BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

1

1

PROPOSED AMENDMENTS TO THE

R06-20

BOARD'S

SPECIAL WASTE

1

(Rulemaking -Land)

REGULATIONS CONCERNING

USED OIL, 35 ILL.

ADM. CODE 808,809

)

ADDITIONAL TESTIMONY OF THEODORE J. DRAGOVICH

My name is Theodore Dragovich. I am the manager of the Disposal Alternatives Unit in

the Bureau of Land Permit Section of the Illinois Environmental Protection Agency ("Agency").

I was present and testified at the first hearing in this matter on May 25,2006. At that hearing,

the Illinois Pollution Control Board ("Board") requested that the

~

~

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n

c

~

  

provide a response to

questions raised by the Board's panel. I submit the following testimony in response to those

inquires and in response to the testimony of

NORA at the May

251h hearing.

1.

Exempt only used oil or also materials regulated as used oil:

The Agency believes that only used oil and not materials subject to regulation as used oil

should be exempt from manifests. There are two main reasons for this decision: to encourage

proper recycling and to insure proper management of wastes that are added to used oil.

As defined in 35

Ill. Adm. Code 739 ("Part

739"), used oil is oil that has been used and

has been

contaminated through use. Other materials that are added to used oil

aAer it has been

generated, that are not themselves used oil, do not become used oil, but become regulated as

used oil because they contain used oil. These other wastes may exhibit characteristics different

from used oil and may be managed differently when separate from used oil.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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Part 739 was adopted by the Board in the identical

in substance rulemaking of

40

CFR

279 ("Part 279").

The United States

~nvironmental

Protection Agency ("USEPA") formulated

Part 279 to regulate as used oil materials that contain used oil or are contaminated with used oil

until the free flowing oil is removed.

USEPA considered this approach more restrictive since

they do not regulate non-hazardous waste management prior to disposal.

USEPA in promulgating Part 279 acknowledged that the states may impose other

regulations on both used oil

i

d

  

the used oil contaminated materials. Prior to the used oil

regulations in Part 279 and Part 739, all nonhazardous pollution control wastes and industrial

process wastes including used oil were regulated as special waste in Illinois. The

USEPA Part

279 subjected non-hazardous material contaminated with used oil to federal regulation for the

first time. Therefore, to exempt all materials regulated under Part 739 from special waste

manifest and permitting requirements would reduce the regulatory requirements for special waste

that has been mixed with used oil.

It is the Agency's belief that an exemption from manifest that is extended to materials

regulated as used oil will lead to more waste being mixed with used oil after generation. Illinois

has a system to regulate non-hazardous special waste transportation, storage treatment and

disposal. These wastes are different from used oil as defined in Part 739 and the impact of

managing these wastes solely as used oil has not been evaluated. Therefore the Agency does not

believe it is appropriate to encourage

mixing other wastes into used oil by offering a manifest

exemption for the mixture.

USEPA has identified the regulatory requirements for used oil mixed

with hazardous waste, but the Agency has not evaluated the impact of regulating non-hazardous

waste that has been mixed with used oil after generation solely under the used oil regulations.

For these reasons, the Agency believes that other non-hazardous wastes mixed with used oil after

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

generation must be subject to both the used oil standards and the appropriate waste management

standards that applied to the waste before the mixture occurred.

However, to clarify, materials that are added to the used oil that are not wastes would not

become subject to the used oil manifesting or additional waste management requirements if

the

material is a fuel. NORA members testified that diesel

fuel is sometimes added to the used oil

by the generator.

USEPA has previously concluded that the diesel fuel is not waste because it is

a fuel and will still be used for a fuel after it is mixed with the used oil. (See the attached

November 30, 1998,

USEPA letter from

Cotsworth to

McPoland, RCRA Online Number 14305.)

The Agency bas also concluded that the used oil and diesel fuel mixture is regulated under

Section

739.110(d) and not 35

Ill. Adm. Code 807 ("Part 807").

Furthermore, NORA members testified that it would be burdensome for the used oil

transporter to determine if the used oil has been adulterated with other wastes.

he^ concluded

that all materials regulated as used oil should receive the exemption from manifest. However, it

is the waste generators obligation to complete the manifest and provide it to the transporter and it

is the generators responsibility to

determine the type and quantity of the waste. NORA testified

that it is not possible for the transporter to make a determination in the field if the used oil is

adulterated after use. However, other than the rebuttable presumption at Section 739.144,

nowhere in Part 739 or Part 809 does it require the transporter to determine if the used oil has

been mixed with other waste. The generator will be responsible for completing a manifest when

the generator mixes the used oil with other special waste that is not exempt

f?om manifests. The

manifest will alert thetransporter that the used oil contains other special waste. Therefore, the

Agency does not see that limiting the manifest exemption to used oil as defined in Part 739 as

burdensome to the transporter.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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Wastes are more amenable to recycling when they are segregated.

USEPA made clear

that they encourage the segregation of waste streams to make them more amenable for

reclamation. (See 57 FR 41581 dated September 10, 1992.)

In other words they do not

encourage mixing other wastes into used oil destined for recycling. The

USEPA regulations at

Part 279 were designed to address used oil contaminated through use. (See 57 FR 41574 dated

September

10,

1992.) The Agency believes it is likely that other waste added into the mixtures

(e.g., inks, solvents and coolants) will not be recycled, but will be burned with the used oil or

treated in a waste water treatment unit. Some of the wastes added to used oil which

will be

blended for fuel do not have fuel value themselves and may contain constituents that are not

appropriate to bum in that setting. In the attached letter from Michael Shapiro to Douglas Green

dated August 14, 1996,

USEPA stated that oil contaminated materials must have a heating value

of 5,000

BTUs to be burned for energy recovery. The Agency believes that if the other wastes

are kept separate by the generator, the potential that these

wastes will be recycled in an

appropriate manner is higher.

In addition, NORA testified that material that is collected and ultimately sold for fuel is

subject to more stringent testing and examination to find concentrations of materials that might

be problematic. However, the used oil specification in Part 739 only establishes limits for

arsenic, cadmium, chromium, lead, flash point and total halogens. Other constituents could be

present in special waste that is not used oil that would be problematic when added to the used oil.

These constituents could reduce viscosity or BTU content or increase ash content or emissions

from burning the oil. Mixtures of used oil and other special waste that were subject to regulation

as used oil could meet the specification in Part 739 for used oil and still not be marketable

&

a

used oil

fuel. Some examples of waste that have been mixed with used oil and managed under

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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Part 739 include: plastic pellets, carbon filter media, surfactants, water based paint, water based

ink, emulsion solutions,

graidwatedoil mixture, cleaning compound, sludge, wash water, super

abrasive, sand tank sludge, water based coolants and barge bilge water.

There is a fundamental difference between exempting used oil as defined and managed in

compliance with Part 739 and exempting materials subject to regulation under Part 739. This is

because these materials are not used oil but are only subject to these regulations because they

contain used oil. Used oil as defined in Part 739 includes the oil and the contaminants that are

mixed with the oil during use. The Agency is concerned with other materials that

ire added to

the used oil after it is generated. These materials may not behave like used oil and therefore the

use of a manifest that accompanies the load would be beneficial to emergency response

personnel and the end receiver of the materials. The used oil tracking system does

notrequire

that the shipping paper accompany the load.

