GENERAL AMERICAN TRANSPORTATION CORPORATION

January 30, 1996

MEMORANDUM

RE: Request for Non-Significant Change to Saegertown Record of Decision, asmodified by the Explanation of Significant Differences

Introduction

This document serves as General American Transportation Corporation's (GATX) formal

request for EPA to change the off-site incineration remedy for the Saegertown site from cement

kiln to a utility boiler for two categories of remaining waste materials. As detailed below, this

change affects only the type of incineration unit used for processing the remaining materials and

is otherwise substantively identical to the cement kiln option discussed in the Explanation of

Significant Difference (ESD). For this reason, GATX believes the shift from a cement kiln to a

utility boiler constitutes a non-significant change and, in accordance with applicable procedures,

this minor change may be documented in the post-decision documents.

Discussion

GATX proposes to treat the remaining category (1) and (2) contaminated soils at the

Illinois Power Plant facility in Baldwin, Illinois, operated by Kipin Industries, Inc. This brand

new plant has one pulverized coal boiler and two coal-fed cyclone boilers. The cyclone boilers

make up the thermal treatment operation.

The following chart compares the Illinois Power Plant with a typical cement plant in regard

to the treatment of contaminated soil:

AR305H8

GENERAL AMERICAN TRANSPORTATION CORPORATION

-2-

Temperature

Gas RetentionTime

Injection

Residual

Destructionremoval efficiency

Waste Analysis

Treatment Rate

15000 to 27000

2-5.0 seconds

Depending on VOC/SVOCconcentration injection zonelimited

Kiln dust must be disposedas solid or hazardous waste,depending uponcharacteristics

99.99%

Pre-acceptance analysisrequired.

Less than 1 ,000 tons perweek

25000F - SOOOoF

5.2 to 6 seconds

Direct into highest heat zoneimmediately upon injection

Ash drops into molten both (2,000oF) and discharges in glassified slagstate. Ash exempt per 40 C.F.R.§ 261.4(b)(2)4. The slag is quenchedand sold as roofing shingles.

Better than 99.99%

In-depth analysis prior to acceptancemeeting or exceeding RCRAregulations.

600-1050 tons per day (5% of coalfeed).

As GATX has learned over the last six months, a cement kiln's ability to burn organic-

contaminated soil is in fact limited. The chief reason for this limitation, we have learned, relates

to the kiln operator's difficulty of injecting low BTU solid material into the unit. These soils

cannot be placed into the hot end of the kiln because they possess insufficient heating value; the

soils cannot be placed into the cold end without causing the organic constituents to volatize before

the destruction zone, thus risking the violation of air emission limits.

In contrast to the technical difficulties cement kiln operators have encountered when trying

to burn coal-tar contaminated soils, these materials are well-suited for destruction in a utility

boiler. In essence, waste coal tar constituents are the same as coal tars in raw coal. Gas, oil, and

GENERAL AMERICAN TRANSPORTATION CORPORATION

-3-

coal tars are essential ingredients in the combustion of coal. Gas ignites immediately giving off

heat to burn the oil, which in turn heats the tars; last, the coke (carbon) burns, leaving only ash.

Adding coal tar wastes to the coal feed reuses a waste material in place of a fossil fuel and

therefore conserves natural resources.

The technical ability of power plants to burn coal-tar contaminated soils is well-recognized

in the literature and in the Superfund program. For example, at the Peoples Natural Gas Co. site

hi Dubuque, Iowa, EPA identified the principal threat as buried coal tar waste and cyanide-bearing

woodchips. EPA's selected remedy included excavation of the coal tar wastes and incineration at

an off-site power plant. EPA noted, "Incineration is a proven technology for coal tar wastes and

a trial burn conducted at a power plant boiler has demonstrated it can achieve the RCRA

destruction efficiency for site-derived coal tar wastes." Similarly, at the St. Louis River site in

Duluth, Minnesota, the selected remedy included excavating visible tar seeps and disposing of the

waste at a coal-fired power plant, a steel blast furnace, a cement kiln, or similar facility. EPA

noted that the "burning process would destroy the [carcinogenic PAHs] in the tar, while allowing

the benefit of energy recovery from the high BTU values present in the tar." In this ROD,

therefore, EPA found that a power plant gave similar performance to a cement kiln in treating coal

tar waste.1 In its evaluation of the remedial alternatives, which included incineration, EPA found

that the power plant alternative provided the "best balance of trade-offs among the alternatives

with respect to the nine criteria that EPA uses to evaluate alternatives." For example, with regard

to implementability, EPA noted that the power plant alternative "has few associated administrative

1 The power plant mentioned in the St. Louis ROD, however, would not accept coal-tarcontaminated soil, but Illinois Power will.

