August
28,
2002
MEMORANDUM
SUBJECT:
Eastman
Chemical
Company
Site
Visit
Report
FROM:
Ivy
Porpotage
TO:
Ron
Josephson,
EPA
The
completed
Site
Visit
Report
for
the
April
17,
2002
visit
to
Eastman
Chemical
Company,
Tennessee
Division
is
enclosed
with
attachments.

If
you
have
any
questions
please
call
Ivy
at
(
703)
934­
3564.
SITE
VISIT
REPORT
EPA
Contract
No.
68­
W­
02­
006
Work
Assignment
No.
2
Facility:
Eastman
Chemical
Company
Kingsport,
Tennessee
Date:
Wednesday,
April
17,
2002
Time:
8:
00
am
­
3:
30
pm
BACKGROUND
In
August
1999,
the
Chemical
Manufacturers
Association
(
CMA),
now
the
American
Chemistry
Council
(
ACC),
submitted
a
paper
to
the
EPA
describing
regulatory
options
for
revising
the
RCRA
mixture
and
derived­
from
rules
as
part
of
the
Hazardous
Waste
Identification
Rule
(
HWIR).
CMA
was
concerned
that
the
mixture
and
derived­
from
rules
resulted
in
the
regulation
of
low
risk
wastes
as
hazardous
wastes,
and
that
the
HWIR
process
was
not
providing
regulatory
relief
in
a
timely
manner.
In
November
1999,
EPA
published
a
proposal
to
promulgate
the
mixture
and
derived­
from
rules
on
a
final
basis
and
solicited
comments
on
the
five
regulatory
options
suggested
by
CMA
(
64
Fed.
Reg.
63382).
In
July
2000,
ACC
resubmitted
these
regulatory
options
and
expressed
concern
that
the
final
rule
would
not
meet
public
expectations
concerning
the
over
breadth
of
the
rule.
The
final
rule
(
66
Fed.
Reg.
27266),
published
in
May
2001,
retained
the
revisions
proposed
by
EPA
in
1999.
EPA
is
now
readdressing
HWIR
and
reconsidering
the
alternatives
proposed
by
ACC.
As
an
ACC
member
and
a
regulated
entity,
Eastman
Chemical
Company
invited
EPA
to
visit
its
Tennessee
Division
facilities.

INTRODUCTION
Eastman
Chemical's
Tennessee
operations
were
established
in
1920
to
produce
methanol
for
Eastman
Kodak.
In
1994,
Eastman
Chemical
Company
became
an
independent
company
headquartered
in
Kingsport,
Tennessee.
The
Kingsport
site
includes
approximately
6,000
acres
of
land
between
the
South
Fork
Holston
River
and
the
Big
Sluice,
though
the
main
plant
site
occupies
858
acres.
Eastman
produces
more
than
1,000
chemicals,
fibers,
and
plastics.

A
wastewater
treatment
facility
(
WWTF),
used
to
treat
wastewaters
from
various
manufacturing
areas,
processes
25
million
gallons
of
wastewater
daily.
The
wastewater
treatment
process
is
depicted
in
Figure
1.
Wastewater
is
neutralized
and
then
mixed
with
microorganisms
that
consume
and
digest
the
organic
wastes.
These
microorganisms
consume
99.5%
of
the
organic
material.
The
process
produces
treated
water,
which
is
returned
to
the
South
Fork
Holston
River,
and
a
biosludge
filter
cake.
This
filter
cake
is
subject
to
RCRA
under
the
mixture
and
derivedfrom
rules.
Eastman
Chemical
Company
Page
3
Site
Visit
Report
OBJECTIVES
The
objectives
of
this
visit
were
to
give
EPA
a
tour
of
Eastman's
WWTF
and
to
provide
EPA
with
information
regarding
the
impacts
of
the
mixture
and
derived­
from
rules
on
a
regulated
entity.

PARTICIPANTS
Both
representatives
of
EPA
and
representatives
of
the
Tennessee
Department
of
Environment
and
Conservation
(
TDEC)
were
invited
to
visit
the
Eastman
facility.
The
following
personnel
participated
in
part
or
all
of
the
day's
activities.