The Department of Transportation regulations only

include requirements to manifest shipments of hazardous materials. Other shipping documents,

such as a log or bill of lading that may be required by the Department of Transportation for

shipments that are not hazardous materials may mislead the reader to believe that the cargo is

only used oil when it could be mainly other wastes mixed with used oil.

In sum, the Agency's position is that the addition of other wastes to used oil after

recycling should be discouraged because it makes the used oil and other waste less amenable to

recycling. The exemption of these materials

born the manifest and hauling requirements after

mixing with used oil may, in fact, encourage this type of mixing. Other materials added to the

used oil after generation should only be exempted

from the manifest and hauling requirements if

the exemptions currently existing in Sections 809.210 or 21 1 apply. The language proposed to

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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the Board by the Agency is still the best alternative and the Agency objects to the language

proposed by NORA in the errata.

2. Language added to Sections

809.301,302 and 501:

The Board asked if the language added to Sections 809,301,302 and 501 creates the risk

of doubt whether the eleven exemptions in Section 809.211 still apply to Sections 809,301,302

and 501. The Agency does not believe that adding this language will impact the other

exemptions found in Part 809.

Used oil transporters may transport other special waste on the same load. This could

occur in separate containers, separate compartments, or within the same compartment. Used oil

transporters may also use the same truck to transport exclusively used oil on one load and at

other times to transport other special wastes that are not regulated under Part 739. Therefore, the

additional language in Sections

809.301,302 and 501 is necessary to specify two separate

exemptions, a manifest exemption and a hauling permit exemption. The manifest exemption will

work independently from the hauling permit exemption because a generator would be exempt

from initiating a manifest if the waste given to the transporter is only used oil as defined and

managed in accordance with Part 739; the transporter would not be exempt from the hauling

permit requirements unless all the loads that are picked up by that truck are used oil as defined

and managed in accordance with Part 739. The transporter may choose to pick up other loads of

non-exempt waste, but must have a haulers permit and a manifest for the non-exempt waste.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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3.

Quantity of manifests:

The Board asked the Agency to identify the number of manifests that were bought by

used oil facilities. The Agency has identified the number of manifests purchased by facilities

that notified of their used oil activity. The numbers provided may not be an accurate

representation of the number of manifests that accompany used oil shipments for two reasons:

the used oil notifiers may have used some of these manifests for the transportation of non-

hazardous special waste that is not used oil; and the count does not include used oil generators

that purchased their own manifests, but are not registered used oil facilities. With that in mind,

the total number of manifests purchased from the Agency by registered used oil facilities was

determined to be 525,824 in a two and one half year period or 210,330 manifests per year.

Considering that some of the registered used oil facilities' main business is non-hazardous

special waste other than used oil the Agency's best estimate is that of these 525,824 manifests

about 168,650 manifests were purchased to transport used oil in a two and one half year period

or 67,460 manifests per year. NORA may be able to provide better statistics on the percentage

of waste managed by NORA members that is not regulated as used oil and also what percentage

of NORA members' customers purchase their own manifests. It should also be noted that

NORA testified to business growth of 25% per year. No growth factor has been included in

these estimates. Therefore, the Agency estimates that the number of shipments of used oil that

would be exempt from manifesting is about 67,460, but could be more than 210,330 shipments

per year.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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4. Reporting requirements:

The Board also asked the Agency about the effect of an exemption on the reporting

requirements. Although Section 739.157 requires

processors to send a biennial report to

USEPA

concerning their used oil activities, the Agency relies on the annual non-hazardous special waste

report in Section 809.501 to collect information on used oil. Pursuant to Section 809.501

generators that ship special waste out-of-state must provide an annual report of the waste they

have shipped out-of-state. Also, treatment, storage and disposal facilities located in Illinois must

submit a report to the Agency regarding special waste received at their facility and special waste

shipped out-of-state from the facility. In the report, the generators and facilities designate the

amount of used oil separately from other special waste. Therefore the Agency would maintain

that any used oil exempt from manifesting as a result of this

rule making is still subject to the

annual reporting requirements of Section 809.501.

In addition, the Board asked the Agency if eliminating manifesting requirements will in

any way frustrate recordkeeping

effortsof the Agency under the special waste rules. If the Board

expands the manifest exemption to materials regulated as used oil in Part 739 as NORA requests,

there will be confusion as to the annual non-hazardous waste reporting requirements of Section

809.501 because it will be unclear whether the quantity of used oil that is reported is used oil as

defined in Part 739 or the total quantity of special waste regulated as used oil. The used oil

regulations do not specify a minimum amount of used oil that must be mixed with non-hazardous

special waste before the non-hazardous special waste becomes subject to regulation as used oil,

so the waste may be mainly waste that is not used oil as defined in Part 739. Limiting the

manifest exemption to used oil as defined and managed in accordance with Part 739 as the

Agency requests and maintaining the reporting requirements for used oil from Section 809.501

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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will establish a bright line where only used oil as defined in Part 739 would be reported as used

oil, while all other non-hazardous special wastes would be reported together.

5. Manifest and tracking requirements for other states:

NORA testified that Illinois is the only state that classifies used oil as a special waste or

requires generators to manifest used oil. A quick review of some other states used oil

requirements indicates that the requirements do vary

from state to state and some other states do

have specific state hauling and recording keeping requirements, even though they do not

designate the used oil as special waste. For instance, Alabama requires a hauler to have a

Alabama Hazardous Waste

and/or Used oil Transporter Permit (Ala. Adm. Code

335-14-17-.05),

California requires a modified hazardous waste manifest (Health and Safety Code, Section

25250.8b), and Michigan requires a permitted transporter (Mich. Adm. Code R 299.9812) and a

manifest (Mich. Adm. Code R 324.12103). Also, Missouri requires transporters to have a

Missouri Hazardous Waste Transporter License and use a "Transporter's Used Oil Shipment

Record"

on forms provided by the state (10 CSR 25-1 1.279). New Hampshire requires that used

oil be transported by a New Hampshire

permittedhazardous waste transporter and be

accompanied by a three-copy bill of lading

(N.H. Adm. Code R. Env-Wm 807.07). Both New

Jersey

(N.J.A.C.

7:26A-6.6(g)) and South Carolina

(SC

ADC 61-107.279) require a manifest.

And Wisconsin requires a used oil transporter to obtain a solid waste transportation license

(NR-

590,

Wis.

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.

  

Code).

The Agency acknowledges that regulation does vary by state but contends that Illinois is

not the only state that has imposed

morestringent transportation

requirements. NORA has stated

that all materials regulated as used oil should be included in the exemption to be consistent with

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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other states. But the regulations for the management of used oil are not consistent between other

states, as just illustrated.

The Agency supports the exemption from manifests and hauling

permits for used oil that is defined and managed in accordance with Part 739, not because it will

make the regulations consistent with other states, but because the used oil tracking and

transportation requirements in Part 739 are adequate for the tracking and transportation of used

oil as defined and managed in

accordancewith Part 739.

