Document bBp3RNJ9xZv2JEx2Bne5nNwZk

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 07/22/2019 to 07/24/2019 Resource Conservation and Recovery Act LQG/TSDF Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Systech Environmental Systech Environmental Tulsa Facility 2701 N 145th East Avenue Tulsa, OK 74116 2701 N 145th East Avenue Tulsa, OK 74116 Rogers County Joe Sommer Operations Supervisor Joseph.sommer@sysenv.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110039076077 RCRA Permit No. 000025452 OKR000025452 562211 4953 Air Quality Permit No. 2018-0805-TVR Personnel participating in inspection: Angela Hays EPA ECAD John Penland EPA ECAD Alicia Chen Joe Sommer Troy Speaks Randy Sparks ODEQ Systech Environmental Systech Environmental Geocycle LLC Lead Inspector Sr. Environmental Specialist Inspector Operations Manager Operations Regulatory Manager 214-665-2285 214-665-9717 405-702-5219 918-437-3902 x 294 803-496-1472 EPA Lead Inspector Signature/Date Supervisor Signature/Date ANGELA HAYS Angela Hays Digitally signed by ANGELA HAYS DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANGELA HAYS, 0.9.2342.19200300.100.1.1=68001003655890 Date: 2019.10.16 10:01:27 -05'00' JEFFREY YURK Digitally signed by JEFFREY YURK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=JEFFREY YURK, 0.9.2342.19200300.100.1.1=68001003652717 Date: 2019.10.16 14:38:16 -05'00' Jeff Yurk Date Date 6ENFORM-019-R7.3 (6/19/2019) 1 Section I - INTRODUCTION Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 PURPOSE OF THE INSPECTION During the week of 07/22/2019, I, Angela Hays, conducted an unannounced inspection of the Systech Environmental Corporation (Systech) fuel quality hazardous waste disposal facility located in Tulsa, Oklahoma, for compliance with the Resource Conservation and Recovery Act (RCRA). I was assisted on this inspection by Environmental Protection Agency (EPA) inspector John Penland and on 07/23/2019, joined by Oklahoma Department of Environmental Quality (ODEQ) inspector Alicia Chen. Beginning 07/22/2019, we met with Mr. Joe Sommer, the Operations Manager for Systech Tulsa, and conducted an opening inspection briefing. During this briefing we presented our credentials to the Mr. Sommer and explained that the inspection was being conducted under the authority of Section 3007 of RCRA. The inspection included walkthroughs of the facility's hazardous waste storage and treatment units, a review of the facility records related to hazardous waste management, and a specific evaluation of the facility's compliance with the RCRA air pollution control requirements. We concluded the inspection of Systech on 07/24/2019 and moved onto inspect Tulsa Cement located on the surrounding property. On 07/26/2019 we conducted a closing conference attended by Mr. Sommer and representatives of the associated Tulsa Cement facility and presented our provisional areas of concern. This report serves as documentation of all onsite activities and observations during the inspection of Systech. Photographs taken during the inspection documenting onsite observations are included as Attachment 1. A summary of areas of concern identified during the inspection are provided in Section III. FACILITY DESCRIPTION The Systech Tulsa facility is registered as a large quantity generator (LQG) and a treatment, storage, and disposal facility (TSDF) (SIC 4953). Systech's primary operation is to receive fuel quality hazardous waste (FQW) for combustion in the Tulsa Cement kilns. The Systech facility consists of a tank farm with secondary containment and two storage tanks, a covered truck off-loading area that can hold two tanker trailers, and an office building. The Systech tank farm and truck off-loading area are situated within the Tulsa Cement plant on property owned by Systech at 2701 N 145th East Avenue Tulsa, Oklahoma 741161. The demarcation between Systech and Tulsa Cement ownership is the piping running from the tank farm to the kilns, which is at least 50 feet from the edge of the tank farm and truck offloading area. Hours of operation for Systech are Monday thru Friday from 7:00 am to 5:00 pm. The facility is operated by three employees. The facility operates under the requirements of RCRA hazardous waste permit OKR000025452, issued by the ODEQ on 08/08/2011, last amended on 04/01/2019, and Air permit 2018-0805-TVR, issued by the ODEQ on 06/18/2018, last amended on 04/22/2019. These permits lay out general facility requirements as well as requirements specific to the individual categories of hazardous waste management units and 1 Appendix 2 - RCRA Permit - Site Map page 27 2 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 air emission units. The RCRA permit specifically authorizes and regulates the operation of two 180,000gallon storage tanks that are also considered treatment units due to the agitation system installed in each tank. In addition to the permitted units, the facility applies the LQG standards for the satellite accumulation areas (SAAs) and less-than 90-day container storage located in the truck off-loading bay. Section II - OBSERVATIONS Unless otherwise stated, facts laid out in this section are observations by the EPA inspectors or statements made by Mr. Joseph Sommer during the inspection. We conducted the onsite inspection during normal business hours from 07/22-24/2019. During the inspection, the facility was conducting normal operations and all areas of the facility were in use. Our primary points of contact at the facility during the inspection were Mr. Joe Sommer and Mr. Troy Speaks. On 07/22/2019, following the opening briefing, we visited each of the hazardous waste management units to review them for compliance with general facility and unit specific standards. On 07/23/2019, we conducted a review of the facility's compliance with the air emission standards of 40 CFR 60.110 to 60.116 and 40 CFR 264, subsections AA, BB, and CC. As part of the review, Mr. Penland conducted air monitoring in accordance with EPA Method 21 using a Thermo TVA-2020 (S/N 202016081525) calibrated using Zero Air, Methane at 500ppm, and Methane at 9,500ppm as specified in 40 CFR 264.1063 and 265.1085 (d). On 07/23-24/2019, we reviewed the facility's operating records pertaining to the hazardous waste regulations and permit requirements. This section provides a detailed description of EPA observations of the individual units assessed throughout the inspection. Truck Unloading Bay / Shipping and Receiving Area The truck off-loading bay is a covered, concrete-lined area located on the Systech owned property within the Tulsa Cement property boundary2. Per the RCRA permit, the bay can store up to 13,100 gallons of hazardous waste in containers. The bay is equipped with two loading racks for the transfer of FQW from transportation containers to the permitted hazardous waste storage tanks. Each loading rack is equipped with a pump and inline grinder to facilitate the transfer of the waste. According to Mr. Sommer a 55-gallon drum is placed next to each loading rack as a satellite accumulation container for waste personal protective equipment (PPE) and debris from the operation of the individual loading rack. Hazardous waste containers are unloaded immediately upon arrival at the facility without interim storage. During the week of this inspection, Mr. Sommer indicated a total of fifty-eight containers of FQW were scheduled to arrive at the facility, each with a load of approximately 45,000-50,000 pounds of hazardous waste. We inspected this area on 07/22/2019 and observed 11 containers of hazardous waste stored in this area. In addition, two satellite accumulation containers were observed. The following describes our observations. 2 Appendix 1 - Photo 508 and 509 3 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 Six 55-gallon containers labeled "Waste Solids, NOS" - Per Mr. Sommer, these containers consist of contaminated PPE and debris generated during the handling and transfer of FQW. Mr. Sommer stated that this waste will be shipped to the Systech facility located in Fredonia, Kansas for fuel-blending. All containers were in good condition, appropriately closed, labeled with the words "Hazardous Waste", and marked with their accumulation start date. Two 55-gallon drums labeled "Waste Flammable Liquids, NOS"3 - According to Mr. Sommer, these drums contain FQW and other liquids collected during the repair of one of the inline grinders on 07/11/2019. This waste will be shipped to the Systech facility located in Fredonia, Kansas for fuel-blending. Both containers were in good condition, appropriately closed, labeled with the words "Hazardous Waste", and marked with their accumulation start date. Three 5-gallon buckets4 - Per Mr. Sommer the buckets contain rocks and other debris contaminated with FQW that was removed from one of the inline grinders on 07/11/2019. This waste will be shipped to the Systech facility located in Fredonia, Kansas. When we inspected these containers on 07/22/2019, only one of these buckets was labeled with the words hazardous waste and the waste accumulation start date; all three buckets were open and two unlabeled. The facility personnel corrected this immediately when we identified this issue. Two 55-gallon satellite accumulation areas5 - Systech dedicates a satellite accumulation area for each of the loading racks. Both containers were marked with the words "Hazardous waste" and were appropriately closed at the time of this inspection. Tank Area The Systech facility has two 180,000 - gallon vertical, fixed roof tanks used to blend and store FQW prior to burning6. Each tank is constructed of mild carbon steel and is equipped with an agitator, an inline pressure/vacuum relief device, high level indicators/alarms and an emergency pressure relief vent. The tanks and pressure/vacuum relief in-line conservation vents are designed for 2 pounds per square inch (psi) before venting to the control system. After releasing the pressure on the tank, the conservation vent will close7, and the tank is sealed until it builds pressure again. To protect the tanks there is a detonation arrestor8 at each tank to protect the tank from any potential flashback, there is also a detonation arrestor at the kiln hood area to stop a flame front from moving through the line. The emergency relief vent is a backup only employed if pressure in the tanks exceeded the design criteria. The emergency relief vents exhaust to the atmosphere. The tanks are equipped with a closed-vent system that routes exhaust from the tank vents to either the cement kilns for combustion control or to a carbon adsorption system when both kilns are not operating. The 4-inch vapor vent lines from the tanks to the kilns flow into a 6-inch vapor line that routes vapors to the kilns. The 6-inch transfer line splits into two 4-inch vapor lines - one for each kiln. These lines to the kiln are equipped with automatically actuated valves. The valves are automatically opened and closed based on kiln operating parameters. 