EPA
Representatives:
Laura
Burrell
Matt
Hale,
Deputy
Director,
Office
of
Solid
Waste
(
OSW)
Barnes
Johnson,
Director,
Economics,
Methods,
and
Risk
Assessment
Division,
OSW
Ron
Josephson
Frank
McAlister,
Chief,
International
and
Special
Projects
Branch
(
ISPB)
Zubair
Saleem
Steve
Kroner
Ivy
Porpotage
(
ICF
Consulting)
TDEC
Representatives:
Bethanie
Glynn
Rick
Whitson
Eastman
Representatives:
John
Barber
Etta
Clark
Nancy
Dotson
Janet
Evans
Art
Meyers
Bethany
Thompson
Gerald
Wrye
David
Sandidge
SUMMARY
OF
FACILITY
TOUR
The
facility
tour
began
at
approximately
8:
30
am
after
a
short
introductory
meeting.
Participants
boarded
a
small
bus
for
a
driving
tour
narrated
by
a
retired
Eastman
employee.
The
first
units
observed
during
the
tour
were
the
4
lift
stations
used
to
transfer
wastewaters
to
the
WWTF.
Each
lift
station
handles
5,000
gal/
min
for
a
total
of
approximately
28
million
gal/
day.
Eastman
pumps
a
total
of
400
million
gal/
day
of
river
water
from
the
South
Fork
Holston
River
Dam
(
controlled
by
the
Tennessee
Valley
Authority)
to
be
used
in
cooling
towers
and
for
various
processes.
The
next
point
of
interest
was
the
hazardous
waste
incinerator.
The
incinerator
is
used
to
burn
solvents,
lab
wastes,
commercial
chemicals,
acids,
ketones,
alcohols,
toluene
and
Eastman
Chemical
Company
Page
4
Site
Visit
Report
methyl
ethyl
ketone,
among
other
waste
streams.
The
organic
destruction
efficiency
for
the
incinerator
is
typically
99.9999%.
A
wet
scrubber
utilized
by
the
incinerator
transfers
scrubber
water
to
the
WWTF
at
a
rate
of
500
gal/
min.

Additional
facility
information
provided
during
driving
tour:

°
Eastman
recycles
one
million
lbs/
year
of
acetic
acid.
°
The
powerhouse
utilizes
electrostatic
precipitators
to
remove
99.9%
fly
ash
from
the
air.
°
Eastman
is
the
largest
manufacturer
of
polyethylene
terephthalate
(
PET).
°
The
facility
uses
58
carloads
(
5,800
tons)
of
coal
per
day.
°
The
railcars
are
used
to
transfer
products
to
Savannah,
Georgia
for
overseas
shipment.
°
Approximately
800
railcar
switches
per
day
are
made
on
the
tracks.
°
Eastman
is
a
large
producer
of
polymers,
fibers,
and
cigarette
filters.
°
The
Holston
Army
Ammunition
Plant
adjacent
to
Eastman
manufactures
explosives
for
the
Department
of
Defense.
°
Approximately
1,200
waste
streams
are
approved
for
discharge
through
the
WWTF.
°
The
Environmental
Management
Information
System
(
EMIS)
is
used
to
track
every
stream.
°
Process
upsets
trigger
the
national
discharge
alert
system
and
close
the
WWTF.
°
Approximately
8,500
of
16,000
Eastman
employees
are
located
at
Kingsport.
°
The
facility
has
an
on­
site
fire
department
employing
seven
full­
time
fire
fighters.
°
A
hydrogen
plant
on
site
produces
all
the
hydrogen
used
in
Eastman's
processes.
°
Both
continuous
and
batch
processes
for
chemical
manufacture
are
operated
at
the
Kingsport
facility.
°
A
coal
gasification
plant
for
chemical
manufacture
was
constructed
on
site
in
1983.
°
The
benzene
reported
by
Eastman
to
EPA
is
from
refueling
cars
and
trucks;
benzene
is
not
used
in
chemical
processes.

The
coal
gasification
process
uses
a
wet­
ground,
high­
sulfur
coal
and
a
high­
oxygen
catalyst.
Spent
coal
is
sent
to
a
landfill.
Syn
gas
from
the
system
goes
through
a
cleanup
process
and
is
used
to
make
acetic
anhydride
and
methanol.

