                                       
MEMORANDUM

Date:		June 6, 2013

Subject:	Report of May 31, 2013 Site Visit to Tradebe, East Chicago, IN

From:		Tanya Parise, EC/R Incorporated
		
To:		Mary Tom Kissell, U.S. Environmental Protection Agency



      This memo summarizes the site visit to the Tradebe facility in East Chicago, IN, which was conducted on May 31, 2013.  The purposes of this visit were to:
      
          * Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 
          * Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
          * Clarify any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility.

	The participants in the site visit included the following:

      Tradebe Environmental Services, LLC
      Tita LaGrimas  -  Executive VP of Regulatory Affairs 
      Robert Vaughn  -  Environmental Compliance Manager
      
      US EPA
      Mary Tom Kissell
      
      EC/R Incorporated 
      Lesley Stobert
      Tanya Parise
      
This memo includes a brief overview of this project, an overview of the Tradebe facility, and is followed by a description of the specific information gathered during the visit.  

BACKGROUND
      
      Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, CAA section 112(d) requires us to promulgate technology-based national emission standards for each major source category listed under section 112(c).  These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards.  The National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Off- Site Waste and Recovery Operations were promulgated on July 1, 1996 (61 FR 34140), and codified at 40 CFR part 63, subpart DD. The final rule was amended on July 20, 1999 (64 FR 38950).  
      
      In the second stage of the regulatory process, the EPA is then required under CAA section 112(d)(6) to review these technology-based standards and revise them "as necessary (taking into account developments in practices, processes, and control technologies)" no less frequently than every eight years. In addition, within 8 years after promulgation of the MACT standards, CAA section 112(f)(2) requires the EPA to promulgate standards, if required, to provide an ample margin of safety to protect public health or to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect.
This second stage in standard setting is referred to as the residual risk and technology review (RTR) for the standards.

      The EPA is in the process of conducting the RTR for the OSWRO MACT standards. As part of the RTR process, this Tradebe facility was selected for a site visit for three primary reasons: (1) it is one of several OSWRO facilities in the Chicago, IL area, which would enable the EPA to see several facilities in one trip, (2) based on available emissions data in the EPA's National Emissions Inventory (NEI), this facility had one of the higher emission rates of the OSWRO facilities identified in that database, and (3) understanding of the facility suggests that this facility is similar to, but different than, and has other operations than the Clean Harbors, Dolton, IL facility.  

PLANT SITE OVERVIEW
      
      The Tradebe Environmental Services, LLC facility is located at 4343 Kennedy Avenue, East Chicago, IN, which is in the greater Chicago, IL area. Tradebe is a hazardous waste management and recycling company. The company's core business at the East Chicago location is recycling. At this site, Tradebe receives waste, including solvents, solvent mixtures, solid and semi-solid materials, and aqueous chemicals, and processes the waste through material handling, fuel blending, and fractional distillation equipment for resale where possible, and waste that is not suitable for onsite treatment is sent offsite to a 3[rd] party facility for incineration, landfill or other means of treatment and/or disposal. The facility is mainly an organic recycling facility. The East Chicago Tradebe facility is also a depack facility. A lab pack is a container consisting of various small containers of chemicals, solvents, industrial supplies, etc. that come from school labs, hospitals, medical facilities, and so on, which must be disposed of properly. The depack facility at Tradebe safely and efficiently handles four specific groups of chemicals (i.e., flammable liquid, corrosive acid, corrosive caustic, flammable solid); with the chemical group processed in individual booths. Tradebe also depacks and consolidates chemicals; the original manufacturer's chemical container is removed from a depack container, evaluated and then placed into a container used for shipping the material off-site. Lastly, the East Chicago Tradebe facility also handles Universal Wastes that are generated by businesses and regulated households. Such waste includes batteries, pesticides and products that contain mercury, such as fluorescent bulbs and thermostats, and this waste is shipped offsite for recovery or disposal. Tradebe's objective is to ship waste for recovery where possible. 
      
      The operations are continuous, with operations occurring 24 hours a day, 7 days a week. The facility receives waste from many businesses. This facility is a RCRA part B plant and also subject to the OSWRO MACT (subpart DD). The Tradebe facility is in a heavy industrial area of East Chicago, IN, roughly 20 miles outside of downtown Chicago, IL.

INFORMATION GATHERED DURING VISIT

	The following section describes the information gathered in relation to the three stated purposes of the visit. 

   1. Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 

 This facility was previously owned by Pollution Controls Industries, which was acquired by Tradebe Environmental Services in 2008 and renamed to Tradebe in 2011. The facility began operations in 1986 at this location. 
 Loads are received via truck. The facility is primarily a drum handling company with a drum storage capacity of 13,750, 55 gallon drums. 
 The facility has a tank farm, a lab pack/de-pack facility, a drum consolidation and handling building, recycling units and a non-hazardous processing building. The facility has four distillation units.
 The facility reviews the profile sheets/manifests of the shipments and then samples between 10-100% of the containers received. 
 When sampling potentially waste-derived fuel, the facility looks for mercury, the BTU content, chlorine, moisture, PCBs, etc. 30% solids is the limit.
 When materials are approved to come in, they first are evaluated for reuse, (if the material can be used as is). If not, they determine whether it can be distilled (thin film, pot still, liquid and solid distillation) that will create a reusable recycled product. If neither of these activities can be done, the material is sent offsite to an approved 3[rd] party facility for treatment/disposal.  
 The facility uses a flare and carbon adsorbers as the primary control devices; there are two small scrubbers and a baghouse in the depack building and two baghouses in use at the site.
 However with carbon being expensive, according to Tradebe personnel, the facility is evaluating a non-regenerative thermal oxidizer. Tradebe indicated the thermal oxidizer is expensive and that it will be a big decision whether to purchase it. If a purchase is made, Tradebe will provide information on the thermal oxidizer to the EPA.

   1. Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
            
 The facility complies with the RCRA standards at 40 CFR part 264, subparts AA, BB, and CC. The facility representatives indicated that the requirements of the RCRA standards were nearly identical to the 40 CFR part 63, subpart DD standards, and that by complying with the RCRA standards, only an additional report or two was required to comply with subpart DD.

   1. Clarify any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility.
            
 Although not specifically requested in the information collection request, Tradebe noted a concern regarding the current subpart DD equipment leak requirements. Regarding the requirements to physically tag leaking equipment, Tradebe indicated that the tags are expensive, use of man-hours to replace the tags that could sometimes fall off, and in Tradebe's opinion, better methods are available that would achieve the same goal (i.e., on site schematics). Ms. LaGrimas indicated she would send an e-mail with these specific concerns for the EPA's equipment leaks group to consider.