In addition, no detailed review has been conducted of the impact of exempting special

waste from Parts 807,808 and 809 when the waste is managed in accordance with Part 739 and

the non-hazardous regulations do not contemplate the regulatory requirements for non-hazardous

waste that is mixed with used oil and becomes subject to regulation as used oil. The wording

proposed by NORA would exempt any non-hazardous waste once a small amount of used oil has

been added to it. But the Agency insists that other non-hazardous special wastes be evaluated

separately to determine if they should be exempted from hauling permits and manifests, not

exempt because the waste was mixed with used oil and not because other states allow an

exemption.

6.

Removal of Board note in Part 739:

During the hearing, the Board asked NORA whether, in

NORA'S opinion, the Board

Notes

in'part 739 regarding state special waste hauling permits requirements would still apply.

The note in question explains that generators of small quantity used oil that transport their own

used oil or have a contractual hauler may still be subject to the hauling permit requirements in

Part 809. Although NORA believed the note would become irrelevant, the Agency believes this

note is still necessary because the used oil may be transported along with other special waste that

is not used oil.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON.

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20460

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1998

OFFICE OF

SOLID WASTE

AND

EMERGENCY

RESPONSE

Ms.

Fran

McPoland

Federal Environmental Executive

Office of

the

Federal Environmental Executive

401 M Street SW (MC 1600)

Washington, DC 20460

. .

Dear Ms.

Mc~oland:

Thank you for your lener regarding the regulatory status of used oil that is mixed

with'^^-

8 fuel under the federal

usedoil management standards (40 CFR Part 279). You asked if JP-8

fuel mixed with used oil from military vehicles would meet the exemption at 40 CFR

279.10(d)(2) for

mixtwes of used oil and diesel fuel that are burned in a generator's own

vehicles.

Used

OiVDiesel Fuel

Mixrure Exempiion

The Used Oil Management Standards

~pecificall'~

exempt from the used oil regulations

mixtures of used oil and diesel fuel on the conditions that

(1) a used oil generator only mixes

used oil that they generate on-site and (2) such mixtures are used as fuel in the generator's own

vehicles (see 40 CFR

279.10(d)(2)).

.Prior to mixing, the used oil

issubject to the used oil

generator requirements of

40 CFR 279 subpart C.

Used

Oil/JP-8

Mixtures

JP-8 is a multipurpose fuel similar to diesel Fuel, and it is

bumed in diesel-type engines in

military vehicles. Based on the

informalion you provided, the U.S.

Anny is proposing to mix

used oil they generate

with JP-8 fuel and burn it in their own trucks in the same way that many

trucking companies mix their used oil with diesel fuel lo be burned in their own trucks. For the

purposes of the exemption for used oil and diesel fuel mixtures, JP-8 can be considered to be

analogous to diesel fuel. Therefore, mixtures of used oil and JP-8 are exempt from the used oil

regula~ions

if

thcy are managed in

accol.dance with 40 CFR

279.10(d)(2).

ATTACHMENT

1

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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. .

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Clrtrn

Air

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40 CFR

279,10(d)(2) excludes used oil and diesel' fuel or IP-8 Fuel mixtures from only

:

the Used Oil Management Standards.

It does nor preclude or supersede regulation under the

,

Clean Air Act (CAA) or any

other

applic?.blc laws. Please be aware that mixtures of used oil and

JP-8 that are burned, and any engines or vehicles in which they are burned, are still subject to any

applicable regulations promulgated under the

CAA. Depending on how the mixture is

accomplished, and by whom, sections

202(a)(4), 203,

206(a)(3)(b), and 21

I(a)-(f) of the CAA

may place restrictions on such a practice as it relates to motor vehicles. For further infomiation

on these restrictions, please contact Mr. Bmce Fergusson ((202) 564-1261) or

Mr. Rich

~ckerman'((202)

564-1301) of the Office of Enforcement and Compliance (OECA)

andlor Mr. David Kortum ((202) 564-9022) of

the Office of Mobile Sources (OMS).

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Sfale

Specijic

Regularions

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States may adopt regulations that are more stringent ihen the federal used oil regulations.

A

In fact, some states regulate used oil as hazardous waste

and others do not allow

burning

df

used

oil. Many states also have comprehensive air quality

programs that may restrict burning of used

oil/JP-8 fuel mixtures. The Army should contact each state in which they would like to conduct

used

oil/JP-8 mixing for a state specific regulatory determination.

....

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if

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have any

further'questions

about the

used Oii

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Standards, please

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contact Mike

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at,(703)

308-0046.

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Sincerely,

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Elizabeth A. Cotsworth, Acting Director

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Office of Solid Waste

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cc:

Paul Machiele, OMS

Greg Orehowsky, OMS

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Jane

Armstrong,

OlMS

Dave Kortum, OMS

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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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I

PPC

9592.1996(04)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

SOLID WASTE AND EMERGENCY RESPONSE

I

Douglas Green

Piper and

Marbury

1200 Nineteenth St., NW

Washmgton,

D.C. 20035-2430

Dear Mr. Green:

This letter is in response to Edison Electric Institute's

request for clarification of the applicability of the Used Oil

Management Standards (Part 279) to materials that are contaminated

with used oil and provide little or no energy when burned.

.

.

Unless burned for energy recovery,

makidws

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with..wrl

nil are not

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"the used

oil has

been properly drained or removed to the extent possible such that

no visible signs of free-flowing oil remain in or on the material"

(see, 40 CFR

279.10(c)).

he recycling of any

oil drained from the

material is regulated under Part 279.

Contaminated materials (after draining)

are?-egulated under

.

.. --

Part 279 if

themat

'

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rgy recovery (see 40 CFR

Part

2

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have a high British

thermal unit (BTU) value and once contaminated with used oil are

managed by burning for energy recovery and, therefore, are

regulated under Part 279.

Conta-ter

draining)

which provide little

0-

burned, such as soil or

clay-ksedsorbents, are not subject to Part 279. Whether a

material-is "burned for energy recovery" depends on the type of

materials being burned and the combustion equipment being used.

For purposes of the EPA regulations governing boilers and

industrial furnaces, burning for energy recovery is limited to

materials that have a heating value of at least 5,000

BTUs/pound

(see, 40 CFR

266.100(~)(2)(ii);

56 FR 7134,7143, February

ATTACHMENT

2

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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21,1991). EPA believes it is reasonable and consistent with'

the

regulations to apply the same interpretation under Part 279. Of

-.

~

course, an authorized state may

interpet.

whit constitutes

"burning for energy recovery" more stringently than EPA and that

interpretation could be controlling to the extent that the state's

used oil management standards are in effect (as distinguished from

the federal used oil management standards set

outat 40 CFR Part

279).

Any material from

whch free-flowing used oil has been

drained and that is subject to a hazardous waste determination as

described in 40 CFR Part 262.11 may therefore be subject to

Resource Conservation and Recovery Act Subtitle C regulation as

hazardous waste. Materials that do not meet the definition of

hazardous waste may still be subject to other applicable Federal,

State, and

local solid waste regulations.