Wastewater
Treatment
Facility
Following
the
driving
tour
of
the
site,
Bethany
Thompson
conducted
a
walking
tour
of
the
WWTF.
The
building
housing
the
influent
pump
(
and
process
headworks)
was
observed.
The
system
includes
six
influent
pumps
and
five
are
typically
used.
Wastewaters
enter
the
system
at
a
rate
of
18,000
gal/
min
through
three
main
influent
lines
(
36­,
30­,
and
24­
inch
lines).
Wastewaters
entering
the
system
are
usually
high
in
acetic
acid
content
with
a
pH
of
3.0
to
3.2.
About
50
truckloads
of
lime
are
added
daily
in
the
neutralization
tanks.
Ms.
Thompson
explained
that
the
grit
chamber
changes
the
flow
of
the
wastewater.
The
grit
(
primary
sludge,
made
up
mostly
of
plastic
pellets)
settles
out
through
the
conical
bottom
of
the
chamber
and
is
dropped
onto
the
biosludge.
This
primary
sludge
is
about
2/
3
(
two
thirds)
wastewater.
Post­
Eastman
Chemical
Company
Page
5
Site
Visit
Report
neutralization
wastewaters
have
high
head
lines
of
approximately
40
to
80
gal/
min.
The
wastewaters
flow
from
the
grit
chamber
to
two
equalization
tanks
with
a
2.4
million
gallon
capacity
each.
The
diversion
basins
are
used
for
very
high
loads
or
rainfall
events.
The
basins
are
always
open,
but
the
annual
flow
is
generally
less
than
one
percent.

Following
equalization,
four
trains
of
the
wastewaters
flow
through
a
splitter
box
with
weir
gates
into
the
aeration
basins.
The
wastewaters
are
step­
fed
into
the
three
aeration
basins
(
55%,
25%,
20%)
for
each
of
the
four
trains.
Wastewaters
are
introduced
into
the
basins
at
a
depth
of
20
to
22
ft.
Eastman
has
five
subsurface
air
blowers
and
uses
coarse
bubble
aeration.
Only
three
blowers
are
operated
in
the
winter
and
four
in
the
summer.
The
flow
into
the
aeration
basins
is
17
to
18
gal/
min
and
a
temperature
of
95o
F
is
maintained.
The
hydraulic
retention
time
is
slightly
more
than
one
day.
Samples
are
collected
from
the
aeration
basins
to
check
the
pH.
Ammonia
or
phosphoric
acid
may
be
added
to
adjust
the
pH;
however,
the
wastewaters
do
not
have
significant
variation
since
Eastman
operates
mostly
continuous
processes.
The
biomass
added
depends
on
the
load;
however,
in
the
first
stage
it
ranges
from
3,000
to
4,000
mg/
L.
The
target
sludge
age
is
11
to
12
days
but
may
be
longer
during
the
winter.

Polymer
is
added
to
the
wastewaters
following
aeration
and
rapid
mix,
just
prior
to
the
clarifiers.
The
addition
of
polymers
before
the
clarifiers
works
better
than
before
the
rapid
mix
because
of
shearing.
The
four
clarifiers
are
operated
in
parallel
and
pull
the
sludge
from
the
center
of
the
unit.
About
90%
of
the
sludge
is
returned
to
the
aeration
basins.
Ms.
Thompson
pointed
to
seven
(
unlined)
RCRA
surface
impoundments
adjacent
to
the
WWTF.
These
surface
impoundments
served
as
the
original
treatment
process,
but
are
now
used
for
effluent
holding.
Eastman
does
not
intend
to
close
these
surface
impoundments
in
the
near
future.
Groundwater
monitoring
samples
collected
in
the
vicinity
are
usually
well
below
drinking
water
standards
or
are
non­
detect.
Samples
are
collected
annually
for
Appendix
IX
parameters
and
quarterly
for
metals
analysis.
A
risk
assessment
conducted
for
the
retrofit
variance
indicated
no
off­
site
movement
of
these
groundwaters.

Ms.
Thompson
explained
that
the
sludge
exiting
the
clarifiers
is
eventually
co­
combusted
with
coal.
Spray
irrigation
was
examined
at
one
point
in
time,
but
did
not
work
well
due
to
runoff
and
other
problems.
The
sludge
is
sent
for
dewatering
immediately
following
the
clarification
process.
The
hazardous
waste
boilers
used
for
combustion
of
the
sludge
also
have
toluene
and
acetic
acid
as
feeds.
The
combustion
units
are
operated
24
hours/
day
by
five
operators.
Ash
from
the
boilers
is
Bevill­
exempt
and
sent
to
an
on­
site
Subtitle
D
landfill.

