Pennsylvania Department of Environmental Protectionevaporative cooler such that the temperature of the gases exiting, the evaporative cooler are lowered to approximately 400 F-450

Pennsylvania Department of Environmental Protection208 West Third Street, Suite 101Williamsport, PA 17701-6448

February 6, 1998

Northcentral Regional Office Fax 717-327-3420

Mr. Gary Jones, Technical ManagerOHM Remediation Services Corporation180 Myrtle StreetLock Haven, PA 17745

Re: Drake Chemical Superfund SiteLock Haven, Clinton County

Dear Mr. Jones:

Enclosed is the Department's Air Equivalency Permit which has been modified to include the trialburn operating parameters.

Please address any comments concerning the enclosed to David A. Bish, Air Quality Supervisor at717-321-6555 or myself at 717-327-3707.

Sincerely,

Sandra J. DownsProject OfficerHazardous Sites Cleanup SectionEnvironmental Cleanup

Enclosure

cc: David Modricker (Project Engineer, USAGE)Gregg Crystall (RPM, USEPA)Hawk RunHarrisburgFile

SJD/sr

An Equal Opportunity Affirmative Action Employer httpr.'/www.dep.itate.pa.us Printed on Kecvged Paper .—,.

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL PROTECTION

BUREAU OF AIR QUALITY

AIR QUALITY EQUIVALENCY DOCUMENT

Department hereby issues this Air Permit Equivalency Document for the operation of the aircontamination source(s) described below.

Source & hazardous waste incinerator and

Owner: OHM Remediation Services Corp. Air associated control systems____

_______________________ Cleaning (Drake Chemical Superfund Site)

Address: 180 Myrtle Street _____.____ Device: ___________________- Lock Haven, PA 17745

Attn: Mr. Gary Jones______________ Location: Lock Haven Borough

Technical Manager ______ Clinton County___

This document is subject to the following conditions:

1. That the source(s) and any associated air cleaning device(s) are to be:

a. operated in such a manner as not to cause air pollution;

b. operated and maintained in a manner consistent with good operating andmaintenance practices.

2. This document is valid only for the specific equipment, location and owner named above.

See attached for additional conditions.

Issued: February 5, 1998(Modified: per trial burns)Expires: March 31,2000

cc: David Modricker (Project Engineer USAGE)Gregg Crystall (RPM, USEPA)Sandra Downs (Project Officer)Hawk RunHarrisburgFile

Environmental Program

AR31898?

EQUIVALENCY DOCUMENT CONDITIONSCOMPANY: OHM Remediation Services Corp.

3. This permit equivalency is issued for the construction and operation of a contaminated soilsremediation operation to be conducted at the Drake Chemical Superfund Site. The remediation systemshall be constructed and operated in accordance with all specifications and operating parametersdesignated herein.

EQUIPMENT

4. The contaminated soils remediation operation shall consist of the following equipment with thereferenced design specifications.

A. A soils excavation, transport, stockpiling and replacement (backfilling) operation, the aircontaminants from which will be controlled by applying operational techniques designed tominimize fugitive emissions plus the application of water, foam or other dust suppression agentsto the excavation site, haul roads, backfilling site or stockpiling operations as needed to minimizedust emissions.

B. A Debris Separation Building (containing screens, conveyors, etc.) which shall be ventilated in amanner that the building will be maintained under negative pressure or draft at all times soilhandling or debris handling is taking place.

The building ventilation will be as follows:

(1) Approximately 600,000 cfh of exhaust air will be vented to an "air handling system"consisting of a particulate filter and a vapor phase carbon adsorption system (this ventilationshall be operating on any occasion that soil or debris handling is being conducted).

A Feed Preparation Building (containing screens, conveyors, feed storage bins, wood chippers,stone crushers, etc.) which shall be ventilated in such a manner that the building will bemaintained under negative pressure or draft at all times soil handling is taking place.

The building ventilation will be as follows:

(1) Approximately 800,000vcfh of exhaust air will be vented to the PY*ROX 8212 rotary kilnincinerator followed by the associated air pollution control systems (this ventilation will onlyoccur when the rotary kiln is in operation).

(2) Approximately 600,000 cfh of exhaust air will be vented to an "air handling system"consisting of a particulate filter and a vapor phase carbon adsorption system (this ventilationshall be operating on any occasion that soil handling is being conducted).