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GENERAL AMERICAN TRANSPORTATION CORPORATION

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difficulties that could delay implementation. The remedy has been used successfully to address

similar problems at similar facilities."

Balancing Criteria

In the March 9, 1995 Explanation of Significant Differences (ESD), EPA determined that

under the NCP, a change in the remedy set forth hi the ROD was warranted. EPA found that no

ROD modification was required because the change affected only the location of the thermal

treatment process, and not the actual remedy. Here, no significant change occurs because only

the type of thermal process, and not its location, changes. In addition, the use of a utility boiler

satisfies the NCP balancing criteria in the same manner as was originally contemplated for the

cement kiln option.

Overall Protection of Health and the Environment

Like the off-site cement kiln option, the utility boiler is capable of destroying organic

contaminants in the waste, and because the remedy occurs off-site, no residues are left on-site.

Compliance with ARARs

None of the contaminated soil destined for off-site incineration is a hazardous waste under

the Resource Conservation and Recovery Act (RCRA). Therefore, the use of a RCRA permitted

facility to manage the soil is not legally applicable. See 40 C.F.R. § 300.400(g). Under nearly

identical facts, EPA Region VII, in the ROD for the Peoples Natural Gas Site, found that only

substantive requirements of RCRA need be met for non-hazardous coal tar waste. The main

substantive requirement, EPA noted, is the DRE of 99.99% (For RCRA wastes, EPA said that

both the administrative (i.e., permitting) and substantive requirements must be met. Peoples Gas

ROD, at p. 23.) Because the Illinois Power Plant exceeds the DRE of a RCRA incinerator or

AR305U5I

GENERAL AMERICAN TRANSPORTATION CORPORATION

- 5 -

cement kiln (Attachment A), it meets this important element of the RCRA substantive

requirements. In addition, as set forth in the above table, the power plant meets the other

pertinent substantive elements of RCRA. Because the coal tar waste is not hazardous, however,

the administrative requirements of RCRA are inapplicable as EPA noted hi the Peoples Gas ROD.

Short- and Long-Term Effectiveness '.

Like the off-site cement kiln option, the use of the Illinois Power Plant will cause no threat

to workers or nearby residents. Also, the power plant constitutes the fastest total remedy.

With respect to long-term effectiveness, the utility boiler possesses a distinct advantage

over a cement kiln. RCRA permitted cement kilns, by definition, burn hazardous waste.

Therefore, cement kiln operators must test their kiln dust to determine whether the waste-burning

activities significantly affect the character of the residue. 40 C.F.R. § 266.112. If the kiln dust

residues are significantly affected, the kiln operator must manage the dust as a hazardous waste.

Id- If the dust is not affected by the burning activities, the kiln operator must nonetheless manage

the dust as a solid waste. Id.

Residues generated primarily from the combustion of coal or other fossil fuels are exempt

from the definition of hazardous waste through the Bevill Amendment. See 40 C.F.R. §

261.4(b)(2)(4). Consequently, the use of a non-hazardous utility boiler to bum the coal tar waste

results in the production of less potential hazardous waste. In addition, as noted in the table

above, Illinois Power processes the ash into a useable product (roofing shingle) and therefore

produces no solid waste either. Thus, even less residual risk exists using the utility boiler as

opposed to the cement kiln because no ash residue is disposed of as either a hazardous or non-

hazardous waste.

GENERAL AMERICAN TRANSPORTATION CORPORATION

-6-

Reduction in Toxicity, Mobility or Volume

As described above, the power plant offers closely comparable treatment performance to

a cement kiln. Organic constituents will be destroyed at high temperatures. Inorganic

constituents, rather than being immobilized in the cement product, will be immobilized into glass-

like slag and re-used as roofing shingles. But though cement kilns have encountered technical

difficulties in processing the contaminated soil, Illinois Power has already demonstrated the ability

to burn the material, and has stated in writing its ability to treat the Saegertown material.

(Attachment B)

Implementability

The technical difficulties GATX has encountered implementing the cement kiln option do

not exist with the Illinois power plant. Coal tar is indigenous to the utility boiler. The

contaminated soils will represent less than five percent of the boiler feed. The power plant can

be ready to accept the Saegertown materials in March 1996.

Cost

The cost of incinerating the material at Illinois Power is comparable to the cement kiln

option.

Public Acceptance

The Saegertown community's chief concern is clear: they want the Site cleaned up as

quickly as possible. In GATX's view, the best means of satisfying this concern consistent with

the BSD, is to treat the remaining material at Illinois Power.