Janet
Evans
indicated
that
samples
are
collected
at
the
combined
interceptor,
before
the
headworks,
for
gas
chromatography
(
GC).
The
influent
is
tested
for
total
organic
carbon
(
TOC)
and
pH.
Samples
are
collected
from
the
equalization
tanks
for
TOC,
pH,
phosphorus,
and
ammonia
analyses.
The
GC
sampling
is
conducted
daily
to
establish
the
appropriate
biomass
load.
Operators
attempt
to
maintain
a
target
level
of
dissolved
oxygen.
All
sampling
is
reported
under
the
Superfund
Amendments
and
Reauthorization
Act
(
SARA),
though
no
reporting
is
required
for
the
influent
under
any
regulation.
Eastman
Chemical
Company
Page
6
Site
Visit
Report
Incinerator
Residues
The
chlorine
feed
to
the
incinerator
is
50
to
60
lbs/
hr
during
normal
operations,
though
500
lbs/
hr
were
fed
during
the
trial
burn.
Eastman
attempts
to
keep
the
dioxin
levels
from
the
incinerator
below
the
detection
limit
for
the
new
Maximum
Achievable
Control
Technology
(
MACT)
standard.
No
current
dioxin
data
are
available.
Dioxin
reported
in
the
2001
Toxics
Release
Inventory
is
from
a
1986
data
point.
Approximately
80%
of
the
dioxin
is
believed
to
be
disposed
in
the
ash,
which
goes
to
a
land
disposal
unit.
A
modified
Universal
Treatment
Standard
(
UTS)
analysis
is
conducted
on
the
ash,
as
well
as
the
8270/
8260A
analyses
for
organics.
Approximately
280
total
constituents
are
analyzed
in
the
ash
and
data
are
maintained
in
EMIS.
Incinerator
scrubber
water
makes
up
about
three
percent
(
500
gal/
min)
of
the
wastewater
stream
entering
the
WWTF
and
is
the
source
of
toluene
in
the
influent.

WWTF
Control
Room
The
tour
group
was
subsequently
led
to
the
control
room
where
Doug
Cross
explained
the
monitoring
process
for
the
WWTF.
The
monitoring
process
follows
the
waste
stream
from
the
lift
stations
through
the
WWTF.
Pumps
and
level
indicators
are
checked
as
well
as
pneumatic
indicators.
The
lime
in
the
neutralization
tanks
is
measured.
Small
deviations
cause
an
alarm
which
the
operator
investigates.
The
monitoring
also
ensures
that
the
grinders
are
working,
as
well
as
the
recycle
valve.
Each
component
of
the
WWTF
is
monitored
in
a
similar
manner.

Dewatering
Building
Around
10:
00
am
the
tour
group
was
escorted
into
the
dewatering
building
where
belt
filter
presses
are
used
to
squeeze
water
from
the
sludge.
Eastman
intends
to
install
a
new
filter
press
that
will
increase
the
solids
ratio
and
decrease
the
amount
of
wastewaters
requiring
incineration.
The
current
filter
cake
is
approximately
15%
solids.
Wastewater
from
the
clarifiers
first
enters
the
gravity
drain
and
then
flows
through
to
the
pressure
zone
into
the
belt
filter
presses.
Grit
from
the
grit
chamber
is
dropped
into
the
de­
watered
sludge
in
this
building.

Biosciences
Laboratory
Art
Meyers
led
the
last
portion
of
the
tour
in
the
Biosciences
Laboratory,
which
is
accredited
through
the
National
Environmental
Laboratory
Accreditation
Program
(
NELAP).
Bio­
solids
are
captured
and
examined
in
the
laboratory
to
ensure
adequate
biodegradation.
The
level
of
bioabsorption
versus
biodegradation
varies
by
chemical.
Mr.
Meyers
displayed
a
projection
of
the
sludge
at
the
microscopic
level,
explaining
that
the
filamentous
organisms
may
be
an
indication
that
additional
ammonia
is
needed
in
the
process.
He
also
discussed
EMIS,
which
Eastman
uses
to
approve
streams
for
entry
into
the
WWTF.
Streams
that
are
not
approved
by
him
may
be
incinerated
or
treated
in
another
manner.
In
the
Aquatic
Ecology
portion
of
the
Biosciences
Laboratory,
the
tour
group
observed
the
fathead
minnows
used
in
biomonitoring.
Eastman
Chemical
Company
Page
7
Site
Visit
Report
The
monitoring
begins
when
the
eggs
are
fertilized
and
testing
is
conducted
once
the
larvae
have
hatched.
Compliance
tests
are
conducted
to
evaluate
mortality
and
reproduction.