AR3I8988


C. A PY*ROX 8212 rotary kiln incinerator (11 ft. in diameter x 60 ft. long) equipped with two45 million BTU/hr. oxyfuel burners utilizing natural gas or propane. The air contaminants fromthe incinerator shall be controlled by the following equipment operated in series;

(1) An ABB Raymond cyclone (no model #) (10.5 ft. in diameter with a conical section length of18.6ft);

(2) An ABB Raymond secondary combustion chamber (no model #) (11 ft. insidediameter x 73.5 ft. Long) equipped with;

(a) Two North American model 4798 "Magna-Flame" 55,000,000 BTU/hr. natural gasburners;

(b) A thermocouple designed and located to provide the gas temperature after a minimumresidence time of at least 2 seconds.

(c) An oxygen lance to improve combustion efficiency as needed.

(3) An evaporative cooler equipped with;

(a) Air atomized water spray nozzles located at the point the gases enter the evaporativecooler contact chamber;

(b) An outlet temperature controller which controls the amount of water sprayed into theevaporative cooler such that the temperature of the gases exiting, the evaporative coolerare lowered to approximately 400°F-450°F.

(4) A Wheelabrator Air Pollution Control fabric collection system consisting of six identicalbaghouse modules operated in parallel;

(a) Each module shall be equipped with 255 sixteen ounce felted fiberglass bags 6 inches indiameter and 14 feet in length;

(b) Each module shall be equipped with a pressure drop monitor to measure the pressuredrop across that module. Said monitors to be located in a readily accessible location;

(c) The fabric collection system shall be equipped with a "primary" differential pressuredrop monitor to measure the pressure drop across the entire baghouse. Said monitor tobe located in a readily accessible location;

(d) The collector bags will be cleaned via pulse jet cleaning activated via the "primary"pressure differential reading;

AR3I8989


(e) The collector will be equipped with thermostatically controlled hopper heaters.

(5) An induced draft fan draws the combustion gases through the system and discharges themthrough the wet scrubbing system to the exhaust stack.

(a) The fan shall be equipped with a pressure controller that modulates the I.D. fan speed tomaintain a slightly negative pressure at the kiln.

(6) A venturi scrubber functioning as a gas cooling device;

(a) The scrubber shall utilize scrubber water supplied by spray nozzles injecting water intothe venturi quench section.

(7) Two Advanced Air Technology vertical packed bed acid gas scrubbers operated in parallel.

(a) Each scrubber will utilize an 11 ft. diameter, 11 ft. deep bed of packing consisting of 2"Ravschert Hi-Flow rings.

(b) The caustic/water scrubbing solution will be maintained within a pH range of 6.5 to 9 viathe addition of NaOH solution.

(c) Each packed bed scrubber will be supplied with a minimum of 450 gpm of therecirculated caustic/water scrubbing solution.

(d) Each scrubber shall be equipped with a flow meter to monitor the caustic/waterscrubbing solution recirculation rate.

(8) A high efficiency multi-pass chevron mist eliminator followed by a mesh pad (one for eachscrubber) for removal of entrained water droplets.

(9) A fiberglass-reinforced plastic exhaust stack -150 ft. high.

D. An Ash Management system consisting of transfer conveyors and an ash storage facility the aircontaminants from which will be controlled by; •

(1) Bottom ash from the incinerator shall be preconditioned by wetting on the drag conveyorprior to the ash management system.

(2) Fly ash from the fabric collection system shall be preconditioned by wetting in a pugmill (12-30% moisture) prior to the ash management system.

(3) All ash will be wetted prior to discharge into the ash management area.

-4-

AR3I8990


(4) The ash storage roof structure and bin walls shall minimize wind dispersal of the ash.

OPERATING REQUIREMENTS

5. The contaminated soils remediation equipment shall be operated within the following referencedspecifications.

A. Fugitive dust emissions from the soils excavation, transport, stockpiling and replacementoperations shall be minimized by all reasonable action to prevent particulate matter frombecoming airborne.

B. The operation of the contaminated soils remediation operation shall not at any time result in theemission of fugitive air contaminants in excess of the limitations specified hi Section 123.1 or123.2, both Sections of Chapter 123 of Article III of the Rules and Regulations of the Departmentof Environmental Protections, or in the emission of any other type of air contaminant in excess ofthe limitations specified in, or established pursuant to, any other applicable rule or regulationcontained in Article III.