AR305l*53

GENERAL AMERICAN TRANSPORTATION CORPORATION

-7-

Summaty

GATX believes that changing the off-site thermal remedy from cement kiln to utility boiler

represents the best solution for completing the Saegertown clean-up. The Illinois Power facility

is substantively identical to the cement kiln option but is better suited to manage the coal tar

wastes. In addition, the power plant represents an innovative approach for managing both the low

and moderately contaminated coal-tar wastes. GATX believes that under the present

circumstances, implementing this change as a "non-significant" change to the ROD meets the

letter and intent of the NCP and furthers the overall goals of the Superfund program.

2040811.1

APPENDIX A

AR305l»55

JRN 26 '96 15=39 FROM 9501 858 ME RDMIN T0 913122698869PflGE.002

• Khm r ixif Cjmoany• 300 SOUP 27in SbMr. 5>O.

December 19,1995

Mr. Peter KIpinKipin Industries. Inc.513 Green Garden RoadASquippa, Pennsylvania 15001

Re: Destruction-Removal Efficiencies

Dear Pete:

The Illinois EPA did not require destruction-renxival efficiencies (DR£) to bemeasured during Iffinccs Power's test bum of coaWar contarninatBd sods. TheAgency reasoned that given the high temperatures and hoWing times of the borers,and the fact that the contaminants were normafly found in the coal used as fuel fortne boilers, direct ORE measurement would not be necessary.

Iowa Public Service conducted a test bum of coal tar and coal tar contaminatedsoils in that company's Port Neal Generating Station Unit 1 cyclone bofler as partof a USEPA Superfund remediation project This boiler is very similar to IllinoisPower's Baldwin Units 1 and 2 cyclone boilers, but much smafler. The three unitsutilize identical Baocock and WBcox cyclones. Each of the Baldwin units generateabout 550 megawatts at iufl toad as compared to 130 megawatts for the Neal unitThe Illinois Power boilers bum a high-3TU Illinois coal, whfle the Iowa PS unit bumsa lower BTU western coat The destru&on ernovai efficiency of the Illinois Powerunits can be assumed to be at least as high as those of the Iowa PS boiler.

Excerpts from the towa PS test bum report are enclosed providing a summary oftheir ORE results.

Sincerety,

BiUWftts

Enclosure

WHVAWHW9S042.WPO*d»

&R305U56

i

JflN 26 '96 15:39 FROM 9501 858 ME flDMIN TO 913122698869 PPGE.003

2 amorxar of 2SSOLIS

testing c-*?n«tqc yi during *"hig program is summarized in Table2.1. only fyj L was buraed daring bas»lin* t*s . Ho. 1. A. caal-vas-ce miicear* consisting of 1 part vast* to 2Q pares coal wasburned daring t«sts 2. tiuwugn 7- Test zMj associAt«d vitii

ORE La th« boil«r ver« conduct ad at; tiia scacfc venting

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prasantiad in aoendix A,.

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Sample Tiaa.

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A-R305U58 ** TQTftL PAGE-004 _**

APPENDIX B

AR305l*59

** Z00'39bd "fcJIOl •**JHN-i«-1996 10=04 FROM ILLINOIS PWR TO 170 753210 P. 02

r CompanySaHwm POMerStMortP.O. Box 1-46

Fax 618 785 1

January 24,

Mf - John M. Kopor. AssociateSenior Project MutgerMetcaffft Eddy, Inc.i Pierce Place, 1400 W.Itnc tQmois 60143

R*; Tre*tmc»t of CotilxipMCtnSSoikKttbcIBiiiofe Pawn-Baldwin TbermalTr**teeat Psdfity

DwrMr.Kuptr.

J3ph> Indnrtrics, Inc. aad Illinois Power htve bad the opportunity to review the analytical d«tosupplied to us rtpitienfing rrt"twiifnt*if soils front ftc Sxcgcrtowua Industnil Sit fcvjiml toSas ertown, Famsylvmia. The d«U rep*e«ent& aaalysis of a range of soils tmpactgj by coel tar.»ftfr«d to as Categcxy I «ad Category tt.

Baaed on our review of fl» analytical date of the Cstogpiy I sod Ctasgoiy n soils, we feel tint ourfacility has the technical ability tod regulatory authority to manag* the soils from the Stegertown sheat Illinois Power's Baldwin Thermal Treatment Facility (BTT).

Final acc«jite»e of ftis mateml £> predicated upon the formal sukmfttal, by Metcatf & Eddy, Inc., ofthe completed BTT Waste Profile Form, ttong with caneot malytJcal data, for each soil category.

On bdmlf of Kfpfa Tndtatries and Illinois POWCT I flunk you for considering BTT as aft option foryour waste m*n«gfmcnt«<inlrwncnts. We look forward to wortcmg with M«t«Uf& Eddy, foe. cmthis project We wekoni* the oppofttmity for you and your client to vhhtteBTTfiKffily. Shouldyoo bave any qoectioos coocenring our pufr-acceptmce wastestream approval process, pfcase fed ft«e«o contact me at 618/785-2294, ext 259.