At
12:
30
pm
the
tour
group
was
escorted
back
to
the
administration
building
for
lunch
and
presentations
by
Eastman
personnel.

SUMMARY
OF
PRESENTATION
AND
DISCUSSION
Impacts
of
Mixture/
Derived­
from
Rules
on
Eastman
Gerald
Wrye
began
the
presentation
with
a
discussion
of
the
impacts
of
the
mixture
and
derivedfrom
rules
on
Eastman.
Eastman's
primary
concern
is
that
the
regulations
focus
too
much
on
the
history
as
opposed
to
the
characteristics
of
the
waste
streams.
Eastman
currently
manages
waste
under
Subtitle
C
that
would
be
managed
as
non­
hazardous
under
Subtitle
D
if
it
were
categorized
based
on
its
characteristics.
Most
of
the
waste
streams
of
concern
are
F002,
F004,
or
F005
listed
wastes.
There
are
a
few
U
wastes,
but
no
K
wastes.
The
solvents
are
currently
managed
in
the
incinerator
or
the
WWTF.
Organic
wastewaters
from
throughout
the
Eastman
facility
that
cannot
be
managed
in
the
WWTF
are
transferred
to
the
incinerators.
Greater
than
50%
of
these
wastewaters
are
hazardous
wastes,
but
only
about
0.5%
are
listed
wastes.
Because
this
small
amount
of
listed
waste
is
fed
to
the
incinerators,
the
scrubber
water
is
hazardous
under
the
derived­
from
rule.
Figures
2
and
3
show
the
hazardous
waste
inputs
to
both
the
WWTF
and
the
hazardous
waste
incinerator.

The
Kingsport
facility
has
three
RCRA
incinerators.
They
are
currently
working
on
meeting
the
MACT
standards
for
these
incinerators
and
have
completed
the
updates
for
two
of
them.
Incinerator
ash
is
managed
on
site
in
a
hazardous
waste
landfill
along
with
contaminated
soils
and
refractory
brick.
A
derived­
from
F039
waste
is
subsequently
produced
from
the
landfill.
Groundwater
monitoring
wells
in
the
vicinity
of
the
landfill
have
had
very
small
amounts
of
F039.
Both
the
F039
waste
and
the
scrubber
water
are
sent
to
the
WWTF;
however,
the
total
amount
of
F039
entering
the
WWTF
is
negligible.

Listed
hazardous
wastes
(
generally
spent
solvents)
make
up
only
0.014%
of
the
wastewater
entering
the
WWTF.
Under
the
mixture
rule,
the
25
to
29
million
gal/
day
of
wastewater
exiting
the
WWTF
are
considered
hazardous
wastes.

Eastman
has
found
phenolics
to
be
the
most
difficult
chemicals
to
treat
using
biodegradation.
Sanitary
wastewaters
from
the
facility
are
sent
to
the
City
of
Kingsport.

Biosludge
from
the
WWTF
makes
up
more
than
75%
of
the
non­
wastewater
hazardous
waste
on
site
and
is
a
big
concern
for
Eastman.
The
de­
watered
biosludge
is
sent
to
hazardous
waste
boilers.
The
ash
produced
by
these
boilers
is
Bevill­
exempt
and
is
disposed
in
an
on­
site
Subtitle
Eastman
Chemical
Company
Page
8
Site
Visit
Report
D
landfill.
Mr.
Wrye
noted,
however,
that
they
are
still
required
to
conduct
significant
analyses
to
meet
40
CFR
266
Subpart
H
requirements.
One
problem
for
Eastman
is
waiting
for
the
analytical
results
while
accumulating
large
quantities
of
ash.

The
following
waste
streams
are
generated
as
a
result
of
the
mixture/
derived­
from
rules:

°
10.5
billion
gallons/
year
wastewater
°
234
million
lbs/
year
biosludge
°
63
million
lbs/
year
boiler
ash
(
Bevill­
exempt)
°
3.9
million
lbs/
year
incinerator
ash
°
small
quantities
of
F039
The
stream
of
most
concern
to
Eastman
is
the
biosludge.
If
the
biosludge
was
exempted
they
would
still
burn
it
in
boilers
as
a
non­
hazardous
waste
or
use
it
as
a
feed
to
the
gasification
system.
They
would
still
be
subject
to
MACT
standards
and
air
emissions
regulations.
The
hazardous
categorization
for
the
biosludge
prevents
them
from
looking
at
beneficial
uses.
If
the
sludge
were
exempted,
the
small
quantities
of
liquid
hazardous
wastes
currently
fed
to
the
boilers
would
be
directed
elsewhere.