C. There shall be negligible soil or ash materials carried onto streets or roads outside the project. ,Any soils carried onto streets or roads outside the project shall be immediately removed.

D. There shall be zero emissions visually detectable from the Debris Separation. Building and theFeed Preparation Building.

E. The particulate filter on the Debris Separation Building and the Feed Preparation Building "airhandling systems" shall be changed as needed to maintain adequate air ventilation of the building.

I*

F. The activated carbon in the carbon adsorption system serving the "air handling systems" shall bechanged when the total hydrocarbon removal efficiency across the carbon bed reaches 95%.

G. There shall be zero fugitive emissions visually detectable from the rotary kiln and/or the rotarykiln feed system.

H. A slightly negative pressure shall be maintained at the kiln hood or kiln disengaging chamberduring kiln operation.

I. The hourly rolling average feed rate to the PY*ROX rotary kiln incinerator shall not exceed the47.3tph maximum feed rate tested during the trial bum.

-5-

&R3I899I


J. The waste feed concentration of heavy metals shall not exceed the following limits:

metal maximum allowable concentration - ppm by weight

arsenic 136beryllium 3.89cadmium 20.6chromium 87.7lead 840

K. The waste feed concentration of chlorine shall not exceed 300 pounds per hour.

L. The PY*ROX rotary kiln incinerator shall be operated at a minimum temperature of 1599°F(mean hourly average) and an instantaneous minimum temperature of 1000°F. (Note: wastefeedmay continue if the instantaneous kiln temperature is > 1599°F

M. The kiln shall be maintained at temperature for 30 minutes following termination of the soil feedto the kiln during any shutdown procedures except emergency shutdowns due to high temperatureor where fuel is not available.

N. The secondary combustion chamber shall expose the gases to a temperature of > 1801°F for aresidence time of not less than 2 seconds.

O. The secondary combustion chamber shall be maintained at temperature for 30 minutes followingtermination of the soil feed to the kiln during any shutdown procedures except emergencyshutdowns due to high temperature or where fuel is not available.

P. The minimum water flow rate to the evaporative cooler shall be designed to maintain an inlettemperature to the fabric collector system of 350°F to 450°F. If the inlet temperature to the fabriccollector exceeds 500°F the safety interlocks shall initiate an emergency system shutdown.

Q. If the excavation of an area with a high volatiles concentration results in an odor or otherenvironmental problem, a foam suppression system (or equivalent) shall be used to minimize theproblem. For purposes of this paragraph it will be the Department's determination that will decideif a problem is significant enough to warrant this treatment.

R. The fabric collection system air to cloth ratio shall not exceed 3.6 to 1.

S. The pressure drop across the fabric collection system shall not be below one inch (water column)or above 6 inches (water column) for a period exceeding 5 minutes.

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AR3I8992


T. A sufficient quantity of spare fabric collector bags shall be kept on hand to immediately replaceany bags requiring replacement due to deterioration resulting from routine operation of theremediation system and fabric collector.

U. The minimum water flow rate to the venturi scrubber cooling device shall be designed to maintainan inlet temperature to the acid gas scrubbers of 175°F to 210°F. If the inlet temperature to theacid gas scrubber exceeds 250°F, the safety interlocks shall initiate an emergency systemshutdown.

V. The caustic/water scrubbing solution serving the Advanced Air Technology packed bed acid gasscrubbers shall not drop below a pH of 6.5 for more than one hour.

W. Each packed bed acid gas scrubber shall be supplied with a minimum of 450 gpm of therecirculated caustic/water scrubbing solution.

AIR CONTAMINANT EMISSION LIMITS

6. The contaminated soils remediation system shall be operated in such a manner that the followingemission limitations are complied with at all times.