Sincerely,

ILLINOIS POWHtCOMPANY

BiilWlttsBTT Project Coordinator

cc: Peter KJpM,Klpfn Industries

was mis AR305l*60 13 S^-p02SQQ'BOOd . . --2 9912921£16 01 HIWQb "3H 8b3 T0S6 WCfeB 8T :ST 36,

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305US2

NEW STATE OF THE ARTFULFILLING AN OLD PROMISE

Kipin Industries, Inc.TVra decades of experience in processing, remediation and recycling oforganics and solids.

Illinois Power CompanyUnique thermal treatment performance capabilities, including capacity,

exceptional size, operating temperatures and residence time.

Together, Kipin Industries and Illinois Power make the Baldwin Thermal Treatment Unita promise kept; A new solution with the flexibility to address a wide range of

materials, consistencies and site conditions; A solution which each day becomes less an alternativeand more the environmental choice for restoring integrity to our land.

When experience and technology unite, we can make a difference in the world.

RR3Q5U63

•**»i* .,.£»••'.;-•• -

jF~-f*i»**~ - wSS J& ' K .1 . '- :,te*~f '•fr-fi ::p .-Jffrt '' ^ <>bft-?. - • -:s • ^3wt T?

KIPIN INDUSTRIES, INC.

ILLINOISP4WER

EXPERIENCE AND TECHNOLOGY UNITEDKipin's two decades of processing experience combined with

unique design features of the Illinois Power Company's Baldwin

Cyclone Boilers, sets the facility apart from standard waste

processors and low temperature thermal treatment units.

Its massive size, longer residence time and higher burning

temperatures provide the Baldwin Facility with the ability to

accept and process a wider range of materials and consistencies.

Individually, each company has made award-winning con-

tributions in pollution control, recycling, waste reduction and

waste-to-fuel conversion. Illinois Power received the

Illinois Governor's Pollution Prevention Award present(

ed by the Department of Energy and Natural Resources

Hazardous Waste Research/Information Center, the

Corporate Recycling Award, "Model Utility" and

Environmental Success awards.

Working together, we're meeting the challenge of \vi--k' M(\

making a difference in the world.

Boilers: Two CyclonesOne Pulverized Coal

Fuel: Coal Fired, Approximately 12,000 TPDBurning Temperature: 2,500°F - 3,000°FResident Time: 5.6 Seconds - 6.0 SecondsBurners: Two Cyclone UnitsWaste Capacity: 600 TPD (Cyclone Units)

ftR305i»65

KIPIN

Kipin Industries, Inc. is dedicated to applying the experience

of two decades in the field to meet waste challenges. From early plan-

ning; to reviewing options for removal and pre-treatment. to trans-

portation and final processing, Kipin is recognized as a leading

resource in waste recycling and remediation.

Since 1978. KI1 has recycled and remediated over

1.000,000 cubic yards of coal tar materials. Kipin

recycles hazardous and non-hazardous coal tars in

coke plants on a daily basis.

Nationally. Kipin has remediated MGP and coke, plant

sites in residential, commercial and industrial areas—

with many sites being sold after remediation without

fear of long-term liability. FulK mobile capabilities

allow economical on-site pre-treatment and remediation of liquids.

sludges and solids. Other benefits of on-site processing include better

use :of resources, less waste for transportation and reduced

governmental documentation and regulatory involvement.

Kl! has developed many proprietary processes in response to a wide

range of materials and conditions. KII builds the equipment in its own

shops and is constantly improving methods, techniques and practices.

inner fJhejGoyerndr'ji Vaste Minimizationward by'iheti)mmpnweailtliSf*ennsylvaniapartme1nti)VjEnvJrohmentalftotectionfor|

*'Kipin's process can take any waste withBTU value and turn it into a high-efficiency, low sulfurJuel.'

PLANT ENGINEER

Liquids 20,000 Gallon

Sludges Receiving Tank

Odors, Wet, Scrap Metals,Over Size, Sticky/Gummy

3,000 CYCapacity ConcreteContainment

*SegregatiorScreening

DecontaminationPreparation .

Scrap Metal Sales 'jrnr?a-rfivj!g

raid

NON-HAZARDOUS WASTE TYPES

WSN-1: Coal tar, coal oil. spjljjid debris contaminated \\ithcoal tar and coal oils.

WSN-2: Petroleum contaminated soil and debris from leakingunder ground storage tanks (LUST).