Mr.
Wrye
reiterated
that
the
biosludge
has
very
small
amounts
of
hazardous
waste
from
the
original
waste
stream
and
Eastman
would
like
it
to
be
evaluated
on
its
own
characteristics.
Some
questions
were
asked
about
attempts
by
Eastman
to
do
a
mass
balance
around
the
WWTF.
Eastman
responded
that
the
system
is
too
complex
and
that
the
recycle
and
volatilization
make
the
calculations
difficult.
Ron
Josephson
suggested
that
Eastman's
efforts
may
have
been
overly
complex.
It
was
also
suggested
that
if
Eastman
was
able
to
do
direct
monitoring
under
the
headworks
rule,
they
might
be
able
to
get
rid
of
the
scrubber
water.
Ms.
Evans
noted
that
they
would
still
report
hazardous
waste
once
a
year
so
they
could
maintain
their
permit
on
the
surface
impoundments,
which
they
don't
want
to
close.
Mr.
Josephson
asked
whether
Eastman
had
ever
pursued
a
site­
specific
delisting.
Ms.
Evans
remarked
that
they
had
spent
a
lot
of
time
and
effort
with
no
luck,
but
they
have
accumulated
a
lot
of
data.

Removal
of
Chemicals
in
Wastewater
Treatment
John
Barber
presented
an
overview
of
the
wastewater
treatment
process
and
the
removal
of
chemicals.
His
slides
are
included
in
this
report
as
Appendix
A.
He
began
with
a
brief
summary
of
the
methods
of
treatment
including
biodegradation
and
hydrolysis
and
then
discussed
surface
volatilization
and
sorption.
The
removal
alternatives
vary
by
groups
of
compounds.
For
instance,
volatile
organics
can
be
treated
using
both
biodegradation
and
volatilization,
but
heavy
metals
can
only
be
treated
using
sorption.
Mr.
Barber
further
described
the
mechanisms
involved
in
the
sorption
of
heavy
metals
to
biosludge.
Eastman
Chemical
Company
Page
9
Site
Visit
Report
Next
he
discussed
the
determinations
that
are
used
for
the
SARA
report.
Eastman
uses
analytical
data,
when
available,
including
National
Pollutant
Discharge
Elimination
System
(
NPDES)
monitoring
reports,
sludge
analyses
for
the
boilers,
gas
chromatography
for
the
influent,
Universal
Treatment
Standards
(
UTS)
analyses
for
Land
Disposal
Restrictions
(
LDR)
compliance
on
clarifier
overflow,
and
additional
special
sampling.
Data
produced
from
a
commercial
modeling
software,
Toxchem,
are
also
used.
Eastman
has
a
15,000­
gallon
pilot
plant
next
to
the
lab
and
had
originally
used
an
in­
house
modeling
software.
They
found
that
samples
using
this
model
were
lower
than
predicted
and
resulted
in
an
overestimation
of
air
emissions.
Toxchem
allows
the
user
to
build
the
treatment
plant
model
and
borrows
chemical
characteristics
from
Chem
9/
Water
9.

Mr.
Barber
presented
six
charts
outlining
the
data
from
Toxchem.
These
charts
have
been
included
as
Appendix
B.
The
summary
chart
for
removal
efficiency
depicts
the
percent
of
a
number
of
volatile
organics
that
are
lost
to
the
air
and
to
the
sludge,
and
the
percent
that
are
removed
during
treatment.
Two
volatile
organics
charts
depict
the
amount
of
several
volatile
organics
in
the
influent
and
then
in
the
sludge
using
total
and
TCLP
analyses.
A
similar
chart
is
included
for
several
semi­
volatile
organics.
Finally,
the
two
metals
charts
depict
the
amount
of
several
metals
in
the
influent
and
then
in
the
sludge
using
total
and
TCLP
analyses.