A. The gases exhausted from the remediation system shall be limited as follows':

Contaminant "Shall Not Exceed" Limitation

total particulate matter .01 gr./dscf corrected to 7% O2*

carbon monoxide 100 ppmv as an hourly runningaverage corrected to 7% O2*

nitrogen oxides 300 ppmv as a daily averagecorrected to 7% O2*

Jiydrogen chloride 4 Ib/hr or shall be reduced by 99%on an hourly average

dioxin & furan 30 ng/dscm corrected to 7% O2*

metals shall comply with 40 CFR 266.106

*using the CO2 formula in the Trial Burn Plan

B. The incinerator shall maintain a combustion efficiency of 99.9% or greater as an 8 hour averagecalculated as follows:

-7- 'AR3I8993


[%C02+%CO]

C. The soils remediation system shall be capable of achieving a destruction and removal efficiency of99.99% of the POHC (this shall be demonstrated using naphthalene and 1,4 dichlorobenzene).

D. The soils remediation system shall not be operated in a manner which will result in malodorswhich the Department determines to be excessive.

E. There shall be no visible emissions from the stack exclusive of condensed water vapor. Nitrogenoxides shall not be visible in the stack gases. Emissions from the secondary combustion chamber,during startup, are exempt from this requirement.

»

CONTINUOUS MONITORING AND RECORDING REQUIREMENTS

7. The contaminated soils remediation system shall be operated with the following monitoring andrecording systems being maintained throughout the life of the remediation project

A. The remediation operation shall operate, test and maintain (including testing and calibration asoutlined in the "Drake Chemical Superfund Site Incineration Facility Instrument CalibrationManual") continuous emission monitors and continuous data records to continuously measure andrecord the following parameters in the stack exhaust gases:

CO carbon monoxide concentrationCO2 carbon dioxide concentrationNOX nitrogen oxides concentration

stack velocity

B. The remediation operation shall operate, test and maintain continuous monitors (and continuousdata recorders where designated - CDR) to continuously monitor and record the followingoperation parameters. In addition, the monitors designated CDR shall be tested and calibrated asoutlined in the "Drake Chemical Superfund Site Incineration Facility Calibration Manual":

( 1 ) P Y*ROX 82 1 2 rotary kiln incinerator

(a) soils feed rate into kiln - CDR(b) kiln pressure - CDR(c) kiln temperature - CDR(d) kiln rotation speed*(e) kiln fuel flow rate*(f) kiln oxygen (fuel combustion enhancement) flow rate

* confidential business information

-8-

AR31899U


(2) Air Pollution Control Equipment

(a) pressure differential across cyclone(b) temperature of secondary combustion chamber at or after the point in the combustion

chamber that represents a residence time of at least 2 seconds - CDR(c) oxygen concentration of the gases exhausted from the secondary combustion chamber*(d) fuel flow into the secondary combustion chamber(e) secondary combustion air flow into the secondary combustion chamber*(f) oxygen flow to the oxygen lance in the secondary combustion chamber(g) water flow rate into the evaporative cooler(h) temperature of gas stream into fabric collector - CDR(i) temperature of gas stream out of fabric collectorG) pressure differential across the fabric collector - CDR(k) temperature of gas stream following venturi quench - CDR(1) caustic/water scrubbing solution flow rate to each acid gas scrubber - CDR(m) pH of caustic/water scrubbing solution - CDR

* confidential business information

C. The outlet hydrocarbon concentration of the activated carbon adsorption systems (serving the airhandling systems on the Debris Separation Building and the Feed Preparation Building) shall bechecked every 24 hours of operation. After the outlet hydrocarbon concentration reaches 10 ppmthe inlet concentration shall also be checked every 24 hours of operation. A log shall bemaintained documenting each inlet (if required) and outlet reading as well as all carbon changesand any maintenance performed.

D. The Department shall receive a monthly report pertaining to the "Drake Chemical Superfund SitePerimeter Air Sampling Plan". The monthly report shall consist of records of samples takenduring the month, status of the samples, any operating problems encountered, results of time-integrated and real-time sampling and analysis (including a hard copy of the real timeconcentration of speciated organics as measured by the NHu GC system), identification of sourcesof contaminants, and recommended means in which to control contaminants.

PERIMETER AIR SAMPLING

Note: Conditions 8 and 9 which describe the perimeter air sampling are not intended to indicatenon-compliance with the operating condition of the incinerator nor the air pollution controldevices. Collection of air samples is expected to be. 90% effective (time integrated). 10% loss of airsamples is expected to account for wet weather conditions and equipment failure. This applies toall samples collected via conditions 8 and 9.