WSN-3: Non-hazardous organic tars, sludges and oils, soil and debriscontaminated with organic tars, petroleum soils and debris^

AR3G5467

KIPIN

Processed Materialto the Boilers

Slag Sales(e.g.: Roof Shingles, Sand Blast Grit)

CONSISTENCIES-MIXTURES CONTAINMENT LABORATORYIn ieveloping and implementing the technology The recycling area consists of a H-inch thick An on-site laboratory is provided toa; ; systems for its new Baldwin Facility, Kipin concrete slab with sidewalls. Containment verify all shipments.st -mists and engineers maintained a keen sen- area is 40,000 square feet. All material issi: '.ity to the everyday reality of waste sites— sent to the boilers via covered conveyors. All SHIPPINGin:- wwn or hidden contaminants and debris. storm water is contained and treated. There is Various methods are available.Fi'-n this understanding, the Baldwin Facility no infiltration/exfiltration. . . • Trucks: Tankers, dumps, boxes, drums.\\ii. be able to handle a wide range of consisten- ' ; roll-offs, special containers.cir-and mixtures of materials, PROCESSES ' • Rail: Gondolas, containers.

S:ind • Rock • Concrete " KII uses conventional and proprietaryi'lastic' • Clay • Soil processes and equipment developed andi'rick •\\bod • Metal built by KII.

i; MI'S in all forms of liquid, sludges and soils.1'. be received and processed.

ftR305i»68

"Kipin has processed enough residual sludgeJrom cankers, refineries and sroragefacilities to run a medium

sized tiyjor over a year."

MANAGER — TAR REFINERY

WASTE TYPE 1Non-hazardous coal tar. soil and debris contaminated _

with coal tar and coal oils.

Waste TypesTar Lagoons Tar Tanks Gas HoldersTar Sumps Tar Tankers Truck Bottoms .Rail Tankers Barge DrumsRoad Oils/Tars Roof Tars Waterproofing Tars

SourcesMGP Sites Coke Plants Tar RefineriesRoofing Pipe Coating ElectrodesHighways/Roads . Construction

AR30Sl*69

"Petroleum heavily contaminated the soil around(he tanks...Kipin's mobile treatment restored the land at

ajracticn of the cost of clean-up liabiliry."

PLANT SUPERVISOR — GAS STORAGE FACILITY

WASTE TYPE 1

l.l Petroleum contaminated 3W1 arid debris ffttm L^nderground Storage Tanks (LUST)

'

"Kipin took our oil-soaked wooden pallets

and transformed themjrom waste into an altemativejuel.'

MANAGER — STEEL MILL

WASTE TYPE 3Non-hazardous organic tars, sludges and oils, soil and debriscontaminated with organic tars, petroleum soils and debris.

Waste TypesCharcoal Carbon Coal/CokeGreases Tar Oils Petroleum OilsSynthetic Oils Palm Oils Vegetable OilsLagoons Bio Sludge Purifier Wood

Asphalts

SourcesManufacturing Truck DepotsCommercial RailroadsIndustrial HighwaysMunicipal UtilitiesAirports SpillsGovernment Bulk TerminalsImpoundments RefineriesPackaging

RR305U73

**&.*£•

"From site analysis to on-site processing,Kipin developed a cost-effective plan of action.

SITE MANAGER— COKE PLANT

SPECIAL SERVICES

Kipin offers an entire spectrum of in-house services from site

assessment and materials assay, to complete decommissioning, mobile

treatment and waste removal. Advanced mobile equipment combined

with experienced engineers, allow Kipin to provide response anywhere

on land or water.

On-site:-Drum Cleaning and Disposal -Equipment Cleaning and Disposal-Pipe Cleaning -Oversize Material Crushing-Waste Stabilization -Decontamination

Off-siteMobile Units: Kipin Industries, Inc. can perform on a turnkey or

individual basis for the following typical services;-Demolition-Site Remediation/Restoration-Excavation/Backfill-Ha uiing/Transporta tion-Stabilizing of Soils, Liquids. Sludge to Pass TCLP-Hazardous Waste Processing/Disposal-Asbestos. Lead Removal/Disposal-Tank. Pipe. Barge and Railroad Car Cleaning

Ask for any of our supplemental guides:-Recycling/Reclamation -Tank Monitoring. Cleaning. Rcmo\ al•'Site Remediation -Decontamination-Waste-To-Fuel Processing -Lead & Asbestos Removal-Demolition -Site Assessment-Lagoon & Sludge Removal -Se\ver Rehabilitation-Pipe Cleaning Systems -Emergency Response

AR305l*76

Metcalf & Eddy ____An Air & Water Technologies Company

iff

February 5, 1996

Mr. Steven J. DonohueProject ManagerU.S. EPA, Region III !3HW24841 Chestnut BuildingPhiladelphia, PA 19107

Re: Kipin Industries, Inc. ReferencesGATX - Saegertown, PA Site

Dear Mr. Dohohue:

As requested and on behalf of General American Transportation Corporation, I have attachedreferences for Kipin Industries, Inc. References include contacts and telephone numbers fromU.S. EPA, State agencies and industrial clients that have been associated with remedies similarto the proposed GATX site remedy. Also included is Kippins' Solid Waste Disposal and/orProcessing Facility Permit for the on-site pre-conditioning of soils prior to transportation to theIllinois Power facility in Illinois, and a skematic of the cyclone boiler feed system.