3 Appendix 1 - Photos 510, 511, 515 4 Appendix 1 - Photos 520 and 521 5 Appendix 1 - Photos 513 and 514 6 Appendix 1 - Photos 516 and 517 7 Appendix 1 - Photos 523, 524, 527, 528, and 529 8 Appendix 1 - Photo 525 4 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 The vapors enter the kiln hood and the flame zone where organics are combusted with at least a 99.99% destruction efficiency. Systech uses 40 CFR 63.685(b)(i) and 681(d) and NSPS subpart DD in lieu of 40 CFR 264 subpart CC for controlling volatile organic emissions from its tanks. The secondary containment system for the tanks is an above-ground concrete impoundment separated with an 18-inch high divider wall9. The total gross containment capacity reported in the permit application is 283,859 gallons. Allowing for the displacement caused by a 25-year, 24-hour storm event and the presence of the equipment within the dike wall, the net available secondary containment capacity, as reported in the permit application, is 181,489 gallons10. The calculations attached to the revised March 2012 permit application to support this capacity show a net secondary containment capacity of 181,500 gallons but fail to account for the displacement caused by ancillary equipment (piping, valves, etc.) within the dike wall. We inspected the waste tanks and ancillary equipment in this area on 07/22-23/2019. During the inspection only tank number two was in use. The tanks are utilized one at a time and switched every three months. Per Mr. Sommer, tank number two was approximately 60% percent full and tank number one was approximately 27% full. Tank number one was still agitating. The agitators turn off when the volume of waste in the tank falls below 22%. The facility also maintains three stormwater tanks11 located in a conjoined containment dike. These tanks accumulate and store contact stormwater from the Systech facility which is used as cooling water for the kilns at the Tulsa Cement Plant. Both permitted hazardous waste storage tanks were marked with the words hazardous waste. The tanks visually appeared to be in good condition and without visual indication of releases or spills. Our visual inspection of the secondary containment dike showed evidence that some repairs to historic structural cracks were beginning to deteriorate but there was no indication that they posed a risk of release to the environment in the case of a spill. On 07/23/2019, we conducted a leak detection inspection of the tanks and their ancillary equipment in accordance with EPA Method 21. None of the components subject to the leak detection and repair requirements were visibly labeled or otherwise made easily identifiable. Systech does maintain a component log with an associated piping and instrumentation diagram (P&ID), but facility representatives were unable to consistently identify the components being monitored. Valves and connectors used for transport of the FQW are required to be repaired within 15 days if a leak is discovered using EPA Method 21. A leak in this case is defined as a monitoring result of greater than 9 Appendix 1 - Photos 518 and 519 10 Appendix 2 - RCRA Permit - Part D Process Description 11 Appendix 1 - Photo 508 5 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 10,000 ppm above the background for these components. No leaks were identified for these components during this inspection. The primary barrier for the hazardous waste tanks, the closed vent system for the hazardous waste tanks, and the pressure relief devices for the tanks and closed vent system are required to be operated with no detectable emissions. No detectable emissions were defined as a monitoring result of less than 500 ppm above the background for these components. EPA monitoring results of greater than 500 ppm above the background were identified at the following locations: the detonation arrestor for tank 1; the hatch for tank 2, and the pressure relief vent for the closed vent system on tank 2. For a full record of the monitoring results consult Appendix 4. Hazardous Waste Manifests On 07/24/2019, we reviewed 425 hazardous waste manifests for wastes received by Systech for fuel burning in the Tulsa Cement kilns. Our review covered waste received between May 1, 2019 and July 22, 2019. The review identified eight manifests for shipments of hazardous waste fully rejected by the designated receiving facility, Ash Grove Cement Company in Chanute, Kansas12. The rejecting facility's signature was not on manifests 018095192 JJK, 018095193 JJK, and 018095194 JJK. While on manifests 018095180 JJK, 018095181 JJK, 018095182 JJK, 018095183 JJK and 018095180 JJK, the facility address where the waste was received was incorrect. These manifests state that the waste was received at the Systech Fredonia, Kansas plant when the waste was received at the Systech Tulsa, Oklahoma plant. Copies of these manifests can be found in Appendix 3. During our review of manifests for shipments of hazardous waste originated by Systech we noted that the weights of wastes listed on the manifests lacked the normal variance expected for the two types of waste streams listed: spent carbon and contaminated PPE. When we asked for an explanation, Mr. Sommer stated that Systech does not own a scale to weigh containers of its waste and therefore, uses an estimated weight for each container: 450 pounds (lbs) for carbon drums and 250 lbs for PPE drums. However, since these manifests are for shipments of containerized wastes and not bulk wastes, the facility can list the number of containers shipped for each waste stream in lieu of the weight. At the time of this inspection, we did not identify evidence that the facility is under-reporting its waste generation and, therefore this practice did not raise any immediate concern. Hazardous Waste Container Inspection Records On 07/24/2019, we reviewed the facility's records of inspection for their permitted hazardous waste container storage area. The records we reviewed were all present and completed by facility personnel. However, the records did not document inspection of waste compatibility, aisle spacing, container closure, or appropriate labeling. 12 Appendix 3 - Manifests 6 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 Training Records On 07/24/2019, we reviewed the facility's employee training records pertaining to the RCRA requirements. Mr. Troy Speaks, Mr. Joe Sommer, and Mr. Cory Brewer had completed the following training programs: Department of Transportation (DOT) Hazardous Materials Shipping; Mining Safety and Health Administration (MSHA) Mine Worker training; and Systech RCRA training. Notably missing was the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) training. This training is required for all employees whose duties may require them to respond to a release or spill of a hazardous waste or operate a hazardous waste treatment, storage, or disposal unit. Contingency Plan On 07/24/2019, we reviewed the facility's hazardous waste contingency plan. The plan was revised on 03/27/2019, document number 56-2019-03-413, in order to update the primary contact. However, the contingency plan lacks information on the fire, police, and hazmat addresses and phone numbers. The facility said they will be able to provide documentation in the form of certified mail receipts for Hillcrest Healthcare Services, Rogers County Emergency Management, Catoosa Fire Department, Catoosa Police Department and Tulsa Fire Department dated March 27. 2019. The contingency plan also lists Mr. Troy Speaks, Mr. Joe Sommer, and Mr. Cody Brewer as potential responders to releases of hazardous waste. As stated above, none of these employees have received the appropriate hazardous materials response training. Section III - AREAS OF CONCERN This section summarizes the Areas of Concern discussed with Systech during the closing meeting. Training: Systech employees handling hazardous waste do not have HAZWOPER training. Systech is also noted in the Tulsa Cement plant's contingency plan for maintenance of spill containment and clean up. Systech employees are not equipped with proper training to handle hazardous waste response. Refer to 40 CFR 264.16. Labeling of valves, gaskets, and flanges subject to 40 CFR Part 264 subpart BB: No labeling on equipment was present at the time of the EPA inspection. Systech provided a diagram of the facility equipment and documentation that the components were monitored twice a week, yet had difficulty identifying components during the inspection. Refer to 40 CFR 264.1050(d), labels in BB and heavy 40 262.1058 or light 40 CFR 262.1057 monitoring responsibilities. Leaks subject to 40 CFR 264 subpart BB: The leaks detected during the EPA Method 21 inspection are required to be repaired within the time frames laid out in the regulations. Refer to 40 CFR 262.1058 (heavy) or 40 CFR 262.1057 (light) and 40 CFR 264.1033(k)(1) for monitoring responsibilities. Including but not limited to notification and certification of leak and repair per Title V Renewal terms (Appendix 5). 13 Appendix 6 - Contingency Plan 7 Systech Environmental Corporation / Tulsa, OK Facility Inspection Date July 22-24, 2019 Closed vent system design and operation: Systech operates the closed vent system for the hazardous waste storage tanks at atmospheric pressure. The RCRA regulations require these systems to be operated under negative pressure. How this would interplay with the system's requirements under the Clean Air Act is a matter for additional review. Refer to 40 CFR 264.1033(k)(2) vent. Hazardous waste tank secondary containment: Total capacity for the secondary containment only calculates for the volume of the tanks located in containment. The calculations do not compensate for the volume of the ancillary equipment within the containment area per 40 CFR 264.175. Facility inspection documentation: Systech inspections are completed weekly with notation of "ok". No unit description or details are recorded per CFR 40 265.195. While these records may be sufficient to document that an inspection generally occurred, they do not address all of the relevant unit standards. Section IV - FOLLOW UP The following information was received by EPA after the inspection. Dates received are indicated below. Part 70 permit No 2018 - 0805-TVR (received September 10, 2019) Documentation of vent repair (received July 10,2019) Certified mailing receipts from Systech to local first responders of facility's contingency plan (received July 31,2019) Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 21 photos taken on 07/22/2019 and 07/23/2019 Appendix 2 - RCRA Permit Part D Process Description Appendix 3 - Rejected Manifests Appendix 4 - Method 21 Monitoring Results - July Appendix 5 - Air Emissions Standards Title V Renewal Permit No. 2018-0805-TVR Appendix 6 - Contingency Plan 8 Systech Environmental Corporation Inspection Date 7/22/2019 to 7/24/2019 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 508 Date: 7/22/2019 Photographer: John Penland, EPA Description: Overview from left to right: Waste water tank, hazardous waste storage tank number one and truck bay. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 509 Date: 7/22/2019 Photographer: John Penland, EPA Description: Interior of truck bay with tanker unloading. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 510 Date: 7/22/2019 Photographer: John Penland, EPA Description: Satellite accumulation drum near East wall in truck bay. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 511 Date: 7/22/2019 Photographer: John Penland, EPA Description: Overview of satellite accumulation drum near East wall in truck bay. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 512 Date: 7/22/2019 Photographer: John Penland, EPA Description: Three open containers of hazardous waste in truck bay, two with no labels. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 513 Date: 7/22/2019 Photographer: John Penland, EPA Description: Satellite accumulation drum of hazardous waste in truck bay. This drum was deemed not full and was still being utilized according to facility. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 514 Date: 7/22/2019 Photographer: John Penland, EPA Description: Close up of drum label from picture 513 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 515 Date: 7/22/2019 Photographer: John Penland, EPA Description: SAA drum in truck unload area UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 516 Date: 7/22/2019 Photographer: John Penland, EPA Description: Hazardous waste storage tank number one UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 517 Date: 7/22/2019 Photographer: John Penland, EPA Description: Hazardous waste storage tank number two UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 518 Date: 7/22/2019 Photographer: John Penland, EPA Description: Overview of piping in secondary containment area for hazardous waste storage tank number one UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 519 Date: 7/22/2019 Photographer: John Penland, EPA Description: Overview of piping in secondary containment area for hazardous waste storage tank number two UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 520 Date: 7/22/2019 Photographer: John Penland, EPA Description: Hazardous waste buckets from picture 512 received lids and labels UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 521 Date: 7/22/2019 Photographer: John Penland, EPA Description: Close up of hazardous waste buckets from picture 512 received lids and labels UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 523 Date: 7/23/2019 Photographer: John Penland, EPA Description: Closed vent system on tank one UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 524 Date: 7/23/2019 Photographer: John Penland, EPA Description: Underneath view of closed vent system on tank one UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 525 Date: 7/23/2019 Photographer: John Penland, EPA Description: Flame arrestor UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 526 Date: 7/23/2019 Photographer: John Penland, EPA Description: Manway on tank two UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 527 Date: 7/23/2019 Photographer: John Penland, EPA Description: Closed vent system on tank two UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 528 Date: 7/23/2019 Photographer: John Penland, EPA Description: Close up of closed vent system on tank two UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Systech Environmental Corporation City: Tulsa County/Parish: Tulsa State: Oklahoma Photograph Number: 529 Date: 7/23/2019 Photographer: John Penland, EPA Description: Underneath view of closed vent system on tank two Appendix 2 RCRA Permit Part D Process Description Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Section D PROCESS DESCRIPTION Revision 2: April 2010 Revision 3: March 2012 Rev. 2 April 2010 Rev. 3: March 2012 Process Information Page D-i Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 SECTION D - PROCESS INFORMATION Table of Contents D.1 Introduction...................................................................................................................... 1 D.2 Process Flow .................................................................................................................... 2 D.3 Waste Management Units ................................................................................................ 3 D.3.1 Tank Systems .............................................................................................................. 3 D.3.1.1 Tank Management Practices ................................................................................... 4 D.3.1.2 Description .............................................................................................................. 4 D.3.1.3 Description of Off-loading Systems to the Tanks................................................... 4 D.3.1.4 Level Indicators and Controls ................................................................................. 5 D.3.1.5 Safety Cutoff ........................................................................................................... 5 D.3.1.6 Pressure Controls .................................................................................................... 5 D.3.1.7 Secondary Containment and Detection of Releases ............................................... 5 D.3.1.7 Leak Detection System ........................................................................................... 6 D.3.2 Response to Leaks or Spills and Disposition of Leaking or Unfit-for-use Tank Systems ...................................................................................................................... 7 D.3.2.1 Spill Response......................................................................................................... 7 D.3.2.2 Tank and Secondary Containment System Repair or Closure................................ 8 D.3.2.3 Certification of Major Repairs ................................................................................ 9 D.3.3 Containers ................................................................................................................... 9 B.3.3.1 Description of Containers ..................................................................................... 10 B.3.3.2 Condition of Containers ........................................................................................ 10 B.3.3.2 Container/Waste Compatibility ............................................................................ 10 D.3.3.3 Container Management Practices ......................................................................... 11 D.3.3.4 Inspections ............................................................................................................ 12 D.3.3.5 Containment .......................................................................................................... 12 List of Figures Figure D-1 Figure D-2 Figure D-3 Figure D-4 Process Flow Schematic Tank Containment and Truck Off-Load Plan Tank Containment and Truck Off-Load Sections Piping and Instrumentation Drawing Att. D-1 Att. D-2 Att. D-3 Att. D-4 List of Attachments Engineering Drawings and Figures Tank Design Assessment Tank Dike Secondary Containment Calculations Truck Off-load Area Containment Calculations Rev. 2 April 2010 Rev. 3: March 2012 Process Information Page D-ii Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 SECTION D - PROCESS INFORMATION D.1 Introduction The Systech Tulsa facility receives hazardous waste for the preparation of fuel quality waste (FQW) to be combusted in the Lafarge Tulsa cement kilns. The Systech facility consists of a tank farm with secondary containment and two storage tanks, a covered truck off-loading area that can hold two tanker trailers, and a laboratory/office building. The Systech tank farm and truck off-loading area are situated within the Lafarge Tulsa cement plant on property owned by Systech. The Systech Tulsa facility has two waste storage/treatment systems that are regulated under the RCRA regulations at 40 CFR 264. Two 180,000-gallon storage tanks (S02) that are also considered as Treatment Units (T04) due to the agitation system installed with each tank; One Truck Off-loading Area that will store containers (S01) totaling up to 13,100 gallons. The demarcation between Systech and Lafarge ownership of the piping running from the tank farm to the kilns is the property line separating the Systech and Lafarge properties, which is at least 50 feet from the edge of the tank farm and truck off-loading area. Rev. 2 April 2010 Process Information Page D-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 D.2 Process Flow The Systech Tulsa operations receive bulk tanker trucks of liquid hazardous waste, which are sampled, tested, and off-loaded into one of two storage tanks where the various received volumes are mixed by top-mounted agitators. After the tanks are mixed and tested to demonstrate they meet the requirements to be burned, the blended FQW is pumped to either or both of the two Lafarge cement kilns to be combusted as fuel in the manufacture of portland cement. Piping is also provided to allow the FQW to be recirculated back to the tank being fed from in the event of an automatic waste flow cut-off to the kiln. Tanker trailers may also be stored within the truck off-loading area, in addition to drums of site-generated hazardous wastes. Figure D-1 below represents the flow of materials through the facility. Figure D-1 Process Flow Schematic Rev. 2 April 2010 Process Information Page D-2 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 D.3 Waste Management Units This section describes the tank system and container storage area. Attachment D-1, Engineering Drawings and Figures, contains drawings that illustrate the features of each system. Figure A-1, Plot Plan, in Section A shows the general layout of the buildings and the off-loading and storage areas within the Lafarge and Systech facilities. D.3.1 Tank Systems Tank systems provide storage capacity for wastes delivered in trucks before they are used as FQW in the manufacture of cement. Truck off-loading usually occurs during the day shift five days a week, while the cement kilns operate twenty-four hours a day, seven days a week. The tanks are sized to be able to supply sufficient fuel over the weekend when the kiln continues to operate. The tanks are also used to blend the wastes to prepare a consistent fuel for the kilns. The facility has one tank farm, shown on Figure A-2, Plot Plan, which includes the two storage tanks. Each tank has a design capacity of 180,000 gallons (32-foot diameter, 30foot high), for a total permitted tank storage capacity of 360,000 gallons. Most of the wastes stored in the tanks are generated off-site, but some of the wastewaters are collected on-site from containment areas. The off-site wastes include liquid and sludge waste fuels. Attachment D-2 contains a copy of the design assessment for the tank systems. Systech will ensure that proper handling procedures are adhered to in order to prevent damage to the new tank system during installation. Prior to placing a new tank system or component in use, an independent, qualified, installation inspector or a qualified Professional Engineer, either of whom is trained and experienced in the proper installation of tanks systems or components, must inspect the system for the presence of weld breaks, punctures, scrapes of protective coatings, cracks, corrosion, or other structural damage or inadequate construction/installation. All discrepancies will be remedied before the tank system is placed in use. Rev. 2 April 2010 Process Information Page D-3 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 All new tanks and ancillary equipment are tested for tightness prior to being placed in use. If a tank system is found not to be tight, all repairs necessary to remedy the leak(s) in the system must be performed prior to the tank system being covered, enclosed, or placed into use. D.3.1.1 Tank Management Practices The tanks are used to receive off-site shipments of liquid waste fuels from bulk trucks, and are used to blend the various liquid waste fuels to prepare a consistent fuel for the kiln. The fuel in the tanks can be transferred to the other tank for blending or pumped directly to the kiln for use as fuel. Operations are both manual with manual valves and manual start/stop of pumps, and automatic valves and start/stop for pumps. Hazardous wastes or treatment reagents are not placed in the tank system if they could cause the tank, its ancillary equipment, or the containment system to rupture, leak, corrode, or otherwise fail. D.3.1.2 Description Each tank is an aboveground, vertical, cylindrical tank with a flat bottom and a top deck. All of the tanks are constructed of mild steel and meet or exceed the minimum requirements of API 620. Ancillary equipment is supported and protected against physical damage and excessive stress due to settlement, vibration, expansion, or contraction. D.3.1.3 Description of Off-loading Systems to the Tanks The off-loading system for the tanks includes two truck off-loading stations and two transfer pumps to unload the trucks. The system is operated manually with all manual valves and manual start for the pumps. The bulk truck off-loading stations are located at the truck pad. These stations operate independently allowing two trucks to be off-loaded at a time. Rev. 2 April 2010 Process Information Page D-4 