-9-AR3I899S


8. During the contaminated soils remediation operation perimeter air sampling shall be conducted at4 permanent sampling sites located on the project perimeter as identified in the Perimeter AirPlan as follows:

A. For 2 months prior to incinerator startup sampling shall be conducted once per week at onesampling site for TSP, metals, SVOC's, and VOCs. (This activity completed)

B. Upon the startup of full scale excavation and for a period of 30 days following startup, samplingshall be conducted daily at each of the 4 sampling sites for TSP, metals, and SVOCs. (Thisactivity completed)

C. From the 30 day period referenced in 8.B. to 1 year, sampling shall be conducted at each of the 4sampling sites, twice per month for TSP, metals, and SVOCs. (This activity completed)

D. From the 1 year period referenced in 8.C. to completion of incineration activities, sampling shallbe conducted at each of the 4 sampling sites, monthly for TSP, metals, and SVOCs.

E. At the start of full scale excavation activities until completion of incineration activities (wheneverthe rotary kiln incinerator is in operation and/or excavation of any contaminated soil is beingdone) real time sampling for VOC's at the 4 sampling sites shall be conducted as outlined in thePerimeter Air Sampling Plan and as follows:

(1) Sampling shall be conducted using a HNu Model 501 Environmental Chromatograph Syste(or equivalent) which shall be operational a minimum of 80% of the time the remediationsystem is on line.

(2) The Model 501 (or equivalent) shall collect a sample from each of the 4 sampling sites onceper hour for 5 minutes.

(3) The Model 501 (or equivalent) will initially operate in a "Quickscan" mode measuring thetotal nonmethane organic compound (NMOC) concentrations.

(4) If the Model 501 (or equivalent) detects an average NMOC concentration greater than 1 ppmover the 5 minute sampling period, a speciated analysis shall be performed on the sample fortoluene, chlorobenzene and tetrachloroethene.

(5) A Perimeter Action Level is hereby established at 10% of the OSHA PEL (permissibleexposure limit) for the 3 speciated analysis compounds. The perimeter action levels aretherefore:

9.146 ppm for toluene7.777 ppm for chlorobenzene2.511 ppm for tetrachloroethene

-10-

AR3I899:6


(6) The perimeter air sampling shall be conducted in accordance with the "Drake ChemicalSuperfund Site Perimeter Air Sampling Plan" including the calibration, sampling andanalytical procedures.

(7) A monthly report detailing the results of the perimeter air sampling shall be submitted percondition 7D herein.

(8) If any speciated analysis indicates concentrations five times the perimeter action level at anyof the sampling sites, the remediation system operators must telephone the Department within1 hour of the analysis and advise the Department of the results of the analysis.

9. Ambient community sampling shall be conducted at 4 permanent sites within Lock Haven as follows:

A. For 2 months prior to incinerator startup to completion of incineration activity, sampling shall beconducted at each of the 4 sampling sites once every six days for VOC's, SVOC's, TSP,dioxins/furans, and metals.

B. The ambient community sampling results shall be submitted to the Department on a quarterlybasis due within 8 weeks of the end of the quarter.

C. In the event that OHM Remediation Services Corp. is prevented from completing the abovesampling because of vandalism, fire, flood, act of God, or other circumstances entirely beyondOHM's control and which, by the exercise of all reasonable diligence, is unable to prevent, ormitigate then OHM Remediation Services Corp. shall be relieved of the requirements ofCondition 9 as far as the "event" has affected sampling (and related reporting requirements).OHM Remediation Services Corp. shall only be entitled to the benefits of this paragraph if itnotifies the Department within ten (10) days in writing of the date it becomes aware or reasonablyshould have been aware of the event impeding performance.

STACK TEST REQUIREMENTS

Note: During testing the equipment interlocks need not be set at the normal prescribed levels toallow testing under a variety of conditions. During these test periods, however, all air pollution ~control systems must be operational to minimize any emissions.