Please contact me at (216) 292-8191 if you have any questions or need additional information.

Sincerely,

METCALF & EDDY, INC.,

Mark W. KittingerProject Manager

xc: Jay Grove - GATXxc: Bob Kimball - PADERxc: John Kupar - M&E

p:\everyone\kipin

Five Commerce Park Square, 23200 Chagrin Bivd . Suite 425TEL: 216-292-8191 FAX. 216-202-593

Referencesfor

Kipin Industries, Inc.

A. Governmental

1. US EPA Region IV, Superfund Branch, Atlanta, GAWrigley Tar Site•Mr. Doug Bell, Regional Project Manager; Currently in Washington DC; 401 MStreet; Room 3105; 202-260-8716

2. Tennessee Department of Environmental and Conservation, Nashville, TNWrigley Tar Site•Mr. Tim Stewart; 614-741-7391

3. US EPA, Washington DCMr. Josephson is familiar "with KII's coal tar recycling capabilities in coke plantsnationally.•Mr. Ron Josephson; 202-260-6715

4, Delaware DNREC, 715 Grantham Lane, Newcastle, DE 19720MGP site in Smyrna, DE. Clean-up of high benzene soils located close to residentialhomes and in hot weather. Rendered non-hazardous for off-site use.•Mr. Steve Jones; 302-323-4540

5. Pennsylvania DER, Pittsburgh, PAFamiliar with KII handling of coal tars and oils.•Mr, Ken Bowman, PA DER Attorney and former Manager of Air Quality of PADER; 412-442-4000

Note: KII received the Pennsylvania Governor's Award for recycling of Coal Tars in1995.

B. Industrial

1. AK Steel; Middletown, OH/Ashland, KYCurrent multiple recycling, demolition and remediation projects since 1993.• Carl Batliner, Director Environmental Affairs, 513-425-3254• Lloyd Chapman, Manager of Projects, 513-425-4772

2. Acme Steel, Chicago, ELCurrent multiple recycling, remediation and demolition projects since 199 L• Jack Garzella, Coke Plant Manager, 312-933-5100

ftR305l*79

References for Kipin Industries, Inc.Page 2

3. LTV Steel; Pittsburgh, PACurrent multiple recycling and remediation projects since 1983.• Dave Griener, 412-221-5737

4. Keystone Coke Works (Formerly Alien Wood Coke); Philadelphia, PATotal site clean-up (80 acres) completed in 1991. Site is now occupied by thePhiladelphia Inquirer Newspaper.• Mickey Wade, Drummond Coal Co. (Former Owners of Keystone Coke), 205-945-6500

5, Terre Haute Coke & Chemical; Terre Haute, INTotal site clean-up, approximately 75 acres. High profile, sensitive residential area.Corporation dissolved after clean-up, see news article attached.• Ed Cox, Vice President, 812-238-9342

6. Chesapeake Utilities Corporation; Dover, DEMGP site clean-up. Sensitive recreational and residential area.• Leslie McKnight, 302-734-6745

C. Project References______

See Attached Typical List

D. Miscellaneous References

See Attached Articles

AR305l*80

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ER-WM-8A: Rev. 1/86 COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

BUREAU OF WASTE MANAGEMENT

PermitFor

Solid Waste Disposal and/or Processing FacilityFORM NO. 8

Permit No. ______301091Date Issued ______ JulV______Date E*pir»ri July 19, 2001

1 FOR THE DEPARTMENT OFi ENVIRONMENTAL RESOURCES

THIS PERMIT IS NON-TRANSFERABLEPage_l__of_8__ A R 3 0 5 8 3

Under the provisions of the Pennsylvania Solid Waste Management Act of July 7, 1980, Act 97, apermit for a residual waste processing facility is granted to (applicant) Kipin Industries, Inc., 513 GreenGarden Road, Aliquippa, PA 15001. This permit is issued based upon application No. 301091 receivedin Central Office December 23, 1985 and applicable/to the facility named as Kipin Industries, Inc. anddescribed as:

MOBILE WASTE COAL TARS AND OILS PROCESSING FACILITY

This permit is subject to modification, amendment and supplement by the Department ofEnvironmental Resources and is further subject to revocation or suspension by the Department of

i IEnvironmental Resources for any violation of the applicable laws or the rules and regulations 'adopted thereunder, for failure to comply in whole or in part with the conditions of this permit and ithe provisions set forth in the application No. 301091 which is made a part hereof, or for causing anycondition inimical to the public health, safety or welfare.