,

Thank you for your interest in the safe and proper

management of used oil.

Sincerely,

Michael Shapiro, Director

Office of Solid Waste

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

1

1

PROPOSED AMENDMENTS TO THE

)

R06-20

BOARD'S SPECIAL WASTE

(Rulemaking

-Land)

REGULATIONS CONCERNING

1

USED OIL, 35

ILL..ADM. CODE 808,809

1

My name is

Christopher Cahnovsky. I am Regional Manager for the

Bureauof Land

Collinsville, Illinois Regional Office.

1 have worked in this capacity since 2001.

Previous to this position I was an Environmental Protection Specialist and Life Science

Career Trainee for the Bureau of Land Collinsville Regional Office. I held this position

from 1990 to 2001. During this time, I have conducted over 1,300 inspections at

facilities that generate solid waste. I received a Bachelor of Science in Animal Science

form Southern Illinois University in Carbondale in 1988 and a Master of Science

liom

Southern Illinois University at Edwardsville in 1993. I am a Certified Hazardous

Material Manager. My testimony today will focus on observations made and documents

obtain during inspections at solid waste generators, transporters and receiving facilities

that have co-mingling non-used oil special waste with used oil and managing the mixture

as used oil. In some cases non-used oil special waste was transported directly to a used

oil transfer facility and subsequently managed as used oil.

The attached examples are:

Attachment 1:

Illinois Manifest

IL8097851

Illinois Manifest

IL8097851 shows that 440 gallons of fixer (Not

USDOT or

USEPA

Hazardous Material) was picked up at Schwartzkopf Printing, Inc. on September 3, 1999

by Safety-Ween Systems,

Inc. and delivered to Safety-Kleen Systems, Inc. East St. Louis

Rail Site. Box

J states that Tanker Truck

SK55173 off loaded the fixer into rail car

UTLX67980 at Safety-Kleen's East St. Louis Rail Site. During an October 29, 1999

inspection at Safety-Kleen Systems,

Inc. East St. Louis Rail Site discovered that rail car

UTLX67980 was shipped to Safety-Kleen in Baton Rouge, Louisiana on September 16,

1999 as Used Oil and Water (not

USDOT Hazardous Material). The fixer waste does not

meet the definition of used oil in 35

Ill. Adm. Code 739. It was picked up by

Safety-

Kleen and managed as used oil at Safety-Kleen's East St. Louis Rail Site. This document

was obtained during an October 7, 1999 inspection at Schwartzkopf Printing, Inc. in

Alton, Illinois

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

Attachment

2:

Illinois Manifest

IL8154584 dated March 13, 1998

Safety-Kleen Oil Recovery Placement Form dated March 13, 1998

Generator Used Oil

Certification/Indernnification

dated March 13,

1998

These documents were obtained during an April 2, 1998 inspection of Roger Cartage

Illinois Manifest

IL8154584 shows that 1,492 gallons of Used Oil and Water Mixture

(Not

USDOT Hazardous Material) was picked up from

~ogers

Cartage Company in

Sauget, Illinois by Safety-Ween Corporation on March 13, 1998 and delivered to

Safety-

Kleen Systems,

Inc. East St. Louis rail site.

Tnrough my interviews with plant

per'sonnel

and review of Rogers Cartage records I discovered that the waste on Illinois Manifest

1L8154584 contains sludge and water from a three tank wastewater treatment system

used to treat wastewater from the cleaning of the residues from the insides of tanker

trucks that contained chlorobenzene and international shipping containers that contained

para-nitrochlorobenzene. The service bays where the used oil is generated are not

connected to this wastewater treatment system.

The Safety-Kleen Oil Recovery Placement Form dated March 13, 1998 confirms this by

listing 712 gallons of solids and 100 gallons of wash water were mixed with 680 gallons

of other liquids. Thedocuments also show that the sludge and wastewater were mixed

with Roger Cartages' automotive service used oil. The sludge and wastewater from the

water treatment system do not meet the definition of used oil. The previous shipment of

this waste by Rogers Cartage was managed as a hazardous waste for ignitability

(DOOI).

Attachment

3:

Illinois Manifest

IL8642755

Illinois Manifest

IL8876533

Safety-Kleen Sample Analysis Report for wastewater

&

water

based paint

These documents were obtained during a January 31,2001 inspection at the Canadian

National and Illinois Central rail yard in Centralia, Illinois.

Illinois Manifests

IL8642755 and

IL8876533 show that on July 7, 1999 2,800 gallons and

2,064 gallon, respectively, of water and paint (Not

USDOT or

USEPA Hazardous

Material) were shipped from the Canadian National and Illinois Central rail yard in

Centralia, Illinois to Safety-Kleen Systems, Inc. East St. Louis, Illinois Rail Site. This

paint waste was shipped directly to East St. Louis and mixed with used oil at the East St.

Louis Rail Site. The Safety-Kleen Sample Analysis Report for wastewater

&

water based

paint show that this waste contains barium and methyl ethyl ketone. The Safety-Kleen

Sample Analysis Report for wastewater

&

water based paint approved this wastewater

and water based paint waste stream for its Vacuum Truck Service. The wastewater and

water based paint waste do not meet the definition of Used Oil in 35

111. Adm. Code 739.

This waste was taken to Safety-Kleen's East St. Louis Rail Site and mixed with used oil

and subsequently managed as used oil.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

During inspections, meetings and file reviews at a used oil transporter and used oil

transfer facility I discovered that it is common practice by this transporter to mix non

used oil waste with used oil waste and manage the mixtures as used oil. Some examples

are included in the following attachments.

Attachment 4:

Non-Oil Waste Streams

This document was obtained from Kevin Farmer of Safety-Kleen during a January 26,

2001 meeting. This is a list of non-oil waste streams that Safety-Kleen intends to accept

with used oil and manage as used oil once mixed. The wastes include plastic pellets,

carbon filter media, surfactants, water based paint, emulsion solutions,

grain/oil/water

mixture, cleaning compound, sludge, wash water, super abrasive, sand, tank sludge and

water based coolants.

Attachment 5:

Non-Oil Waste Streams

This document was obtained from Kevin Farmer of Safety-Kleen. The document is a

February 13,2001 revision of the Non-Oil Waste Streams accepted by Safety-Kleen at

their East St. Louis Used Oil Transfer Station. This list includes plastic pellets, carbon

filter media, surfactants, water based paint, emulsion solutions,

grainloillwater mixture,

cleaning compound, sludge, wash water, super abrasive, sand, tank sludge, water based

coolants and barge bilge water.

Attachment 6:

Pages 282 and 283 of a

safety Kleen Facility Waste Report

This document is pages 282 and 283 of a Safety Kleen Facility Waste Report. This 283

page report summarizes all waste received at Safety-Kleen's East St. Louis rail site from

November

1, 1999 to December

3

1,2002. This document shows that the Safety-Kleen

facility accepts combustible liquid, water, wash water, fixer, grease, soil, ink oily sludge,

sludge, waste liquid, mineral oil, oil sludge, diesel, asphalt and combustible liquids. The

aforementioned non-used oil wastes are mixed with used oil and managed by

Safety-

Kleen pursuant to 35

Ill. Adm. Code 739. Safety-Kleen maintains that the East St. Louis

Rail Yard is only regulated under the 35

Ill. Adm. Code 739 regulations.