10. Within 720 operating hours of incinerator startup stack testing shall be conducted to verify compliancewith the air contaminant emission limits established via Condition 6 herein. (This activity completed)

-11-

AR3I8997


11. Testing shall include 3 trial bum runs (with an optional additional trial burn) plus additional mini bruns. During these tests, the soils feed material to the incinerator will be spiked with the following

* quantities of materials:

Compound Target Quantity to be Added to the Soils Feed (Ib/hr)

naphthalene 851,4 dichlorobenzene 85arsenic 12beryllium .3cadmium 1.9chromium 6.0lead 74.0

EPA and DEP have determined that no chlorine spiking is going to be done during the trial burn toeliminate any unnecessary risk for the duration of the trial burn and preparatory miniburn. (Thisactivity completed)

12. Approval is granted for testing which shall include at least 1 risk burn (2 runs) during which there willbe no addition of materials to the normal soils feed. (This activity completed)

13. Approval is hereby granted for 1 temperature performance test (3 runs). During the temperatureperformance test the secondary combustion chamber temperature/residence time limitation will besuspended in order to determine the destruction/removal efficiency of the contaminated soilsremediation system while operating with a secondary combustion chamber temperature below 1800°F.

14. All testing and analysis shall be conducted in accordance with the source test sampling and analysisprotocols specified in "Trial Burn Plan for the Drake Chemical Superfund Site Mobile HazardousWaste Incinerator" Volume 1 - Trial Burn Plan and Volume II - Project Quality Assurance Plan.

15. During all stack tests, the stack exhaust gases shall be continuously monitored for CO, CO,, NOX andstack velocity. In addition the incinerator and air pollution control equipment parameters delineated inCondition 7B shall be recorded at a minimum of 30 minute intervals during all stack testing activities.Both the continuous monitoring results and the incineration and air pollution control equipmentparameters shall be submitted with the corresponding tests.

16. Testing shall be conducted for dioxin/furans once/month for the 3 months following the initial batteryof tests or longer per contract modification.

17. Testing shall be conducted for particulate matter and metals once every 3 months from the time of fullproduction incinerator startup until termination of incinerator operation.

-12-

AR3I8998


18. Within 60 to 90 days of the completion of the tests referenced in Conditions 11, 12, 13, 16 and 17herein, a test report shall be submitted to the Department. This report shall contain the results of thetests, a description of the testing and analytical procedures actually used in the performance of thetests, the emissions monitoring, the process equipment and air contaminant control equipmentoperating data required by Condition 15 (herein), a copy of all raw field test data and a copy of allcalculations generated during data analysis.

EQUIPMENT INTERLOCKS AND SYSTEM SHUTDOWNS

19. The following conditions shall initiate the automatic shutdown of all waste feed materials to the kilnwhile retaining fuel firing capabilities:

A. Kiln firing hood or kiln disengaging chamber pressure greater than -.1 inches water column for 10seconds or greater than 0 inches water column instantaneously.

B. Secondary combustion chamber discharge temperature less than 1801 °F.

C. Carbon monoxide concentration in stack gas exhaust greater than 100 ppmv for 1 hour rollingaverage; or greater than 200 ppmv instantaneously; or loss of signal.

D. Stack gas flow greater than 46.2 fps (hourly average).

E. Failure of both secondary combustion chamber burners.

F. Caustic/water scrubbing solution flow to either of the packed bed acid gas scrubbers less than 450gpm.

G. Acid gas scrubbing solution pH less than 6.5 for 1 hour.

H. Differential pressure across the baghouse less than 1.0 inches water column.

I. Nitrogen oxide emissions greater than 300 ppmv (daily average); or loss of signal. NOxaveraging to start 2 hours after soil feed to kiln is initiated.

J. Kiln discharge gas temperature less than 1000 F instantaneously or the hourly rolling average lessthan 1599 F. (Note: Waste feed may continue if the instantaneous kiln temperature is > 1599°F.)

K. Failure of both kiln burners.

L. Kiln dry ash conveyor stopped.

M. Kiln rotation less than .4 rpm.

-13-

AR3I-8999


N. Thermal relief valve (TRV) on secondary combustion chamber not closed.

O. Solids feed rate hourly average greater than 47.3 tons/hr.

20. The following conditions shall initiate an emergency system shutdown that stops waste feed, fuelfeeds. ID fan and opens the TRV.

A. I.D. fan failure.

B. Evaporative cooler discharge gas temperature greater than 500°F.

C. Electrical power failure.

D. Acid gas scrubber inlet temperature greater than 250°F.

21. The following conditions shall initiate the automatic shutdown of all waste feed and fuel feed:

A. Secondary combustion chamber discharge gas temperature greater than 2600°F.

B. TRV open (except afterburner startup during which fuel can be fed).

22. The following conditions shall initiate the automatic shutdown of all kiln waste and fuel:

A. Kiln discharge temperature greater than 2200°F.

B. TRV open (except afterburner startup during which fuel can be fed).

GENERAL CONDITIONS

23. None of the air contaminant control equipment shall be bypassed during the soil feed (except as notedin Condition 20 herein).