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 D.3.1.4 Level Indicators and Controls Each tank uses a mechanical or electrical device for level measurements. Each tank has a high-level alarm that works off the level indicators to alert the employees to prevent overflowing of the tank. An audible alarm horn is located in the bulk truck off-loading areas. D.3.1.5 Safety Cutoff Emergency stop buttons that stop all transfer pumps are located at the facility. In addition, the tanks have a high-level sensor that will shut off all transfer pumps. This system is designed to prevent overfilling the tanks. D.3.1.6 Pressure Controls Each tank is equipped with an in-line pressure/vacuum relief valve that vents to either of the cement kilns where working and breathing losses are controlled in the kilns' combustion chambers. Each tank is also equipped with an emergency pressure/vacuum release vent set per API 620 standards to prevent damage to the tanks. The emergency vent releases to the atmosphere. D.3.1.7 Secondary Containment and Detection of Releases Figure D-2, Tank Containment and Truck Off-load Plan, and Figure D-3, Tank Containment and Truck Off-load Sections, show that the secondary containment for the tanks is designed to contain liquids. The area is constructed of reinforced concrete with any cracks or gaps sealed. The concrete is compatible with the waste stored. The concrete secondary containment system acts as a liner external to the tank in compliance with 40 CFR 264.193(d). The containment area is generally sloped at a 1% incline toward a sump within the tank dike. According to the Department of Commerce Technical Paper No. 40, "Rainfall Frequency Atlas of the United States," the 25-year, 24-hour storm is 7.2 inches of precipitation for the Tulsa area. Rev. 2 April 2010 Process Information Page D-5 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Per the dimensions shown on the Plan and Section drawings in Attachment D-1, the total gross available containment within the tank farm is 283,859 gallons. Allowing for displacement by the 25-year, 24-hour storm event and the presence of the equipment within the dikewall, the net available secondary containment capacity is 181,498 gallons, which is more than the largest tank volume. Details of these calculations are shown in Attachment D-3: The top of the dike wall is at least 2.0 feet above grade to prevent run-on into the tank dike area. Precipitation collected in the containment area drains to a sump and is pumped by a sump pump to one of three stormwater tanks located in the adjacent containment area. The sump pump is operated manually. Small leaks of waste fuels are cleaned up within 24 hours or in as timely a manner as possible after detection. The collected materials are placed back into the fuel. If a major release of waste fuels occurs, the majority of material would be pumped into a storage tank, and the remainder would be cleaned up as a small spill. The Attachment D-1, Engineering Drawings and Figures, shows that all offloading and tank transfer equipment and piping are located within secondary containment areas. The only hazardous waste equipment not within the secondary containment area are the burn lines and return line to and from the kilns, and above-ground welded flanges, welded joints, and welded connections that are inspected daily for leaks. D.3.1.7 Leak Detection System The FQW storage tanks are provided with a leak detection system that is designed and operated so that it will detect failure of the primary containment structure in compliance with 40 C FR 264.193(c)(3). The tank walls are visible to inspection. The tank floors consist of a double bottom with the lower plate made of pebble or checker plate. The interstitial space between the plates created by the pebble or Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-6 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 checker pattern allows any leakage to run to one of the inspection ports at the side of the tank. Both bottoms are sloped from the center of the tank down to the side walls to assure any leakage will run to the inspection ports. D.3.2 Response to Leaks or Spills and Disposition of Leaking or Unfit-for-use Tank Systems D.3.2.1 Spill Response The facility removes from service any tank system or secondary containment system that has a leak or spill or that becomes unfit for use. In any of these cases, the facility ensures that the following actions take place: The flow of hazardous waste into the tank system or secondary containment system is stopped. The system is then inspected to determine the cause of the release. If the release was from the tank system, the facility removes as much of the waste as necessary to prevent any further releases and to allow inspection and repair of the tank system. If the release is to the secondary containment system, all released materials are removed to prevent any harm to human health and the environment. The Site Manager or designee conducts a visual inspection of the release and, based on that, would prevent any further migration of the leak or spill to soils or surface water. An inspection is also conducted to ensure that any visible contamination of the soil or surface water has been removed and properly disposed of. Any release to the environment above the Reportable Quantity (RQ) will be reported to ODEQ within 24 hours of its detection. Exceptions to this Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-7 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 requirement are if the hazardous waste leak or spill is less than or equal to a quantity of one pound and if it is immediately contained and cleaned up. Within 30 days of detecting a release to the environment above the RQ, a written report containing the following information will be submitted to ODEQ, unless the agency instructs otherwise. The written report will include: o The likely route of migration of the release; o Characteristics of the surrounding soil; o Results of any monitoring or sampling conducted in connection with the release, if this information is available. If this information is not available at this time, it will be submitted when it becomes available; o Proximity of down-gradient drinking water, surface water, and populated areas; and o A description of the response actions taken or planned. D.3.2.2 Tank and Secondary Containment System Repair or Closure Following a spill or release, the tanks and secondary containment systems are repaired in accordance with 40 CFR 264.196(e). Unless these requirements can be satisfied, the leaking tank system will be closed in accordance with 40 CFR 264.197. The requirements of 40 CFR 264.196(e) are the following: If the cause of the release was a spill that did not damage the integrity of the system, the system may be returned to service as soon as the released waste is removed and repairs, if necessary, are made. If the cause of the release was a leak from the primary tank system into the secondary containment system, the primary system must be repaired prior to returning the tank system to service. Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-8 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 If the source of the release was a leak to the environment from a component of a tank system without secondary containment, the facility must provide the component of the system from which the leak occurred with secondary containment that satisfies the requirements of 40 CFR 264.193 before it can be returned to service, unless the source of the leak is an aboveground portion of a tank system that can be inspected visually. If the source is an aboveground component that can be inspected visually, the component must be repaired and may be returned to service without secondary containment as long as the appropriate certifications by an independent, qualified, professional engineer are obtained. If a component is replaced to comply with these requirements, that component must satisfy the requirements for new tank systems or components in 40 CFR 264.193. Additionally, if a leak has occurred in any portion of a tank system component that is not readily accessible for visual inspection (e.g., the bottom of an inground or onground tank) the entire component must be provided with secondary containment in accordance with 40 CFR 264.193 prior to being returned to use. D.3.2.3 Certification of Major Repairs If the facility has repaired a tank system in accordance with the above requirements and the repair has been extensive (e.g., installation of an internal liner or the repair of a ruptured primary containment or secondary containment vessel), the tank system will not be returned to service unless the certification has been obtained by an independent professional engineer in accordance with 40 CFR 270.11(d)(1) that the repaired system is capable of handling hazardous wastes without release for the intended life of the system. This certification will be submitted to ODEQ within seven days after returning the tank system to use. D.3.3 Containers A maximum of 13,100 gallons of containerized waste may be stored within the truck offloading area. This value is based on being able to store two (2) 6,000-gallon tank trailers Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-9 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 in addition to non-bulk containers of site-generated wastes that must be shipped off-site for final treatment or disposal. B.3.3.1 Description of Containers Containerized off-site wastes are only stored in the bulk container in which they were received. No non-bulk containers of hazardous waste will be received for storage. Site-generated wastes may be stored in new, used, or reconditioned nonbulk containers meeting Department of Transportation (DOT) specifications. These containers meet the requirements of 49 CFR, Part 178, Subpart L - Nonbulk Performance-oriented Packaging Standards. These standards incorporate specifications for container dimensions and materials of construction. B.3.3.2 Condition of Containers Containers in storage are periodically inspected to ensure that they are in good condition and not leaking. If the container is observed to not be in good condition or if it begins to leak, the contained waste is transferred to a container that is in good condition, or the liquid hazardous waste may be off-loaded into the storage tanks. B.3.3.2 Container/Waste Compatibility Wastes received from off-site require that the shipping containers comply with DOT regulations, which include the requirement that the materials of construction of the containers be compatible with the contents so that the ability of the container to contain the waste is not impaired. On-site generated wastes that are placed in storage for off-site shipment are placed in DOT-specified containers that are compatible with the contents. Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-10 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 D.3.3.3 Container Management Practices All containers of hazardous waste in the truck off-loading area remain closed during storage, except when it is necessary to add or remove waste from that container. All containers of hazardous waste in the truck off-loading area are opened, handled, and stored in manner that will not cause the container to rupture or leak. D.3.3.3.1 Aisle Spacing Aisle spacing in the container storage area conforms to National Fire Protection Association (NFPA), federal, and state requirements. Tankers and the non-bulk containers are stored with at least 2-foot aisle spacing on each side to allow access to the bulk containers. Non-bulk containers of site-generated wastes are stored on pallets with container labels facing the aisles. Adequate space is provided to prevent the tank trucks from damaging the non-bulk containers that may be stored within the area. D.3.3.3.2 Marking and Labeling All non-bulk site-generated waste containers are marked and labeled in accordance with all applicable ODEQ and DOT regulations. The labels attached to the non-bulk site-generated waste containers have the words "Hazardous Waste" and the date accumulation began in that container. Before shipping the site-generated waste containers, a label meeting the 49 CFR 172.304 labeling requirements is affixed. The bulk containers (tankers) are not required to be labeled while in storage, but the container must be properly placarded and the shipping papers (i.e., hazardous waste manifest) are readily available to identify the contents of the bulk container. Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-11 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 D.3.3.4 Inspections All containers are visually inspected upon receipt to verify that they are in good condition and leak-free. The containers are inspected at least weekly. The contents of a damaged or leaking container are processed, immediately transferred to a container in good condition, or placed in an overpack. In addition, the condition of the container storage area is also inspected for deterioration of the containment system caused by corrosion or other factors. D.3.3.5 Containment Figure A-2, Plot Plan, shows the location of the truck off-loading area adjacent to and on the west side of the tank storage area. Figure D-2, Tank Containment and Truck Off-Load, Plan, and Figure D-3, Truck Containment and Truck Off-load Sections, shows that the truck off-load area is a curbed, concrete containment area. The area is under roof to minimize the amount of precipitation collected within this area. The permitted capacity for this area is 13,100 gallons. Typically, this area may be used to store two 6,000-gallon tankers plus twenty 55-gallon drums. However, if two tankers are not being stored in the area, additional non-bulk containers may be stored that continue to meet the volume limits and storage and aisle spacing requirements. The containment system has been designed and constructed of concrete that is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed. The truck off-load area is sloped to drain and remove liquids resulting from spills, leaks, or precipitation and to provide adequate secondary containment for the largest container (6,000 gallons) plus allowance for accumulated precipitation. See Attachment D-4 for calculation of the available secondary containment in this container storage area. Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-12 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 The perimeter curbing and raised approach aprons prevent run-on into this container storage area. Any waste leakage or spills are cleaned up within 24 hours after detection or in as timely a manner as possible consistent with the procedures identified in the site's Contingency Plan in Section G. The truck off-load area is located at least 50 feet from the Systech property line since the area manages ignitable wastes. Rev. 2 April 2010 Rev 3. March 2012 Process Information Page D-13 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment D-1 Engineering Drawings and Figures Figure D-2 Figure D-3 Figure D-4 Tank Containment and Truck Off-Load Plan Tank Containment and Truck Off-Load Sections Piping and Instrumentation Drawing Dwg. No. 42-06G02 Dwg. No. 42-06C02 Dwg. No. 42-06P01 Rev. 2 April 2010 Process Information Page Att. D-1-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment D-2 Tank System Design Assessment Rev. 2 April 2010 Process Information Page Att. D-2-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment D-3 Tank Dike Secondary Containment Calculations Gross Volume of Tank Dike plus 2 sumps (assumes no sloped floor): Two sumps = 4' x 4' x 5' x 3 = 240 cu. ft = 1,197 gallons Dike inside width = 55 feet Dike inside length = 149 feet (each FQW tank = 65 feet plus 19 feet for stormwater tanks) Dike maximum depth = (5'-2.9") feet = 5.24 feet Total Volume (without deducting sloped floor) = (55 x 149 x 5.24) + 160 cu. ft. = 43,182 cu. ft. = 323,001 gallons Less displacement: Sloped floor at FQW tanks (floor slopes at .25" per foot from adjacent corners to each sump forming 2 triangular wedges within each half of the dike area). The volume of the concrete wedges can be estimated using the volume of a pyramid formula (area of base times height divided by 3) as follows: Elevation at 3 corners other than sump in each half = 1.24 feet above sump elevation The volume of the 4 concrete wedges = of the volume of a slab 110 ft by 130 ft by 1.24 ft less the volume of a pyramid 110 ft by 130 ft by 1.24 ft. [(110 x 130 x 1.24) - (110 x 130 x 1.24 3)] 2 = 5,910.7 cubic feet = 44,212 gallons Sloped floor at stormwater tanks: Length = 19 feet Width = 55 feet Slope elevation = 5.25 feet - 4 feet = 1.25 feet Volume of concrete wedge = 19 x 55 x 1.25 x .5 = 653 cu. ft. = 4,885 gallons Two FQW tank pads: Tank base diameter = 34 feet Tank pad height = 1.5 foot above sump elevation (ignores portion of pad within the wedges) Rev. 2 April 2010 Rev. 3. March 2012 Process Information Page Att. D-3-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Tank Base displacement volume = 2 x 1.5 x x 34 x 34 / 4 = 2,723.8 cu. ft. = 20,374 gallons Base of 1 FQW tank (the other is assumed to be the leaking tank): Tank diameter = 32.0 feet Height of tank within containment zone = (5.24 - 1.5) = 3.74 feet Volume of bottom of tank = 3.74 x x 32 x 32 / 4 = 3,007.9 cu. ft. = 22,499 gallons Base of 3 stormwater tanks (assume flat bottom on the floor): Tank diameter = 12 feet Average height of tank within containment zone = (4 + 75% of 1.25) = 4.9 feet Volume of bottom of tanks = 4.9 x x 12 x 12 / 4 x 3 = 1,662.5 cu. ft. = 12,436 gallons Two divider walls (assume top is level): Divider walls width = 8 inches = .67 feet Divider walls length = 55 feet Top of divider walls above sump elevation = 18 inches Volume of divider walls = 2 x .67 x 55 x 1.5 = 110 cu ft = 827 gal. Rainwater Volume 24-hour, 25-year precipitation = 7.1 inches Volume = 55 x 149 x 7.1 / 12 = 4,8494 cubic feet = 36,268 gallons Net secondary containment Volume = 323,001 - 44,212 - 4,885 - 20,374 - 22,499 - 12,436- 827 - 36,268 = 181,500 gallons Volume of largest tank Tank diam. = 32 feet Tank height = 30 feet Tank volume = pi x 32 x 32 /4 x 30 = 24,127 cubic feet = 180,470 gallons Adequacy Determination Since available containment of 181,500 gallons > 180,470 gallons tank volume, dike dimensions provide adequate secondary containment. Rev. 2 April 2010 Rev. 3. March 2012 Process Information Page Att. D-3-2 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment D-4 Container Storage Area Secondary Containment Calculations Gross Volume of Truck Off-loading Area and Dike plus 1 sump (assumes no sloped floor): One sump = 4 x 4 x 5 = 80 cu. ft = 598 gallons Containment inside width = 39 feet Containment inside length (from top of roll-over berms at each end) = 80 feet Rollover berm height above sump = 10" = 0.83 feet Total Volume (without allowing for sloped floor) = [39 x 80 x 0.83] + 80 cu. ft. = 2,670 cu. ft. = 19,971 gallons Less displacement: Two sloped floors: Elevation change = 0.83 feet Volume of 1 wedge = 39 x 40 x 0.83 x 0.5 = 647 cu. ft. = 4,840 gallons Volume of 2 wedges = 2 x 4,840 gallons = 9,680 gallons Bollards: Base of each bollard = 6-in. diameter = 0.196 sq. feet Volume within containment = 8 x 0.196 x .834 = 130 cu. ft. = 10 gallons Pump/grinder pads (2): Pump stands sit on the floor. Assume minimal displacement. Precipitation (since the off-loading area is under roof with walls extending down about 30% of the distance from the roof edge on the side walls, some precipitation can enter the containment area. Assume that 10% of the maximum precipitation can still enter the area.): 24-hour, 25-year storm = 7.1 inches = 0.59 feet Volume of rainwater = 0.59 x 39 x 80 x 0.1 = 184 cu. ft. = 1,377 gallons Non-bulk container storage - Base of 20 55-gallon drums. This is conservative since the drums are stored on pallets, but for this calculation, assume they are sitting on the floor: Drum diameter = 23 inches = 1.92 feet Depth in containment - since drums are spread along the wall, assume they are all at the midpoint of the containment depth = 0.83 / 2 = 0.41 ft Rev. 2 April 2010 Process Information Page Att. D-4-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 1.92 x 1.92 / 4 x 0.41 x 20 = 23.7 cu. ft. = 177 gallons Net secondary containment Volume = 19,971 - 9,680 - 10 - 1,377 - 177 = 8,727 gallons Volume of largest container or 10% of permitted capacity Tanker maximum volume = 6,000 gallons 10% of permitted capacity = 10% x 13,100 gallons = 1,310 gallons Containment must be able to hold 6,000 gallons Adequacy Determination Since available containment of 8,727 gallons > 6,000 gallons tanker volume, dike dimensions provide adequate secondary containment. Rev. 2 April 2010 Process Information Page Att. D-4-2 Appendix 3 Rejected Manifests Appendix 4 Method 21 Monitoring Results - July Appendix 5 Air Emissions Standards Title V Renewal Permit No. 2018-0805-TVR Appendix 6 Contingency Plan Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Section G CONTINGENCY PLAN Revision 4: March 2012 Revision 5: August 2012 Revision 6: November 2013 Revision 7: May 2014, page G-8 only Revision 8: December 2014, page G-3 only Revision 9: December 2017, page G-3 only Revision 10: March 2019, page G-3 only Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-i Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Contingency Plan Table of Contents G.1 RESPONSE LEVEL ........................................................................................................... 4 G.2 INITIAL ACTIONS............................................................................................................ 5 G.2.1 Spill ............................................................................................................................. 5 G.2.2 Fire .............................................................................................................................. 5 G.2.3 Tornado ....................................................................................................................... 5 G.2.4 Medical Emergency .................................................................................................... 6 G.3 NOTIFICATION ................................................................................................................ 7 G.3.1 Internal ........................................................................................................................ 7 G.3.2 External ....................................................................................................................... 7 G.3.2.1 Notification of National Response Center (NRC) .................................................. 8 G.3.2.2 Written Notification to ODEQ Director ................................................................. 8 G.3.2.3 Notification of the Local Emergency Planning Committee.................................... 9 G.3.3 Identification ............................................................................................................. 10 G.3.4 Assessment................................................................................................................ 10 G.4 FOLLOW-UP ................................................................................................................... 12 G.4.1 Control and Containment .......................................................................................... 12 G.4.2 Remediation .............................................................................................................. 12 G.4.3 Termination and Follow-Up Actions ........................................................................ 