DATED:

Tc(

n

P

13,

20.06

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield,

1L 62794-9276

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

31363-R4505

(REPRINT)

PREPU4LIFICATION

EVALUATION

PAGE

1

OF

'5

PARTS

LlASHER

SERVICE

COMPLETCD!

0

8/18/99

FLUID

RECOVERY

SERVICES

REVISED:

R

bY:

06i28,

5

9

  

ACCEPT

FOR

SHIPNEIIT

~-

-

f

COIlTROL

t;:

BRAtlCH

SUBt,lITTER:

616033

1935427-6

ST

LOU

S

LAB

#:

9935477-r:

PROFILE

REF

#:

2131955

GENERATOR

INFORMATTON:

CUSTOMER NUMBER:

5160-fi3-3582

SCHWARTZKOPF

PRINTING

4121

HUNBERT

RO

ALTON

I

L

62002

RTTN:.

JIM

SCHIJhRTZKOPP

BR4NCH:

5168'23

-

ST

LOUIS

E

N

R

A

T

O

.

  

$

i

t

~

E

~

~

T

~

~

'

~

!

n

:

  

g°F!tI:I!i

ADDRESS:

BILLING

ComPAtiY

&

ADDRESS:

SCHWARTZKOPF

PRINTINQ

4121 HUMBERT

RD

ALTON

I

L

  

62002

PHONE:

618-

463-

0747

s.1.c.:

27520101

STATUS:

US

EPA

10:

CESQG

STflTE

10:

XL

L190185134

O.

SHIPPING

INFORFlATION:

001'

ASSISTAtIEE

RE

UESTED

ODT

SHI

P

NAXE:

FIXER

( N O T

USOOT O R

U

S

~

P

A

  

~BzARoous

MATERIAL)

HA2

CLASS/OXVISION:

NO

ID+

(UN/NA):

PACK

GRP:

NON- BULK

SHXPPIt4G

COtJTAINERS

-

5

5

POLY

.

OTY:

12

FREQ:

OUARTFRLY

.

ACCEPT

FOR

SHIPMENT

COIITItIUE3

ON

NEXT

PArJE

Attachment

1

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

81363-R4505

(REPRIliT)

PRECUALIFICATION

EVALUATION

PARTS

WASHER

SERVICE

PAGE

2

OF

'5

FLUID

RECOVERY

SERVICES

COAPLETED:

08/18/99

REVISED:

-

-

-

-.-

-.

RUK:

86/28/99

ACCEPT

FOR

SHIPHENT

B?AMCH/SUBMlTTER:

5160C3

COliTROL

L A B

8:

a:

i935477-6

9935477-4

ST

LOUIS

PROFILE

REF

fi:

2131956

C

.

  

GENERAL

MATERIAL

C

REGULATORY

INFORMATIOI{:

(IAME

OF

N A T E R I A L : F I X E R

DEVELOPER

PROCESS

DESCRIPTION8

P

INTING

ODOR:

NONE

R

YES

NO

X

REGULATED

OR

LICENSED

RADIOACTIVE

WASTE

X

REGULATEO

MEDICAL

INFECTIOUS

WASTE

x

WASTE.

SUBJECT

T

o

BLNzEN:

1,EsHAP

REeuLATIoNs

X

TSCA

REGULATED

PCB WASTE

X

REGULATEO

SUBPART

CC

WASTE

(VOC'S

)a

508

PPM)

X

REGULATEO

OZOl4E

DEPLETING

SUBSTANCE

X

C E R C L R R E G U L A T E O

(SUPERFUND)

WASTE

X

HAZARDOUS

DEBRIS

X

WASTE

CONTAINS

UHC'S/OOKSTITUENTS

OF

CONCERN

X

UHC

I

N

SECTION

D

X

UHC

I

N

  

.ADOENDUN

X

NEiTS

LOR

STANDARDS

X

PARTIALLY

MEETS

(FOR

LANOFILL

ONLY)

X

COMMINOLED

WASTE

X

SORBENT

ADDEO

X

BIODEGRADABLE?

X

EXEMPT

WRSTE:

I

F

YES,

LIST REFERENCE

40

CFR

X

STATE

HAZAROOUS

WASTE

X

EPA

HAZARDOUS

WRSTE

STATE

WASTECODES:

TX

OUTS1191

j

P

A

  

WASTE

CODES!

NONE

..

--

--

-.

'"

ACCEPT

FOR

SHiPHEll7

CTRY:

USA

---

CO1:TiHUEO

011

lIEXT

PAGE

ATTACHMENT

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

81353-R4505

(REPRINT)

PREOUALIFICPTIOIJ

E V AL U ATI

O N

PARTS

WASHER

SERVICE

PAGE

3

OF

5

C O M P L E T E D :

08/18/99

FLUID RECOVERY

SERVICES

REVISED:

RUN:

08/i8/99

ACCEPT

FOR

SHIPMENT

-

iOl4TROL

b:

1935477-

6

BRANCH/SUBMITTER:

S

~

S

B

B

J

  

L A B

r:

9935577-5

ST

LOUIS

FROFILE

REF b:

2131955

...............................................................................

0.

MATERIRL

COmPOSITION:

1.

CHERICAL/PHYSICAL

CONSTI

T UENT S:

NO

VOLATILE

O R G A N I C S D E T E C T E D

((0.1%

E ACH )

NOH-

VOLATILE ORGANICS

WATER

CONTENT

2.

ELERENTAL

CONSTITUEIITS

r

THE

FOLLOIJING.VALUES

ASSOCIATED

LJITH

THE

"(" ARE

NON- DETECTED.

THE

VALUE

LISTED

I

S

THE

REPORTING

L

I

~

I

T

.

  

'*'*

ACCEPT

FOR

SHIPMENT

COATINUEO

ON

NEXT

PAGE

Attachment 1

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

81363-R4505

(REPRINT)

PREQUALIFICflTIOti EVALUATION

PARTS

LlASHER

SERVICE

PAGE

4

OF

5

FLLID RECOVERY

SERVICES

COhPLETED:

06/18/99

QCIJJSED:

RUN:

08/28/99

ACCEPT

FOR

SHIPMEhT

CONTROL

b:

1935477 -

6

BRANCH

SUB(8ITTER:

515003

ST

lOUfS

LAB

it:

5935477-4

PROFILE

REF

C

t

  

2131955

-------------------------------------------------------------------------------

F.

NATERIAL

PHYSICAL

CHARACTERISTICS

@

73F:

3

OF

PHASES

1.000

L

IQUID

8

100.300

COLOR

BLUE-GREEtl

VISCOSITY

DENSITY

(50

1

.010

NO

FLASH

FIT

140.000

F

ASH

Z

2.100

WTk

PH

LIQUIDS

)20X

H20

P

H

6.900

RTU'S

/

L8.