See Permit Condition for waste limitationsand/or special conditions. .

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.-. ... - -• .„-.*•-•Commissioners: School plans HWefin<s X_,.«, _.vv. • . -••»»».• . ~ . -_.. • ; -.-'jetitaSffgaZ • Today: Warm. Highs near 70.

• Tonight: Cloudy. Lows 45-50.• Tomorrow: Windy. Highs in 50s.

— Details, 83

. - . . . - . _Charles Town coal-gas tank cleanup begins. .. - - ._..:..jr*:rvri.i-...-v --._,-... .- ^ s-«» . -j. .iyi__4B_sa

Cloudy

MORNING t HERAI7th Year No. 327 Hagerstown, Md. Wednesday, November28,1990 25c

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oh•it

By Rtdun! T. M««gnw

Dave Peters (left) and Paul Sheppard work on removal of thick sludge from an old coal gas tank. The material will b« recycled for fuel.

'Nothing's wasted' in clean-upSludge from Charles Town coal gas tank recycled for fuelBy DAVE McMILLION list of 11 potential hazardous waste sites in Jef- the work. Many times companies will try to cut __-.SUff Writer. Charles Town ferson County. costs for cleaning up, he said. **•CHARLES TOWN, W.Va. — its dean-up has Supertane finally decided it would voluntarily "They (Supertane) said do whatever you »"C

been the source of a lawsuit and disagreements P3? lor removal of the tank but later sued the have to and do it right," Kipin said.between owners and environmental agencies, previous owner of the property. Roger Perry, to The tank was built to provide the town withbut the thick black sludge in the bottom of a force """ to telP PaX for &e work- coal gas during the 1900s. Coal gas lines cancoal gas tank on West Congress Street will be T"6 cast * pending in U.S. District Court in still be seen in some of the older homes ui town.useful after aU. Wheeling. _ city officials said.A Pittsburgh company has begun transform- But U«''s aU irrelevant to Kipin. The process involved heating coal and "dnv.

'.

ing the sludge back into coal through a sophisti- He's Jf "PPX 'o see his operation spitting u,g of/ u,e glS-- whjch W3S plpe<1 Mo e UnJ<_cated process using ovens, sawdust and fresh out Ironl Ule 19th century tank, used years sud Kipin. The facility actually consisted ofcoal. aS° to P™"" 8" to Charles Town residents. two tanks, one which was inverted in a pool ofOnce all the sludge has been processed back The sludge is being pumped from the lank water, he said.

into coal, it will be sold for fuel according to and into a "roaster." where it is mixed with Gas was piped under the inverted tank, whichPete Kipin of Kipin Industries Inc., the comp- sawdust and fresh coal to absorb moisture. caused it to rise in the water. The tall railsany hired to clean up the site and dismantle the The mixture is continuously being turned in extending up from the main lank guided thetank. the roaster and when it is dry, the result is a inverted tank as it rose, Kipin said.

"All we're doing is reversing Mother Nature low grade coat Kipin said. He said the coal is Kipin said he could find no evidence thai theand putting it back where it came Irom," Kipin usually sold to factories for heaung fuel. tank had contaminated the area. In fact, thesaid. "Nothing's wasted." Kipin said he hopes to be finished by the first sticky substance had preserved the operation

Kipin Industries was hired by Supertane Gas of the year. Although it's too early to determine including the pool of water for the invertedCorp.. the owner of-the site. The work ends how much the cleanup will cost Supertane. tank.hesaid.months of bickering between Supertane. previ- Kipin said it will be "a few hundred thousand The coal gas plant was not exclusive toous owners of the property and state and fed- dollars." Charles town. He said aboul 3.500 of the out-era! environmental agencies over who should Kipin commended Supertane for its willing, dated plants exist in the United Stales and

inCO__t*inoCO

The Governor'sWASTE MINIMIZATIONAWARDS-1995 WINNERS

______^________ 2530-PA-DEP-19°g

Printed on recycled paper

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

-Please note our new name-DEPARTMENT OF ENTVmONMENTAL PROTECTION

DEPRachel Carson State Office Building

P.O. Box 2063Harrisburg, PA 17105-2063

September 12, 1995

(717) 787-2814The Secretary

Mr. Peter KipinPresidentKipin Industries, Inc.513 Green Garden RoadAliquippa, PA 15001

Dear Mr. Kipin:

Congratulations! Kipin Industries, Inc. has been selected to receive a 1995 Governor'sWaste Minimization Award for accomplishments in preventing or reducing the generation andrelease of waste in Pennsylvania. Your waste minimization efforts, whether they are related tosolid waste, waste water, air emissions, or all three, not only result in significant environmentalbenefits, but also impressive economic gains. Your efforts serve both to reduce the amount ofwaste requiring disposal and to conserve our natural resources for future generations.