Economics
The
next
presentation
by
Janet
Evans
described
the
economic
consequences
of
a
RCRA
designation
for
Eastman's
biosludge.
Her
presentation
slides
have
been
included
as
Appendix
C.
Management
of
the
biosludge
in
tanker
trucks
invokes
the
RCRA
container
standards,
and
the
inspection
and
recordkeeping
requirements.
The
combustion
of
the
biosludge
is
subject
to
extensive
RCRA
management
requirements,
recordkeeping,
and
permitting.
Ms.
Evans
further
described
the
uncertainties
in
the
RCRA
requirements
for
this
340­
ton­
per­
day
waste
stream.
The
dewatering
processes
rely
on
the
wastewater
treatment
tank
exclusion.
There
are
concerns
with
Bevill
exclusions
affecting
the
management
of
31,000
tons
of
coal
ash
(>
50%
coal
must
be
maintained
in
boiler).
Ms.
Evans
also
stated
that
the
hazardous
designation
limits
Eastman's
flexibility
in
considering
other
waste
management
options.
For
instance,
significant
amounts
of
the
waste
can't
be
shipped
out
for
research
because
the
research
facility
would
also
be
required
to
have
a
permit.
Eastman
Chemical
Company
Page
10
Site
Visit
Report
Next,
Ms.
Evans
addressed
the
annual
operating
costs
associated
with
Eastman's
RCRA
boilers
and
incinerators.
These
costs
include:

1.
Additional
personnel
$
500,000
2.
Additional
low
metals
coal
premium
$
250,000­$
500,000
3.
Low
metals
analysis
$
150,000
4.
Bevill
test
costs
(
outside
analyses)
$
10,000
5.
Systems
materials
and
maintenance
$
5,000
6.
Continuous
emission
monitors
materials
and
maintenance
$
60,000
7.
In­
house
weekly
and
daily
sludge
analyses
$
30,000
8.
Certification
of
Compliance
Testing
$
100,000
TOTAL
ANNUAL
COST
$
1,105,000
­
$
1,355,000
Additional
costs
for
permitting
of
RCRA
BIF
units
and
compliance
with
BIF
MACT
standards
include:

1.
Risk
assessment
data
collection
$
500,000
2.
Trial
burns
$
700,000
3.
Establishing
operating
conditions
and
negotiating
permit
$
500,000
4.
Permitting
fees
$
150,000
5.
Installation
of
new
APC
equipment
$
61,000
6.
Increased
annual
operating
costs
$
3,000,000
Eastman
provided
EPA
and
TDEC
participants
with
two
sets
of
data
which
have
been
included
in
Appendices
D
and
E.
The
first
is
2000
SARA
Report
wastewater
treatment
data.
The
second
is
data
for
the
biosludge
(
without
grit)
spanning
from
July
1999
to
January
2002.

Ms.
Evans
again
addressed
the
delisting
issue,
indicating
that
Eastman
had
been
told
delisting
wasn't
applicable
to
thermal
treatment.
Clean
fuel
exemptions
are
not
very
useful
since
the
limits
are
generally
at
the
detection
levels.
There
is
the
potential
for
an
outlier
data
point
with
long
term
sampling
which
may
make
a
facility
out
of
compliance.
Considering
the
large
number
of
constituents,
such
low
limits
create
problems
with
variability
and
certainty.
She
suggested
a
need
for
a
rolling
average
or
confidence
level
and
stated
that
the
exit
levels
proposed
under
HWIR
in
the
past
were
too
low.
Efforts
to
obtain
a
delisting
have
been
unsuccessful
for
Eastman.
Ms.
Evans
added
that
the
hazardous
constituents
in
the
biosludge
come
from
characteristic
wastes
and
not
from
the
spent
solvents.

Matt
Hale
and
Mr.
Josephson
both
agreed
that
it
is
harder
to
get
out
of
the
system
than
it
is
to
get
in.
Barnes
Johnson
remarked
that
risk­
based
tools
are
usually
available
when
establishing
criteria,
making
this
particular
effort
more
difficult.
Modeling
with
combustion
also
gets
to
be
complicated.
Mr.
Hale
pointed
out
that
EPA
is
dealing
with
a
wide
range
of
potential
situations
which
lead
to
conditions.
EPA
is
held
to
a
high­
level
analysis
and
has
to
justify
why
each
condition
makes
sense.
Using
conditions
on
a
national
level
will
invite
criticism
for
each
Eastman
Chemical
Company
Page
11
Site
Visit
Report
assumption.
Mr.
Johnson
noted
that
the
options
for
risk
based
conditions
have
changed
and
that
the
3MRA
(
Multimedia,
Multipathway
and
Multireceptor
Risk
Assessment)
model
is
no
longer
used.
He
added
that
constituency
groups
now
want
data
for
the
person
standing
at
the
fence
line
of
the
facility.
These
proposed
revisions
require
setting
risk­
based
levels,
which
will
be
an
area
of
substantial
contention.
EPA
is
already
dealing
with
such
contention
for
the
Headworks
rule.