OR

RANGE

(

500.000

BTU/LB

COMMENTS:

BULK

DENSITYI

1.01

WATE2

COMPATIBILITY;

COMPATIBLE

O

R

P

O

R

A

T

~

U

I

  

-

UISPOSITIONI

ACCEPT

FOR

SHIP

PART

IIUNBER:

b89C315

B

CS~~RG

WIJ(25tOL

55

REVIEW

DATE:

08/18/1999

REVIEWERS:

RBU

PPRO'JEO

C

iACBAFETY-iLEE~d

SYSTEMS.

1t4c.

z

SAFETY-SLEEN

SYsTENs,

I

Nc.

3700

LAGRANGE

ROAO

1722

COFPER

CREEK

ROAD

SMITHFIELD.

t:Y

40068

OENTOli,

TX

76238

FED

EPAS:

KY0053348108

TX0077603371

STATE

EPAII:

65124

TELEPHONE:

5028452553

9JBdB35200

STATE

AUTH:

PPROV~D

OUT

-

FPYTcl

D

ESCRIP~TT~~-

-

0305478

DRUR

OR

BULK

FIXER

NOT USOOT

OR

USEPA

HPZRRDOUS

MATERIAL1

-6mPROV.

COOTS-TX

OUTS1191'

V

S

EPA

WASTE

CODES:

tlOliE

*

PROPER

SHIPPING

DESCRIPTION

NRS

BASED

OX

THIS

SINGLE

ANALYSIS.

GENERATOR

*

MUST

CERTIFY

THAT

SHIPI~IEIIT I

S

  

NOT

HAZARDOUS.

PER

COllPAIlY

POLICY,

FRS

*

CUSTOr4ERS

MUST

COCIPLETE

GENERATOR

CERTIFICATKON

LJITH EACH

SHIPMENT

'

AND

BRANCH

WILL

FILE

It1

CUSTONER

RECORDS.

*

OK

FOR

LJRSTE

lJAl'ER

FUEL,

lJAS1-i

SHTPPEO

It4

DRUMS

FilOr

THE

CUSTOMERS

SITE

"

XUST

HRVE

A P R C P E R L Y C L O S E D

LIO

OR

BUtlG

PRIOR

TO

SRIPt~lENT.

F

.*r.****r....\**

.,

~

*

*

*

*

*

*

.

.

*

*

i

,

*

*

*

.

.

.

.

*

*

.

*

L

*

.

'

*

*

*

I

*

.

.

.

r

r

l

i

L

,

l

*

\

i

.

+

.

  

.

i

<

r

r

&

.

A

2

.

*

<

A

*

%

"

  

THIS

SERVES

AS

NOTICE

PER

FEDERAL

All0

STATE

REGULATIONS

THAT

EACH

FACILirY

NOI'EO

ABOVE

HAS

THC

APPRO?RIATE-

PEPMIT5.

CAPABILITIES.

CRPhCITY:

AIiD

IS

LJILLING

TO

A C C E P T T H E

MATERIAL

IAS

DESCilIBEO

Iti

THE

APPROVAL

SEiTXON.

IT

I

S

  

THE

RES?ONSIA.ILITY

OF

THE

GENERATOR TO

NOTIFY

SAFETY-KLEEr4

CORP.

OF

~II~Y

CHAllGES

IN

THE

PRQCESS

GEt4ERATXIjJG7,.THIS

WASTE

STREAN.

r

*

a

ACCEPT

FOR

SHIPMENT

CONTINUE0

ON

rlEXT

PAGE

Attachment

1

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

8

1363-R4505

(REPRItiT)

PREOUALIFICATIOf< EVALUATION

PAGE

5

OF.

5

PARTS

LJASHER

SERVICE

COMPLETED:

08/18/99

FLUID

RECOVERY

SERVICES

REVISED:

RIJ~I:

O

~

:

?

R

:

~

S

  

ACCEPT

FOR

SHIPMENT

$RAMZH/SUB!lITTER:

516033

ST

LOUIS

CONTROL

tt:

1935477-

6

LPB

R

:

9

935477-0

PRJFILE

REF

k:

2131955

A D D I T I O N A L A N A L Y T I C A L

RESULT

DESCRIPTION/ELEXEHT

NON-

VOLATILE ORGANICS

PCB

PCB

AMOUNT

OTHER.

RADIOACTIVITY

WATER

COMPATIBILITY

WATER

CONTENT

RESULT

14

ti

0

tl

E

(

1.0

N

G/~:G

N O N E O E T E C T E O

COMPATIBLE

8

6

THE

ANALYSIS

CONTAINED

H

EREIIt

RRE

PERFORmEO

SOLELY

FOR

THE

PURPOSE

OF

QUbLIFYING

THE

AIIALYZEO

AATERIlALS

FOR

ACCEPTANCE

BY

SAFETY-KLEEM

CORP.

I

N

  

ACCORDANCE

WITH

I

T

S

PERMITS

ANO

PROCESSING

CAPABILITIES.

t4OTICE

OF

LAN0

DISPOSAL

RESTRICTIOtl

OF

WflSTE

I

S

NOT

REQUIRED.

I

.

*

,

  

ACCEPT

FOR

SHIPPlEPlT

** TOTAL PffiE.06

**

Attachment 1

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

...

L

11.

US

DOT

besdpllon

(Induding

Pmper

Shipping

Name. Hazard

Class

and ID Number)

a.

USED. OIL

AND

WATER

MIXTURE

(NOT

USDOT

HAZARDOUS

'

MATERIAL

)

I

EMERGENCY

RESP

800-468-1760(

24

HR).

IF

UNDEL~

SK

CORP

AUTHORIZED

TO

RETAIN

LICENSED

SUBSEOl

E

-

I

16.

GENERATOWS

CERTIFICATION: I

hereby

declare

that

me

cmlentn

01

lhlr

mnslgnment

are

IulIy

and

ascuralehl

dercnbed

above

proper

Ullpping

nam

and

are

clsrrilled,

packed.

rnahed,

end

isbeled,

and

are

in 1

remeas

I

n proper

d

~

w

n

  

tor

lranrpod

by

highway

acmding to

ap&%

inlemanmsl and

nahnd

government

regulallmr,

and

lllimis

regulations.

...

......................

.....................................

PrinledITv~ed

Name

Monlh

Day

Year

I

I

I

I

I

IS.

Discrepancy

lndicalion Space

\

I

. 20.

Fqiiily Owner

or

Operalor

hylilication of receipt

ol hazardous

materials

c0ver.d by

lhls

manflst

except as

oaled\C

item 19.

/

I

DATE

C

Monlh

Day

Yea

c

;cld

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

/li

GENERATOR USED OIL

CERTlFlCATlONllNDEMNlFlCATlON

Generator

Information

Date

3-

13-

9$

.P&~L&=

co.

