 June 2010.
http://www.deq.virginia.gov/export/sites/default/enforcement/finalordersII/BRSCJune282010.p

df

2. Wagoner, K.A. The Franklin News Post . “BREAKING NEWS: Fire forces evacuation of 20
Henry residents.” 4 June 2010. http://www.thefranklinnewspost.com/article.cfm?ID=16449

### Addendum Appendix 1 June 2011

Additional Damage Cases f rom Recycling of Hazardous Secondary Materials

15 3. U.S. Environmental Protection Agency. “Blue Ridge Solvents and Coatings.” 28 June 2010.
http://www.epa.gov/reg3wcmd/ca/va/pdf/vad003124625.pdf

# Addendum: A n Assessment of

Environmental Problems Associated with Recycling of

Hazardous Secondary Materials

Appendix 2: Additional Sites Considered B ut

N ot Included i n the Damage Case Analysis

### June 2011



## Appendix 2

Additional Sites Considered But

Not I ncluded in the Damage Case Analysis

Site Name State EPA/ RCRA ID Reason Rejected



### Bayer Cropscience, LP West Virginia WVD005005509 Damage Unrelated to Recycling Environmental Quality Company North Carolina NCD982170292 Damage Unrelated to Recycling

Agri um Hartsville Rainbow Operations South Carolina SCD003350675 

### Damage Unrelated to Recycling

# Addendum: An Assessment of

Environmental Problems Associated with Recycling of

Hazardous Secondary Materials

Appendix 3: Analysis of Recycling Damage Cases that

Are Also Intermediate Facilities

### June 2011

- 1

- Analysis of Recycling Damage Cases that Are Also Intermediate Facilities

Site Name BR Indicates

Intermediate Facility Damage Case Study Text

Indicating Intermediate Facility

Romic Environmental Technologies , AZ Yes

Romic Environmental Technologies , CA Yes