To honor all of the 1995 Governor's Award winners, we will be holding our PollutionPrevention Conference and Awards Dinner on October 25, 1995. The day's activities willprovide an opportunity to highlight the efforts and successes of this year's winners. Tworepresentatives of your organization are invited to attend the conference and awards dinner asour guests. Please contact Georgia Kagle of our Pollution Prevention Program at(717) 787-7382 with the names of your representatives, and for further information about theawards ceremony. The enclosed brochure provides detailed information about the conference,and also outlines the registration procedures if additional personnel from your company wish toattend the events.

Again, congratulations on your commitment to improve and preserve our environmentthrough your waste minimization programs. We look forward to seeing you in October!

Sincerely,

James M. SeiSecretary SEP £ g J995

Enclosure ., . •. -rmr"' IM/>r\int; uvL/Uof RIECD, INC.

An Equal Opportunity/Affirmative Action Employer Recycled Paper

SUMMARY / O VER\1EWThe Kipin Recycling Process

farCoke Oven Wastes

[n the production of iron and steel in integrated plants using blast furnaces and basic oxygen furnaces, large amountsof coke are required. Coke is produced by pyrolizing bituminous coal in units called "coke ovens" which separatestars, oils, and gas from coal to produce "coke".

In the separation process, large amounts of waste and fay-product materials, such as tars, pitch, etc. are produced. Someof these waste materials are considered to be hazardous, and thus require special handling and disposal methods. EPAregulations in the past few years have "land banned" these wastes.

KH has developed, in Pennsylvania, a process whereby these hazardous coke oven wastes can be recycled back to thecoke ovens as a beneficial coal substitute which actually improves the coke strength and recovering the waste coal tars.This process also allows for the use of inferior or lower grade coals.

The wastes are processed in a manner which improves the inferior coal and allows waste (oxidized) coal to be used thusproviding an economical advantage as well as avoiding the problems of disposal and environmental liabilities. Theprocess is located at the coke plants such that daily production of wastes can immediately be recycled/reused. Idled cokeplants and other coal tar wastes from tanks, lagoons, pits, etc. are now recoverable as a resource and sent to a recyclecenter at an operating coke plant for recovery. In addition, the recycling plants can accept other types of waste materialsgenerated in a coke oven plant, including waste wood, plastic, paper, petroleum oils and greases, and other materials.

An example of the recycling practiced by KH is the recycling plant operating in Pittsburgh at the site of LTV SteelCompany's coke plant The KII plant, located adjacent to LTV's coke plant, processes approximately 8,000,000pounds of waste per year since 1983. Further, the recycled material reduces the amount of raw materials otherwiserequired to be processed in the ovens. Environmental control is enhanced by immediate re-utilization of the waste ina safe, clean manner, and eliminates downstream potential spills and emissions of pollutants into air/water/ground atdisposal sites utilizing less desirable technology than that employed by KH Total estimated amount of wasterecycled/reused is an amazing plus two hundred million (200,000,000) pounds since 1983. KII has used this processto clean-up five idled coke plants in Pennsylvania, recovering over 75.000 cubic yards (150.000,000 pounds) of wastesfrom the ground for reuse.

The LTV recycling plant provides continuing employment for approximately five personnel. The recycling plant hasreceived full approval and backing of LTV Steel Company, and long term contracts for continuing operation of the planthave been negotiated with KII. Approximately 20 fabrication, mechanics and support personnel positions have beencreated in western Pennsylvania to fabricate equipment for expansion nationwide. The process has been duly permittedby the PA DER. The PA DER has also issued KH a statewide mobile permit for recycling coal tars and oils.

KH is exploring other opportunities in the Commonwealth of Pennsylvania to utilize their recycling process, not onlyfor coke oven wastes but also odier materials; such as MOP sites, wood tar sites, waste coal sites and iron dusts. Fromits Pennsylvania roots, the KH process is now used on a daily basis in Illinois, Ohio, Kentucky, Alabama and will soonspread to Europe and the Far East.

Primed oa 100% Recycled Piper

EXPERIENCE AND TECHNOLOGY UNITE

(Al'll)lH1 I'lHll'Ts S('h lll C l i l f | l l l \ ,111,1''; !

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iicccpl and pmrrss a uidcr idii^c ul nuii'T;.

Iriliiilions in imlliiliuii conirni icc\ hn^ •

Po1

Illinois Governor's Pollution Prevennc

ed by the Department of Energy and ."

Hazardous Waste Research'lnforma

Corporate Recycling Award. "Mor

Environmental Success awards

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