~?~L@uY;~u~:P

S K Customer No

A-

66x2

I

As&~r

,

+r

S K

011

Services Sales Re

/a06

S-K Branch No

c-

/d0-72

Clty

State

ZIP

Oil Certification (check appropriate box)

Used oils generated at this facility originate only from automotive sources. Automotive sources include, but are not limited to, commercial

service

service

slalions, oil change stations, and truck 1 automobile

Heel maintenance.

This facility generates;

(c

t

l

O

O

O

gal I

quarter

41001 gal I

quarter

r

Used oils generated at this lacilily may include oils from sources

otller than automotive including, but not limited to, industrial lubricating

oils, cutting oils, or gear oils.

Ha

rdous Waste Certification (check appropriate box)

This facilily generales less than 100 kg of hazardous waste in a calendar month (approximately 27 gallons), and is classilied as a CESOG.

X

This lacility

generat&,between

100 kg and

1000 kg of

hazardous waste in a calendar month

(approxima!ely 27 to 270 gallons), and is

classified as a SOG.

.

This facility generates more than

1000 kg of hazardous waste in a calendar month (approximately 270 gallons), and is

classiliedas a LOG

Waste Segregation Certification (check if applicable)

This facility has available on-site

the equipment 1 services necessary lo properly segregate

all waste streams generated at the lacility,

and ensure that RCRA hazardous wastes are not mixed

inlo

lhe used oils.

*.

Tolal Chlorine Analysls

.I

Automotive

Oil:

Analysls Not

Aequlred

Automotive Oil Only

I

CESOG

-

Automotive Oil Only and

segregates

the oil lrom

all hazardous wastes

-

Analysis Required

(Complete

information at right)

Chlorine:

-

41000 ppm

-

ciOOO ppm

(If

clOOO

ppni. a sample

musl be sent

to the Tech Center for rebuttal)

lndustrlal 011:

Date of Preshipment

Approval:

Chlorine Test:

1

(must be

perforpjed at the time

of each

service to ensure the oil matches the

preshipment analysis)

i

Generator hereby

certllles

thal the

Intormallon provided above

1s

true and correct. Generator also

certllles that the used

olls

supplled to

Salely.Kleen or its subsidiary

wlll not be mixed,

combined,

or

olharwlse blended

In any

quantity

with

malerlals conlalnlng

polychlortnated

biphenyls

(PCBs), halogenated

solvenls, or any olher material

dellned as hazardous wasle under 40 CFA

Part261 or

applicable

Slat8

fEg~latlOn8.

Generator agrees lo

lndemnltg and

hold

Salety-Kleen or its subsldlary harmless lor any damages, costa,

anorneys and

expem leer,

arlrlnp

oul of or

In

.my way

relaled lo a breath

ol any

al

the above

cedlllcatlons by Generalor.

\-*

.:,,,

*,

\

-

. ,

.C,

!.' .

.~.

SAFETY.KLEEN CORP.

(Signature)

:j

Attachment

2

1000 North Randall Road

Smtl4ltGU

o

Elgin,

Illinois 60123

(Title)

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

I

.

.

  

I

10.

US EPA ID Number

i.

:ra~tsporter's

Phone

i

.>

?aci!itfs

IL

EPA

HW

Nurlbsr

n

..

.

.

-.

'L:.

GENERATOR'S

CERTIFICATION: I

her6i.y declare

that the

contcnls of

lhis consignment are

lvlly and

acc~tal?!:

d6.-tibed above

by

proper shipping name

andare

classified,

oacked. marked, and labeled, and are in all respects in proper

conl!!iu,(

lor

t,ansport by highway

according to applicable

i?ternalional and

?ational

Qovemmenl

regulalions.

1%

Transporter 2

Acknowledgemenl

0:

Recei?!

of

Materials

PrintedJTyped

Name

1

:+

.

7;.

Discrepancy Indication Space

98

lC

I

. .

I

-,

-.

-

.

--

-.

-

.

--.-.!

?.' Facility Owner

or

Operator:

Certification

cl

receipt

of

hazar6our

malariais covered

bj

this

manilesl

except

7.;

:;:',:;$

in

::em

19.

-.

--

-

I.

-.-I

PrintetVryped

~

ame

Signature

?

I

:

  

02:;.

'ai

i

I

,

  

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

-

.

.

-.

..

.

. .

-. . .

.

-.

.

..

.-

-- .

- .

oF

ENvl::OE1MENTAL

PROTECTION AGENCY DIVISION OF LAND

POL1

U

i1CN

COi.ll'nOL

.-

19.

Discrepancy

lndicalion

Space

t

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

SAFETY-KLEEN

SAMPLE ANAL

YSIS

PdPORT

Prequalificntion

TCLP Report

-

ACCEPT FOR

SRIPMEST

PAGE

1

I

S.kiLE

DESCRIPTION:

i

I

WASTE

WATER

&

WATER

BASEC

P.OT

I

1

SK

REPRESENTATIVE:

KEVINLIIILSON

BRANCH#:

503301

I

REPORT DATE:

04:07!1999

CONTROL

#:

1910886-2

SURVEY

k

2015681

Generator: IL CENTRAL

R.VIROAD

600

GILhlORE ST

C!ZNTR.<L\

U

62801

?he enclosed TCLP

Analysis

andor

witable

gmerator

knowledge as applied to your

compmj on

the

sampl?

in question DOES

lUOT SHOW

my

TCLP Characteristic

Waste Code.

For

the

matcrial to bc

classified

as

non-hazardous,

thc

generator must

determine

thet the

waste

;s

nct

defined as a "listed

hoz~dous

waste,

not mixed with 3 "listed"

hamdous waste, not derived from

3

"listcd"

h3zudo~~

W3~1c.

md

ohmin

3rlequ311:

inform>lion

pertoinin6

to the hazardous

cheracteri-:ics

of:

S-pitability

Cowsivity

Reactivity

TCLP Toxicity

W

~

t

e

  

Code

DO01

Wssk

Code

DO02

W,aste

Codr

DO03

Waste

Codes

DO04

-

Dl43

revirwed

and accepted

for

shipment

A

Safepi-Kleen

represen~ive

will be

conlacring you

wirh

funhar

dclail

rcprdin&

hc

shipping

handling, and processing

of

you

material.

If

you have my questions regarding the above

malyxis,

plc'w

contacl

Custumcr

Scrvice

a1

[7?3)825-7338

P.O.

Box

92050

Elk

Grow

Villagc.

U

60009.1050

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

SEP

29 '99

16:08 FR

SRFETY-KLEEN

CORP

217 328

61

0

TO

16185333332

P.

13

-

-.

Gal,%

191

0SB6-2

,~ccEP'TR

SHIP?iIENT

1

P,\GE

2

.

.

1

sur/ey

$:

?015681

...

U.

CENTRA

I

WLEO.~

!!