13 Fig. G-1 Fig. G-2 Table G-1 Table G-2 Table G-3 Att. G-1 Att. G-2 Att. G-3 Att. G-4 Response Process Typical Spill Response FIGURES TABLES Emergency Coordinator (EC) Notification List Spill Quantity and Appropriate Response Emergency Contacts ATTACHMENTS Emergency Response Operations Emergency Response Resources Plot Plan Example of Agreement for Emergency Assistance Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-ii Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 SECTION G CONTINGENCY PLAN As required by 40 CFR 264.51, 270.14(b)(7), and O.A.C. 252:205-3-2(f), Systech Environmental Corporation (Systech) has developed a Contingency Plan designed to minimize hazards to human health and the environment from fires, explosions, and any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. The Contingency Plan meets the requirements of 40 CFR 264 Subpart D and serves as a mechanism to ensure that the response management teams at Systech are adequately prepared to address a worst-case situation. As such, the Systech Contingency Plan details procedures for mobilizing personnel and mitigation assets. The resulting response is designed to minimize life threatening situations and damage to natural resources. This Contingency Plan will be implemented in conjunction with the co-located cement kiln operations on which the Systech facility is located. As such, activities identified in the Plan may be implemented by either Systech or cement plant personnel. This chapter outlines the initial response actions necessary to protect the safety of Systech personnel, the environment, and facilities during a hazardous waste discharge or other situation. The objective of the Contingency Plan is to provide field operators and responders with procedures for initial response to hazardous waste spills and other emergencies, to make initial notification of key personnel, and to activate the facility's Contingency Plan. This Contingency Plan is divided into sections that correspond to each stage of the initial response process for emergencies. Each section identifies the key personnel responsible for executing specific tasks. Figure G-1 summarizes the response process and serves as a map for this Contingency Plan. The Systech facility receives prequalified waste materials from regulated hazardous waste generators or marketers. Non-hazardous wastes may also be received. The materials are temporarily stored until they can be blended, processed, or used directly in the cement manufacturing process. All waste materials are blended, processed, and controlled to the extent Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 that their physical and chemical characteristics have been made compatible with the material and process requirements of cement manufacturing. The facility was designed and is operated to prevent spills, fires, or explosions. Personnel are thoroughly trained to act immediately should it ever become necessary to implement the Contingency Plan. The Contingency Plan is designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous wastes or hazardous waste constituents to the air, soil, or surface water. This plan would be implemented if any of these occurs. Attachment G-3 is a Plot Plan of the cement plant and Systech facility. Figure G-1: Response Process Discovery Coordinator Actions Response Management Systems Communications Initial Actions (G.2) Activate Internal Facility Alarm (G.3.1) Activate Contingency Plan (G.3.1) Notification (G.3.2) Identification (G.3.3) Assessment (G.3.4) Control & Containment (G.4.1) Remediation (G.4.2) Coordinator Write-up (G.4.3) Required Reports Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-2 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 On-Site EC Primary EC Alternate EC Table G-1 Emergency Coordinator (EC) Notification List Position/Title, Work Phone Cement Plant Shift Supervisor/Leadman 918-437-3902 or ext. 250 918-388-1150 (direct dial) One Shift Foreman will be on-site at all Address times. The Shift Foremen who are not on- site have no EC responsibilities. 24 Hour Emergency Phone 918-388-1150 Name Joseph "Joe" Sommer Position/Title Address Operations Supervisor 14547 North 68th East Ave Collinsville, OK 74021 Cell Phone (620) 870-1016 Name Wilma Davis Position/Title Address Fredonia, Interim Plant Manager/Operations Manager 100 N 1st Street Independence, KS 67301 Cell Number (620) 288-9438 Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-3 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 G.1 RESPONSE LEVEL The appropriate level of response for a particular incident largely depends on both the professional judgment of the primary or alternate EC and the regulatory reporting requirements. The factors that affect the level of response necessary for a specific incident include: Type of waste handling system and the necessity of suspending operations or diverting waste fuels during an emergency; Potential for fires, explosions, or releases to spread to other areas of the plant; Immediate health and safety effect of the incident on plant personnel; and Potential hazards to the outside environment and public health. More detailed information on specific components and functions of the response management system is provided in Attachment G-1. Figure G-2 Typical Spill Response Activate Contingency Plan Contain/Stop Flow Land Impact Containment and Recovery Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Notify Appropriate Personnel and Agencies Assess Spill Size and Threat Water Impact Containment Strategies Estimate Equipment and Personnel Needs Is Assistance Needed? Cleanup and Disposal Evaluation and Review Contingency Plan Page G-4 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 G.2 INITIAL ACTIONS G.2.1 Spill Upon discovery of a discharge, or imminent discharge, of hazardous waste, the discoverer shall immediately follow the steps outlined below. 1. DO NOT enter a hazardous area without proper personal protective equipment: respirator, gloves, rubber boots, goggles, and monitoring equipment as appropriate. 2. Stop flow by closing valves or shutting off pumps. 3. If spill is FQW, stop all transfer activity to the kiln area. 4. Shut off all ignition sources in the area, including, but not limited to, electrical equipment, automobiles, cigarettes, and welding equipment. 5. Contact the EC that is on-site... G.2.2 Fire Upon discovery of a fire, the discoverer shall immediately follow the steps outlined below. 1. Contact the EC that is on-site (in the order listed on Table G-1). If the primary EC is not on site, contact the alternate EC. 2. Activate local emergency response. 3. DO NOT enter any area that would jeopardize your safety. 4. Contain fire with hand-held extinguisher if the fire is manageable and does not present a threat to safety. G.2.3 Tornado Upon issuance of a tornado warning for the plant location, the discoverer shall immediately follow the steps outlined below. 1. Contact your immediate supervisor promptly so that he/she may contact all other employees using established communications systems. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-5 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 2. The Control Room Operator will activate the emergency siren. 3. Go directly to a shelter which is the nearest identified tornado shelter and away from windows or open areas. If at all possible, do not shelter alone. 4. Upon notification that the danger has passed, proceed to the primary rally point for a headcount. G.2.4 Medical Emergency Upon discovery of a medical emergency, the discoverer shall immediately follow the steps outlined below. 1. Assess the situation. If the accident scene is safe to enter, provide first aid to the best of your ability. If the accident scene is not safe, proceed to step 2. 2. Contact the designated first responder (9-1-1). Inform him of the nature of the emergency and location and state of the victim. 3. Contact the on-site EC. If the on-site EC is not available, contact the primary or alternate EC. Inform them of the nature of the emergency, and if emergency services are required. 4. If the accident scene is safe, stay with the victim. Make them as comfortable as possible until help arrives. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-6 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 G.3 NOTIFICATION G.3.1 Internal At the time a fire or release, which is not readily containable, or if a tornado warning is issued, the internal facility alarm is activated as instructed by an onsite, primary or alternate EC. The responding EC will implement the Contingency Plan and notify appropriate emergency response agencies, as needed. A list of emergency contacts is listed in Table G.3. The Emergency Coordinator is responsible for implementing the Contingency Plan. The Emergency Coordinator or designated alternates are available to facility personnel at all times. They will be on the facility premises or on call and therefore available to respond to an emergency by reaching the facility within a short period of time. The Emergency Coordinator, who is responsible for coordinating all emergency response measures, is familiar with: All aspects of the facility's Contingency Plan. All operations and activities at the facility. The location and characteristics of waste handled. The location of all records within the facility. The facility layout. The emphasis on immediate response to emergency conditions requires that the Emergency Coordinator be free to use his or her judgment in an emergency situation. Therefore, the Primary Emergency Coordinator and alternates have the authority to commit the resources needed to carry out the Contingency Plan. G.3.2 External All reportable spills >1 gallon are recorded in the Operating Record. Copies of these records are maintained by the Operations Supervisor. The EC or alternate is responsible for determining if a spill must be reported to federal, state, or local agencies. Any spill to surface waters is reportable. The EC or alternate is also responsible for notifying the Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-7 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 appropriate agencies if needed. Information to be included in the notification is addressed in Section G.3.3. G.3.2.1 Notification of National Response Center (NRC) Spills of hazardous substances, which exceed the Reportable Quantity (RQ) for that substance, must be immediately reported to the NRC. Any quantity of oil or fuel that reaches surface waters must be reported to the NRC. The information to be provided to the NRC by telephone is included in Section G.3.3. G.3.2.2 Written Notification to ODEQ Director The Site Manager is responsible for preparing spill reports for the regulatory agencies. All releases reported to the NRC will also be reported to the Oklahoma Department of Environmental Quality (ODEQ) by telephone. In addition, any spill of oil or fuel that exceeds 25 gallons should also be immediately reported to ODEQ. Table G-2 Spill Quantity and Appropriate Response Size Response Notify > 1 pound to environment (offsite) <25 gal in containment Cleanup and immediately cleaned up) Cleanup Report (if not contained and ODEQ Operation Supervisor >25 gal in containment Cleanup ODEQ Anything to surface water Contain and Cleanup NRC, ODEQ >1000 gal to surface water Contain NRC, ODEQ >RQ on-site, outside of Cleanup containment NRC, ODEQ >RQ leaving site Cleanup NRC, ODEQ, LEPC Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-8 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Branch FIRE HAZMAT POLICE HOSPITAL Table G-3 Emergency Contacts Agency Catoosa Fire Department Tulsa Fire Department Catoosa Police Department Hillcrest Health Care System Address (if written notification is required) Phone # 911 Type of Report Telephone 911 Telephone 911 Telephone 1120 S. Utica Tulsa, OK 74104 918-579- Telephone 1000 Reporting Deadline As Needed As needed As Needed As Needed Bailey Medical Center AMBULANCE LEPC Pafford Ambulance Rogers County Emergency Management Agency STATE/ FEDERAL Tulsa Area Emergency Management Agency Oklahoma Dept. of Env. Quality (ODEQ) National Response Center 106th & Garnett Owasso, OK 74055 911 219 S. Missouri, Rm. B113, Claremore, OK 74017 411 S. Frankfort Ave., Tulsa OK, 74103 707 N Robinson Oklahoma City, OK 73102 918-3412060 918-5967361 800-5220206 800-4248802 Telephone As Needed Telephone Immediately Telephone Immediately Telephone Immediately Written 15 days Telephone Immediately G.3.2.3 Notification of the Local Emergency Planning Committee The Local Emergency Planning Committee (LEPC) contact for the area is the Rogers County and Tulsa County Emergency Management Agency. The LEPC will be notified when any other agency is notified of a spill that leaves the site. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-9 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 G.3.3 Identification The responding EC will identify the following characteristics of any released material: Identification; Exact Source; Amount; and Impacted area. This may be accomplished by visual observation of materials, review of facility records or manifests, or, if necessary, by chemical analysis. G.3.4 Assessment During an emergency, the responding EC will assess the following possible hazards to human health or the environment: Direct and indirect effects of any materials released; Effects of gases generated; Effects of hazardous surface runoff from fire control materials; Effects of chemicals used to control the emergency; and Potential for surface water contamination. Will this emergency threaten human health or the environment outside the facility? If the responding EC determines that a significant quantity of hazardous waste has been released, or that an emergency will threaten human health or the environment, the responding EC, or his designee, will immediately activate the plant evacuation alarm and notify local authorities by calling the emergency 911 number. By calling 911, the Fire Department and the Police Department will be aware of the situation. If necessary, the responding EC, or the police or fire department, will notify the Hospital and Ambulance Service. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-10 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 If a reportable quantity of waste has been released, the primary EC will also notify the National Response Center as well as other appropriate agencies and authorities. The EC will include the following information in the notification: Name, address, and telephone number of the plant owner or operator; Name, address, and telephone number of the plant; Date, time, and type of incident (e.g., fire, explosion); Name and quantity of material(s) involved; Location of the spill; Surface on which the oil spilled; Amount of time before the spill will flow into a storm sewer inlet or other drainage pathway; Cause of the spill; Extent of damages and injuries, if any; Assessment of actual or potential hazards to human health or the environment, if applicable; Actions taken to mitigate the spill; If an evacuation will be required, and; Estimated quantity and disposition of any recovered materials. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-11 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 G.4 FOLLOW-UP G.4.1 Control and Containment During an emergency, the responding EC must take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other areas at the plant. These measures may include, where applicable, shutting off the flow of liquids, shutting down the flow of fuel into the kilns, and shutdown of the kilns. The EC will also monitor for leaks, pressure buildup, or other potential problems when the fuel flows and kilns are shut down. G.4.2 Remediation The following specific procedures will be initiated following an emergency: Immediately after an emergency, the primary EC will make arrangements for treatment, storage, or disposal of recovered wastes, contaminated soil, contaminated groundwater, contaminated surface water, or any other contaminated materials. Materials that result from a release, fire, or explosion will be analyzed and if the materials meet fuel requirements will be reintroduced into the tank system. Materials determined to be hazardous waste, and not meeting fuel requirements, will be sent to an appropriate off-site treatment or disposal facility. If the system is damaged, the waste will be containerized and either stored at Systech until repairs are made or sent to an appropriate off-site treatment or disposal facility. The Emergency Coordinator will ensure that no waste that may be incompatible with the released material is treated, stored, or disposed of until clean-up procedures are completed. Storage operations will be suspended in the affected area. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 The primary EC will ensure that cleanup procedures are completed and that emergency equipment is clean and fit for use before resuming operations in an affected area. Contaminated equipment will be rinsed with clean solvent or pressure water where necessary. Any resulting Contingency Plan Page G-12 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 contaminated solvent will be retained in a catch bucket or container and transferred into the fuel storage tanks. Small quantities of water used to clean contaminated equipment will be managed similarly. The primary EC will investigate the cause of the emergency and will take steps to prevent the recurrence of such incidents. G.4.3 Termination and Follow-Up Actions If a release to the environment occurs in an amount greater than 1 pound, the primary EC will notify ODEQ, in compliance with 40 CFR 264.196(d), within 24 hours of detection. The primary EC will also ensure that any waste that may be incompatible with the released materials is not treated, stored, or disposed of until cleanup procedures are completed; and that all emergency equipment listed in the Contingency Plan is decontaminated and fit for its intended use before operations can resume in affected areas of the plant. The EC will note in the plant's operating record the time, date, and details of any incident that requires the implementation of the Contingency Plan. Within 15 days of the incident, the Primary EC will submit a report to ODEQ, and the Local Emergency Planning Committee (LEPC). The report will contain the following information: Name, address, and telephone number of the plant owner or operator; Name, address, and telephone number of the plant; Date, time, and type of incident (e.g., fire, explosion); Name and quantity of material involved; Extent of injuries, if any; Assessment of actual or potential hazards to human health or the environment, if applicable; and Estimated quantity and disposition of any recovered materials. The Contingency Plan will be reviewed and amended, if necessary, whenever: Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 The facility permit is revised. Contingency Plan Page G-13 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 The plan fails in an emergency. Changes occur in the facility's design, construction, operation, maintenance, or other circumstances which materially increase the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes occur in the response necessary in any emergency. The list of Emergency Coordinators changes. The list of emergency equipment changes significantly. Rev. 8, December 2014 Rev.9, December 2017 Rev.10, March 2019 Contingency Plan Page G-14 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment G-1 EMERGENCY RESPONSE OPERATIONS Spill Response INITIAL RESPONSE DO NOT enter a hazardous area without proper personal protective equipment: respirator, gloves, rubber boots, goggles, and monitoring equipment as appropriate. Stop waste flow by closing valves or shutting off pumps. Stop all transfer activity. Shut off all ignition sources in the area including, but not limited to: electrical equipment, automobiles, cigarettes, and welding equipment. Contact the EC that is on site, who will contact the primary or secondary EC. If an RQ is exceeded or the spill threatens to spread outside the plant, immediately notify the NRC. DUTIES OF RESPONDING EC Attempt to determine the source of spill without risking personal safety. Identify the material spilled and determine the hazards involved in terms of the potential for fire, hazardous gas release, corrosion, explosion, or water pollution. If it is a reportable spill, notify appropriate agencies. Evacuate all endangered or unnecessary personnel. In case of the release of toxic or flammable gases, determine if off-site evacuation is advisable. Remove nearby wastes that may be incompatible with the spilled material. Investigate the spill and check analytical records and inventory data. Evaluate the hazard potential and assign trained personnel to clean up the spill. SPILL RESPONSE PROCEDURES Contain the spill as much as possible while attempting to stop the spill. If flammable material, rope off the spill area a minimum of 50 feet away from spill. To contain the spill: With absorbent booms or CKD: 1) Use booms in tandem (one placed a few inches behind the other) or CKD dikes to help control the flow of material. 2) Oil sorbent booms should be used on any water that could possibly be contaminated; they will serve as backups for materials that might get by the tandem sorbent booms With absorbent: 1) Pour absorbent from bags or barrels to form a dike. 2) Barrels can be turned on their sides and rolled to create a dike. 3) Use front-end loader buckets of absorbent or CKD for major spills. After the spill is contained, recover as much FQW liquid as possible and return to the FQW tanks; treat the remaining spill with neutralizing agents to decrease the risk of fire, corrosion, explosion, or other hazards. Apply non-reactive sorbent materials. If contamination of the area occurs, depending on instructions from the regulatory agencies, excavate the area and isolate removed materials from rainfall and runoff in a container or containment area. After the material has been characterized, develop a disposal plan. A plan may include, but not be limited to: blending with other materials and using as a fuel in the hot end of the kiln, or off-site disposal. Use on-site monitoring to determine safety of the area. Make any temporary repairs. Complete a written description of the event. The Primary EC will report the spill, if necessary. Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Fire or Explosion Response INITIAL RESPONSE Contact the EC that is on site, who will contact the primary or secondary EC. EC will notify Fire Department and send an employee to the front gate for escort. DO NOT enter any area that would jeopardize your safety. Contain fire with hand-held extinguisher if the fire is manageable and does not present a threat to safety. DUTIES OF RESPONDING EC Determine what material is on fire by location, inventory, or log. Determine if the staff is endangered by the fire or if the fire could spread to other wastes. Define the limits of the fire, estimate the potential dangers with respect to other materials in the immediate vicinity, and call the local Fire Department if needed. Evacuate all endangered personnel to the designated rally points. In case of a release of toxic gases or a potential for explosion, determine if off-site evacuation is necessary. Determine the best and safest approach to handling the fire, taking into consideration not only the type of fire, but also the direction of the flame, spread, wind direction, potential dangers and any physical limitations. FIRE RESPONSE PROCEDURES The EC will help Fire Department personnel decide if the fire should be left to burn or should be extinguished. Use only as much water as necessary, to minimize the amount of water that may become contaminated. Allow only emergency vehicles into the plant during the emergency. Contain any spilled material or contaminated water by using absorbent or absorbent booms Collect all contaminated absorbent for disposal Make any temporary repairs. Complete a written description of events. Begin equipment and area decontamination and replacement The Primary EC will report the fire, if necessary. FIRE RECURRENCE AND SPREAD PREVENTION PROCEDURES To reduce the possibility of sparking or heat generation that may result in a fire or explosion, shut down all mechanical equipment. Turn off all equipment not required for emergency response and close all pipelines feeding the kilns, if it can be done without hazard to personnel. After system shutdown is accomplished, monitor gauges and indicators for evidence of system changes. If changes develop, take steps to immediately identify and remedy the condition. Periodically inspect the affected areas for leaks, including, but not limited to, drops, sprays, pooling of liquids, or wet areas. Examine piping for evidence of failure, including cracks, ruptures, or abnormal distortion. The Primary EC will ensure that no material that may be incompatible with the released material is treated, stored, or disposed until cleanup procedures are complete. Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-2 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Emergency Evacuation Procedures DUTIES OF RESPONDING EC The responding EC is responsible for implementing the evacuation and will notify personnel if an evacuation is necessary. Employees and visitors will be directed to the proper exit and to the assigned safe areas. EVACUATION PROCEDURES The EC will assess the conditions and order an evacuation or any other action that is required. The EC will notify personnel if an evacuation is necessary by sounding the emergency alarm (a continuous blast on a siren or by providing instructions to evacuate using the radio/telephone system). When an evacuation is announced, work will be stopped. Personnel should go to the nearest exit. All employees should leave the plant and report to the designated rally points. Employees should not run or linger in entranceways or driveways and should congregate in the designated rally points. The Site Manager will bring the guest log to the rally point and account for all plant guests. All employees will be accounted for by their immediate supervisors. The Primary EC will notify personnel when it is safe to re-enter the facility. Re-entry will not be permitted until the Primary EC declares that it is safe to do so and issues an all-clear signal. RALLY POINTS and Routes Employee Parking Lot - Primary, evacuation should be by most direct route that does not put employee at risk of exposure, ( e.g. directly South past cement plant office building.) Scale House - Alternate, evacuation should be by most direct route that does not put employee at risk of exposure, ( e.g. directly West then Southwest across gravel lot.) EMERGENCY EVACUATION PRECAUTIONS Keep calm, think and avoid panic and confusion. WALK to the nearest exit. Know all exit locations; be sure that you know the quickest way out of the building. Do not lock office doors when evacuating the building. Do not delay evacuation for any reason. Do not assist in fire control unless you are properly trained and qualified. Stay clear of the plant and DO NOT interfere with emergency operations. Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-3 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Tornado Procedures DUTIES OF RESPONDING EC The responding EC is responsible for sounding the tornado alarm and will notify personnel if shelter is necessary. Employees and visitors will be directed to the proper shelter and to the assigned safe areas. SHELTER PROCEDURES The EC will assess the conditions and order personnel to seek shelter or any other action that is required. The EC will notify personnel if shelter is necessary by sounding the emergency alarm (a continuous blast on a siren or by providing instructions to seek shelter using the radio/telephone system). When an alarm is sounded, work will be stopped. Personnel should go to the nearest shelter. All employees should report to a designated tornado shelter. Employees should not run or linger in entranceways or driveways and should congregate in the designated shelters. Do not shelter alone if possible. The Primary EC will notify personnel when it is safe to leave shelter and proceed to the rally point. Departure from shelter will not be permitted until the Primary EC declares that it is safe to do so. Once the Primary EC announces an "all-clear" over the radio/telephone system, personnel should proceed to the designated rally point. The Site Manager will consult the guest log and account for all plant guests. All employees will be accounted for by their immediate supervisors. RALLY POINTS and Routes Employee Parking Lot - Primary, evacuation should be by most direct route that does not put employee at risk of exposure, ( e.g. directly South past cement plant office building.) Scale House - Alternate, evacuation should be by most direct route that does not put employee at risk of exposure, ( e.g. directly West then Southwest across gravel lot.) SHELTER PRECAUTIONS Keep calm, think and avoid panic and confusion. WALK to the nearest shelter. Know all shelter locations; be sure that you know the quickest way to shelter. Do not lock office doors when seeking shelter. Do not delay taking shelter for any reason. Go below ground if possible. Stay away from any opening. After the all-clear is given, stay clear of the plant and DO NOT interfere with emergency operations. SEVERE WEATHER SHELTERS Main Office - North hallway by break room Console - console basement Cooler Building - Tunnel to console Quarry - Basement of gyratory Blending - Interstice at man lift elevator Garage - Parts room Packhouse - Silo interstices Mill Building - Basement of load center Coal - Drag and hopper tunnel Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-4 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-5 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Procedures for Recovery of Personnel DUTIES OF RESPONDING EC The responding EC is responsible for polling supervisors and determining which, if any, personnel are not accounted for. If EMS is requested, EC will send an employee to the front gate for escort. EC will ensure plant is safe for personnel to conduct search and rescue operations. EC will arrange needed personnel in groups of four to conduct search and rescue. SEARCH AND RESCUE PROCEDURES Groups of four will comb assigned areas for personnel (with Lafarge personnel). Found employees should be reported over the radio. Search groups should not move injured employees except in case of immediate danger. Search groups will stay with injured employees until emergency personnel have arrived on-scene. Rev. 5, August 2012 Rev. 6, November 2013 Rev. 7, May 2014 Contingency Plan Page Att. G-1-6 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment G-2 EMERGENCY RESPONSE RESOURCES Emergency Equipment Location Outline of Capabilities Internal Communication Systems Portable radios FQW emergency shutdown switch Telephone (intercom) Emergency alarm Facility-wide office, personnel, kiln area Kiln control room Lab, office, facilitywide Plant-wide, kiln area Internal communication Shut off primary feed pumps to kiln Internal communication, plant-wide public address, emergency alarm Plant-wide, audible fire alarm External Communications Systems Telephones Office, lab, kiln area, EC Call outside for emergency assistance Extinguishers: 20-lb ABC AFFF Fire Protection System Absorbent Fire Extinguishing System Tank Farm, Truck Offloading Area, Fuels Laboratory Tank Farm Spill Control Equipment Truck Offloading Area Solvent Absorbent Booms Organic vapor monitor Empty containers Truck Offloading Area Fuels laboratory Truck Offloading Area Other Emergency Equipment First aid supplies: bandages, gauze Lab bandages, tape, butterfly bandages, antibacterial ointments, splints, aspirin, eyewash, local/topical anesthetics Emergency eyewash, fountain and Lab, Truck Offloading drench showerhead Area For use on Type A, B, or C fires Automated response to control fire Contain, absorb, and clean up spills from off-loading pads, container building Absorb spills Exposure monitoring Receptacle for leaking or damaged containers and for spilled materials Immediate first aid for minor injuries Immediate treatment for personnel in case of contact with waste materials Rev. 5, August 2012 Rev 6, November 2013 Rev 7, May 2014 Contingency Plan Page Att. G-2-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Emergency Equipment Protective clothing and equipment: hard hats, protective eyewear, rubber and neoprene boots, impervious gloves, face shields, protective eyeglasses, half-face dust/chemical cartridge respirators, chemical cartridges Clean solvent Location Office Truck Offloading Area Outline of Capabilities Protect personnel from possible hazards Rinse contaminated equipment Rev. 5, August 2012 Rev 6, November 2013 Rev 7, May 2014 Contingency Plan Page Att. G-2-2 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment G-3 PLOT PLAN Rev. 4, March 2012 Rev. 5, August 2012 Rev. 6, November 2013 Contingency Plan Page Att. G-3-1 Systech Environmental Corporation Tulsa, OK U.S. EPA ID No. OKR000025452 Attachment G-4 EXAMPLE OF AGREEMENT FOR EMERGENCY ASSISTANCE Rev. 4, March 2012 Rev. 5, August 2012 Rev. 6, November 2013 Contingency Plan Page Att. G-4-1 AGREEMENT FOR EMERGENCY ASSISTANCE BY AND BETWEEN SYSTECH TULSA FACILITY AND _______________________ This agreement has been prepared to make arrangements for emergency services to be provided by the _____________________ in the event of emergencies that may result from fires, explosions, or a major release at: Systech Environmental Corporation 2701 N. 145th East Avenue Tulsa, Oklahoma 74116 918-437-3902 Any request for emergency assistance will be issued by telephone by the primary emergency coordinator, the on-site coordinators, or their designee. Systech will have someone at the plant entrance to give specific directions to the incident. One of the emergency coordinators will be at the scene to brief you on the assistance required. The materials primarily being handled at the Tulsa facility are organic compounds which have been used as industrial solvents, coats, etc., that have been blended into Fuel Quality Waste (FQW). Heavy metals will be present within the FQW. A Material Safety Data Sheet for typical waste fuel is enclosed for your use. If an emergency arises, the specific compounds involved will be immediately identified by consulting material inventory and analytical records at the Systech facility which is located within the Systech Tulsa facility. A copy of the Systech Contingency Plan, which describes emergency response procedures, identifies the type and location of emergency equipment and sets forth emergency assistance requirements, is enclosed with this agreement. The __________________ agrees to provide emergency assistance to the Systech Tulsa facility, at their request, if an incident occurs which requires facilities, equipment or expertise not available at the facility. _____________________________________________________________________________ Systech Tulsa: By: ______________________________ Date: ______________________________ _______________: By: ______________________________ Date: ______________________________ Rev. 4, March 2012 Rev. 5, August 2012 Rev. 6, November 2013 Contingency Plan Page Att. G-4-2