24. If fugitive dust emissions are observed from the ash storage facility additional steps must be taken toeliminate these emissions including but not limited to the installation of strip curtains to cover the opensections of wall and the areas of vehicle ingress and egress if these steps prove inadequate to controlthe dust (as determined by the Department) then OHM Remediation Services Corp. or its agent mustdetermine additional steps to remedy the emission.

25. The Department shall be immediately notified of any operation of the equipment or malfunction of thesources or associated air contamination control devices which results in, or may possibly be resultingin. the emission of air contaminants in excess of the limitations established herein or specified on anyapplicable rule or regulation contained in Article III of the Rules and Regulations of the Department ofEnvironmental Protection.

-14-

AR319000


26. Upon completion of remediation of the on site contaminated soils at the Drake Chemical SuperfundSite the operation of the PY*ROX 8212 rotary kiln incinerator shall be terminated. No materials otherthan contaminated soils from the Drake Chemical Superfund Site shall be processed through thesubject contaminated soils remediation system (aside from the minor quantities of spiking materials tobe used during stack testing or lime products used for soil conditioning, or clean soil used for testingequipment).

27. If fugitive emissions are visible from any of the ash conveyors additional control measures must beimplemented to eliminate the fugitive emissions.

28. The operation of the contaminated soils remediation system shall not at any time result in violation ofChapters 121 through 143 (relating to Air Resources) nor Chapters 264.340 through 264.353 (relatingto Hazardous Waste Incineration) all sections of Title 25 of the Pennsylvania Code.

29. Any notification required as a result of any condition herein should be directed to: David W.Aldenderfer, Environmental Program Manager, Air Quality, 208 West Third Street, Suite 101,Williamsport, PA 17701, telephone (717) 327-3637.

-15-

AR31900I

ROUTING OF SHOP DRAWINGS, EQUIPMENT DATA, MATERIAL SAMPLES, OR MANUFACTURER'S CERTIFICATESOF COMPLIANCE FOR APPROVAL

(Used to route ENG Form 4025 with items attached. Not to become a part of the Contractor's record)__ FROM: " DATE———————

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES OHM REMEDIAL SERVICES CORPORATION!__ 208 WEST 3RD STREET | 180 MYRTLE STREET I

WILLIAMSPORT, PA 17701 LOCK HAVEN, PA 17745 FEBRUARY 4 11

ATTN; SANDRA DOWNS____________________________________ATTN: ANTHONY GARCIA__________________________________

The attached items listed on ENG Form 4025 are forwarded for approval action

P-i-iiS'CONTRACT NUMBER CONTRACTOR r" ' ~"——" 'llffl DACW4S-93-C-0200 OHM REMEDIAL SERVICES CORPORATION

PlftRANSMiTTAL NUMBERS " ~~~" ~ " PROJECT TITLE AND L O C A T I O N ' — '~~331 DRAKE CHEMICAL SUPERFUND SITE, LOCK HAVEN, PA.

flpCOMMENTS (Attach additional sheet, if necessary.)

ilaNIOSH METHOD Sii i DECEMBER 1997

li||:NIOSH METHOD 5518 AIR MONITORING REPORT FOR 2-NAPHTHYLAMINE

SSS NO OF INCL. TYPED NAME AND TITLE SIGNATUREPip 1 TO PADER ANTHONY T. GARCIA IWK S TO AREA ,-,_____________QUALITY CONTROL MANAGER_________________________.______

TO:

2

IFgCOMMlNTS (Attach additional sheet, if necessary.)

iSSlcbMMENTS (Attach additional sheet, if necessary.)