-

-

..-

r~

\

h

t

e

  

EPA

TCLP

Reg

Limit

G

l

A

  

-

halyzcd

Method

Result

Units

Waste

#

Ttst

Cyanide Screening

0312911 999

05049-90

250

%G

m

g

/

i

  

Sulfidc Screening

031291

1999

D397S-89A

500

hFG

mg/L

113/39/1999

1020

5140

>I42

"F

DC.01

Flash Point

-

-

9040

2

,212.5

7.67

m&

D.202

pH

-

03/29/1995,

EPA

Date

EPA

TCLP

Reg Limit

Result

Analyzed

Mcthod

mglL

m

en

Waste

#

Andyte

~

2

3

  

2-~eth~lpheiol

04/02/1999

~170

--

?OO

~0.98

-

D014i3

3+4Methylphenol

04/03/1999 8270

200

<I3

.---

-

DO30

2.4-Diniuotoluenc

041031 999

8270

0.1:

&67

-

0410211999

8370

0.13

<].I

DO32

HsxacNorobenzene

04/02/1999

0.5

DO33

I-Iexachlombutadicne

8270

C1.l

DO34

Hexachloroethane

0410211999

SYO

3

Cl oil

-

0410Y1999

SZ70

-

>

DO36

Nuobenzenc

4.97

-

0037

~entachlorophenol

031021 999

Y

170

loo

c.4

-.

DO38

Pyidine

01/0?11999

8270

5

c2.9

. -

DO41

2,4,5-Trichlorophcnol

03/02/1999

8270

400

~1.0

-

.--

04/02/1999

8270

7

DO42

2,4,6-~fichlo&hmol

=1.5

2.

-

--

Attachment

3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

SEP

29

'99

16:09

FR

S

&

~

~

-

~

~

~

~

~

'

  

CORP

217

328

61

0

TO

iE1953:33232

P.

11

.-.

.

.-

7

,

controL#:

1910886-2

)

ACCEPT FOR

SHIPMEXT

,i

PAGE

3

1

Swey

3:

2015651

-

IL

CENlRiL

RiLIROAD

:I

8.

-

EPX

Date

EPX

TCLP Reg

Limit

Result

Waste

#

Analyte

Analyzed

Method

mglL

rng&

DO04

ksenic

0313011 999

6010

5

c5.00

DO05

Barium

0313011999

6010

100

42.5

W06

Cacbnium

0313011999

6010

1

.

-

-

-.

.

. .

.

-

4500

-

-

-

DO07

Chromium

030011999 6010

1

--

<0.500

-

DO08

Ltad

0313011999

6010

i

4.00

MX)9

Mercury

0313011999

7471

0.2

c0.10

UOlO

S

~

C

N

U

~

  

03/31/199'J

7730

I

~0.45

-

-

-

-.

.

-

-

-

6010

DO1

1

Silver

0313011999

,

.r0.j00

EP.4

Dale

EP.4

TCLP Reg Limit

Result

Waste

#

Analyte

Analyzed

Method

mg&

mz/L

DO18

Benzene

0312911999

8260

0.5

c0.20

,...

-.

DO19

Carbon Tetrachloride

0312911 999

8260

0.5

4.20

....

DO21

Chlorobenzenc

0312911 999

8260

100

<0.30

DO22

Chloroform

0312911999

Y

260

6

<(1.30

-

-

3027

1,l.Dichlorobenzene

031?9/1999

5260

. .

$2

4.?0

---

DO28

1.2-Diddoroethane

0312913 999

8360

0.5

c0.20

-.

-.

i1029

1.1-Dichloroethylenc

0312911 999

8260

0.7

<O.?O

DO35

Mcthyl'Ethyl

Ketone

0312911999

8260

100

1.01

.

-

DO39

Tetrachloroethylene

03/29/1999

$260

-

0.7

a

?O

DO40

Trichloroerhylene

03139i1999

5160

-

....

0.j

..

<0.30

I

......-

-

DO33

Vinyl Chloride

03/29/1999

8260

0.2

4

14

Attachment

3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

smile

Description:

W.4STE

WATER

&

WATER

BASED

P.4IXT

Date

Sampled:

Datc

Received:

Number

of Phases:

Percent Solids

Method 1311):

Percent Dry Solids (Method 1311):

Method

D&

%tile

Lexh:

1311

Not

Required

ZHX

Leach:

1311

Not Required

BNA

Extraction:

3510

03/29/1979

-'.

1

The analysis contained herein

are

performed to provide

Safety-Uccn

Corp.

and

iir

rudorners a means of

,

determining compliant

wnstc handling practices that are consistent with

appl;=ble

permi,&

and processing

/

L.

capability.

.-

A

Attachment

3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

-

-

-

SEP 29

'99

16:09

FR

SGFETY-KLEEN

CORP

217 328 61 0 TO

151E5333332

P.

16

SAFETY-KLEEN SAMPLE ANAL

YSIS

REPQRT

Prequalijicntion

TCLP Combination

Rqart

Oil

Services

STATUS

RECENED

3i3011999

COMPLETED:

4i511999

S-K

REPRESENT.4T.WE:

Kevin

Wiison

REVISED

4/7/1999

BRIWCWARii

#:

j03301

ACCEPT

FOR

REPORT DATE:

41711999

SHIPMENT

SAMPLE

DESCRIPTION:

Warre

Warn

&

Watehased

Pain1

Nature

of Business: Railroad

S.I.C.:

Status:

SQG

-

Facility Address:

Billing

Addres~.

600

Giimore St

Centralje,

1Z

62801-5212

Process

&scription:

Painring Of

bilcarj

Material Description:

Waste Water

&

Wdlerbased

Paint

Generation Amount: 7000

Gallons

Yearly

Gallons On Hand:

P.O.

#:

Date Survey Signed:

03!1611999

Contact:

Jolm

Burch

Title:

Manags

Phone: (618)533-3366

Survcy Comments:

Looking

tbr

SKVS Approval. TCLP Combo

~19910986

...

The

nnnlyris

conhined herein are performed solely for the purpose of

qualifyingthe

analymd materials for

acccp&nce

by

Safety-Kleen

Corp. in

accurdancc

with

ik

permits

and processing

capnbility. This

repod

shall not bc reproduced in

except in

full, without the

witten permission of

the

Safctv-Kleen

Techninl Center

.

-

.

.

Disposition:

Accept for

shipmcnt

Attachment

3

Part

Number:

87174

K;'a;le

L\'?ttr

Review Date:

41511999

Rcviewers:

RBU

G

AS

A3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 15, 2006

---

.

SEP 29 '99

16:09

FR

S2FETY-KLEEN

CORP

217 328 61 0 TO

iG135333332

.

...-

.

P.

17

rcontr0~

lr:

i=6-s

)

ACCEPT

FOR

SHLPMEST

,I

PAGN

4

11,

,

SwCy#:

2015681

Dl Central

Rsilrtiad

i/

-,

i

...

.. .

-

.

.-

APPROVED

FACILITIES:

Safety-Kleen

Corp.

FED

EPA

Yumber

:

TXD07760337!

1722

Cooper Creek

Road

Shte

EPA

Number

:

65124

Telephone

:

S17-383-2611

Denton.

TX

76208

Shle

Authorizntion

:

Additional Description:

Safety-Klczn

Corp.

65;

Eut 138th Sneet

Doltcn,

IL

604

19

SafetpKleen

COT.

37W

LaGrange

Road

Smithfield KY 40068

F'ED

EPA Number

:

UD9$0613915

Shte