Mr.
Josephson
briefly
described
the
areas
of
interest
to
EPA
in
consideration
of
the
proposed
Headworks
exemption.
The
first
is
obtaining
data
for
the
four
solvents
proposed
by
ACC.
EPA
is
considering
direct
monitoring
as
a
demonstration
of
compliance,
but
the
reporting
burden
becomes
a
big
issue
with
this
alternative.
Ms.
Evans
interjected
that
the
reporting
burden
would
be
offset
by
the
decrease
in
current
recordkeeping
requirements,
which
are
overly
extensive.
Mr.
Josephson
noted
that
EPA
is
trying
to
evaluate
what
data
are
available
for
the
risk
analysis
efforts
and
is
considering
where
facilities
should
be
conducting
the
monitoring.
EPA
does
not
want
a
one­
size­
fits­
all
model.
In
terms
of
the
de
minimis
loss
exemption,
EPA
is
considering
whether
there
are
regulatory
controls
that
can
be
used
if
F
and
K
wastes
are
included.

Mr.
Josephson
also
identified
incinerator
scrubber
water
and
multi­
source
leachate
as
areas
of
interest.
Ms.
Burrell
asked
if
the
facility
does
any
monitoring
of
their
scrubber
water.
Ms.
Evans
responded
that
there
is
virtually
no
monitoring,
other
than
checking
the
percent
solids.
When
the
scrubber
water
went
to
the
city
it
was
monitored,
but
it
hasn't
been
since
the
late
1980s.

Etta
Clark
asked
whether
EPA
would
consider
site­
specific
exclusions
aside
from
delistings
and,
if
so,
how
Eastman
would
explore
this
alternative.
Mr.
Hale
noted
that
the
route
for
a
sitespecific
exclusion
would
be
through
the
Region
or
state
and
not
EPA
Headquarters.
He
also
suggested
that
such
an
effort
would
invoke
priority
and
resource
issues
for
EPA.
The
delisting
process
was
specifically
set
up
to
address
site­
specific
considerations.
Nancy
Dotson
noted
that
the
Eastman
facility
is
very
big
with
many
processes
and
chemicals
and
indicated
that
it
becomes
difficult
and
complex
to
do
a
delisting.

Mr.
Johnson
remarked
that
there
seemed
to
be
two
different
stories
being
made.
First,
that
if
the
waste
is
not
considered
hazardous,
the
boilers
wouldn't
have
trial
burns
and
there
would
be
less
burden
in
operating
them.
Secondly,
if
the
waste
is
taken
to
the
gasifier,
then
the
boilers
could
be
shut
down,
and
the
efficiency
would
be
a
lot
greater.
Ms.
Dotson
stated
that
they
would
still
have
MACT
and
air
emissions
standards
to
comply
with
under
the
first
scenario.
However,
it
wasn't
clear
what
MACT
standards
would
apply
if
the
waste
was
non­
hazardous.
Mr.
Johnson
stated
that
EPA
is
looking
at
the
net
environmental
impact
and
will
continue
to
explore
gasification.

The
meeting
was
concluded
at
approximately
3:
30
pm
and
Ms.
Dotson
remarked
that
she
would
work
on
getting
invitations
for
EPA
from
other
ACC
members.
FIGURE
1
WASTEWATER
TREATMENT
FACILITY
FLOW
DIAGRAM
FIGURE
2
WASTEWATER
TREATMENT
YEARLY
OUTPUT
FIGURE
3
WASTEWATER
TREATMENT
HAZARDOUS
WASTE
FLOW
APPENDIX
A
REMOVAL
OF
CHEMICAL
COMPOUNDS
IN
WASTEWATER
TREATMENT
PLANTS
APPENDIX
B
TOXCHEM
DEMONSTRATION
CHARTS
APPENDIX
C
ECONOMIC
CONSEQUENCES
OF
RCRA
DESIGNATION
APPENDIX
D
BIOSLUDGE
DATA
APPENDIX
E
SUMMARY
OF
WASTEWATER
TREATMENT
SARA
COMPOUNDS
APPENDIX
F
SITE
VISIT
PHOTO
LOG