"S*»JNO. OF INCL. TYPED NAME AND TITLE SIGNATURE

TO: ~"" FROM: DATE

The following action codes are given to Hems listed on ENG Form 402S:jACTION CODES

iji

A - APPROVED AS SUBMITTED, D - WILL BE RETURNED BY SEPARATE CORRESPONDENCE.

fp~ e - APPROVED, EXCEPT AS~NOTED ON DRAWINGS. E - DISAPPROVED (SEE ATTACHeD)S?:* RESUBMISSION NOT REQUIRED.Pf si F- RECEIPT ACKNOWLEDGEDB~ C - APPROVED, EXCEPT AS NOTED ON DRAWINGS.iSil REFER TO ATTACHED SHEET. RESUBMISSION REQUIRED. G - OTHER (specify)

is ACTION CODES TO BE INSERTED IN COLUMN G. SECTION 1,ENG FORM 4025 (Attach sheets, when required.)

j ITEM NO. • - i 1 -| (Taken from ENG Form 4025)

ii CODE GIVEN ' "'$ ^ _ .. ._ _ _. _

ggsf REMARKS

TYPED NAME AND TITLE ' " SIGNATURE

ENG FORM 4026 EDITION OF NOV 66 MAY BE USED. * U.S. G.P.O.: 1988-523-108

AR31 9002

ROUTING OF SHOP DRAWINGS, EQUIPMENT DATA, MATERIAL SAMPLES, OR MANUFACTURER'S CERTIFICATESOF COMPLIANCE FOR APPROVAL

(Used to route ENG Form 4025 with items attached. Not to become a part of the Contractors record)

TO: " FROM: ~ ~"~ ' ' -•- • -PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES i OHM REMEDIATION SERVICES

208 W. 3RD STREET 1 80 MYRTLE STREET FEBRUARY 3, 1998WILLIAMSPORT, PA 17701 LOCK HAVEN, PA 17745

m ATTN: SANDRA DOWNS ___________________________ AT™: ANTHONY GA_RCJA_ ____ _

* Trie attached items listed on ENG Form 4025 are forwarded for approval action

'. " ' "" "CONTRACTOR ~ —————— ~" — _ . , .DACW45-93-C-0200 OHM REMEDIATION SERVICES, CORPORATION

TRANSMITTAL NUMBERS " " ~ ~ PROJECT TITLE AND LOCATION ~"329 . DRAKE CHEMICAL SUPERFUND SITE, LOCK HAVEN, PA.

^COMMENTS (Attach additional sheet, if necessary.)!=:^TECHNICAL DIRECTIVE 28

itlOSHA METHOD 93 SUMMARY REPORT/,

TYPED NAME AND TITLE" ~"~ ' ' " ' """ SIGNATURlANTHONY T. GARCIA

QUALITY CONTROL MANAGER- - -

COMMENTS (Attach additional sheet, if necessary.)

,FROM. , ^^ T/ - - - //" ' 7—— DATE

COMMENTS (Attach additional sheet, if necessary )"~ ~ - - - - - - - - _. .. — _

NO. OF INCL.'" "' ;TYPED NAME AND TITLE - SIGNATURE

TO: """"" '• ----- -••- -• • PROM: • DATE

4.

_ __ __ _ ______ _ The following action codes are given to items listed on ENG Form 4025: 'AC'tiON CODES """ " " " ' " """ " ~ ------- --- - - - -- ••- . - -

A-APPROVED AS SUBMITTED. . . D - WILL BE RETURNED BY SEPARATE CORRESPONDENCE.

B-APPROVED, EXCEPT AS NOTED ON DRAWINGS. E - DISAPPROVED (SEE ATTACHED)RESUBMISSION NOT REQUIRED.

F- RECEIPT ACKNOWLEDGEDC - APPROVED, EXCEPT AS NOTED ON DRAWINGS.

REFER TO ATTACHED SHEET. RESUBMISSION REQUIRED. G - OTHER (specify)

ACTION CODES TO BE INSERTED IN COLUMN G, SECTION I, ENG FORM 4025 (Attach sheets, when required.)

ITEM NO.KSK8S ' (Taken from ENG Form 4025) '

___ _ _ ________ . I__ __ __

l-NO.OFINCL. TYPED NAME AND TITLE SIGNATURE

ENG FORM 4026 EDITION OF NOV 66 MAY BE USED. _ n , A ^ rS W*- G.P.O.: 1988-523-1081 NOV 74 AR3190C13

Documents

Pennsylvania Department of Environmental Protectionevaporative cooler such that the temperature of the gases exiting, the evaporative cooler are lowered to approximately 400 F-450