attachments d- f (pdf)

106
Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 ATTACHMENT D MULTIPLE HEARTH INCINERATOR - HWMU-32 ENGINEERING DESCRIPTION OF THE MULTIPLE HEARTH INCINERATION SYSTEM RED ROCHESTER, LLC EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497 TABLE OF CONTENTS Multiple Hearth Incinerator Figure D2 – Building 95 Multiple Hearth Incinerator Figure D16 – Multiple Hearth Incinerator Waste Sludge Feed and Ash Management System Appendices: Appendix D-5 – SCC Burner Information Appendix D-6 – SCC Combustion Air Fan Curve Appendix D-7 – ID Fan (System) Performance Curve Appendix D-8 – Weigh Conveyor Vendor Diagrams HWMU-32 Drawings List Trial Burn / Comprehensive Performance Test D1

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Page 1: Attachments D- F (PDF)

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

ATTACHMENT D

MULTIPLE HEARTH INCINERATOR - HWMU-32

ENGINEERING DESCRIPTION OF THE MULTIPLE HEARTH INCINERATION SYSTEM

RED ROCHESTER, LLC

EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY

EPA ID NUMBER NYD 980592497

TABLE OF CONTENTS

Multiple Hearth Incinerator

Figure D2 – Building 95 Multiple Hearth Incinerator

Figure D16 – Multiple Hearth Incinerator Waste Sludge Feed and Ash Management System

Appendices:

Appendix D-5 – SCC Burner Information

Appendix D-6 – SCC Combustion Air Fan Curve

Appendix D-7 – ID Fan (System) Performance Curve

Appendix D-8 – Weigh Conveyor Vendor Diagrams

HWMU-32 Drawings List

Trial Burn / Comprehensive Performance Test

D1

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

MULTIIPLE HEARTH INCINERATOR (MHI)

The MHI, serial no. 74445, was manufactured by Envirotech System, Inc. The MHI as shown in Figure D-2 is an eight hearth (0 to 7) unit. The zero hearth, located at the top of the unit serves as a flue gas pretreatment device. The sludge is fed to the #1 hearth by a screw conveyer system. Drying of the feed occurs on hearths #1 and #2. Burning or combustion of the feed takes place on hearth levels #3, #4, and #5. Ash cools down on levels 6 and 7 and is discharged at the bottom of the unit. The waste feed proceeds from one hearth level down to the next and, the feed is distributed across each hearth with a rotating rabble arm. The calculated residence time is approximately two hours (15-20 minutes in each hearth) for the waste feed inside the hearth, before it is "ashed" out in the bottom. Natural gas is used as needed as auxiliary fuel to support the combustion temperatures inside the hearth for the 2-hour duration. Depending on which hearth level the arm is located, the blades are pitched inward or outward to promote gradual waste feed movement to the center or outside wall of the MHI. Also, the arm

serves to break up the Waste feed allowing uniform heat distribution through the waste feed layer.

Non-contact cooling air is introduced at the bottom of the unit and flows through the center of the rotating hollow shaft and may either be discharged fully to atmosphere or partially returned to the #6 hearth to provide air below the burning zone. Combustion / flue gases exit from the top of the zero hearth and are sent to the SCC for further destruction of organics and hydrocarbons.

Table D-5 provides the construction details of the MHI. The specifications of the burners are listed in Table D-6.

SECONDARY COMBUSTION CHAMBER (SCC)

Organics present in the flue gases exiting from the MHI are destroyed in the SCC. The SCC operates at temperatures and residence times sufficient to meet regulatory requirements for Destruction and Removal Efficiency (DRE) for organic compounds in the waste feed. The actual temperatures that will determine operating conditions were and will again be demonstrated during Comprehensive Performance Tests that are required every 5 years. As previously mentioned, no wastes are fed directly to the SCC.

D2

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

The SCC specifications are listed in Table D.7, Burner specifications are given in Table D-8.

Drawings 095XX-312-017-Sheet 11 (SCC general arrangement) and E095XX-310-025 (process flow

diagram) indicate the dimensions used in calculating residence time.

Waste Feeds to MHI

Sludge is pumped from one of-the four holding tanks. There are three (3) 50,000 gallon and one

(1) 100,000 gallon holding tanks. Sludge is pumped from a holding tank to the dewatering equipment

(centrifuge) for dewatering. The dewatered sludge is dropped from the centrifuge into the sludge

storage bunker by gravity. A bunker conveyor moves the sludge to the horizontal portion of the

elevating conveyor. Grit conveyed with a grit conveyor can be added to the sludge on the elevating

conveyor. The elevating conveyor lifts the sludge and grit and drops it from a horizontal section into a

screw auger, which feeds the sludge into the #1 hearth.

RED has a waste feed measurement system. Drawings of this belt weigh scale system, are attached in Appendix D-8. As shown on the waste feed and ash handling system schematic (Figure D-16), it is located at the end of the drag conveyor and before the drop chute to the screw conveyor. When the sludge weigh conveyor is out of service the incinerator is not operated.

Combustion Air and Fuel to MHI

Approximately 10,000 scfm of combustion air is provided to the MHI by a 100 horsepower

(hp) fan. Additional combustion air is provided by a second blower with a rating of 2500 scfm at 7" static

pressure and 5 hp.

Commercially available natural gas is fed to the MHI at the rate of up to about 12,400 cfh at 3.5

psig. MHI burner specifications are given in Table D-6. A maximum heat load of about 48

MMBTU/HR is available at the MHI. In the event of an automatic waste feed cutoff, natural gas will

continue to be used to support the combustion temperature inside the hearth and the secondary

combustion chamber at the permit limit for a duration of 2.25 hours to ensure that the sludge remaining in

the hearth is burned out.

Drawing E095XX-770-003 shows combustion air and natural gas flows to the MHI. The drawing

also provides details of MHI instrumentation.

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

Auxiliary Fuel and Air to SCC

The SCC burner combustion air is provided from a blower. The SCC burner and blower

specifications are listed in Table D-8. Natural gas is fed to the SCC through a burner rated at

approximately 22 MM Btu/hr. The available maximum heating load to the MHI and SCC combined is

about 70 MMBTU/HR.

Auxiliary Waste Feed to SCC

No wastes are fed to the SCC. The feeds to the SCC consist of the exhaust gases, from the MHI, natural gas and- auxiliary combustion air provided by a blower as referenced in Table D-8.

FEED LOCATIONS

Table D-1 identifies the various feeds and where they are introduced to the system. Generally

combustion is accomplished by the heating value of the waste feed. Auxiliary natural gas is fed to the

MHI as needed. In the SCC, natural gas is used to elevate the temperature of the MHI flue gases in order to

complete destruction of organics.

AUTOMATIC WASTE FEED CUTOFF SYSTEMS (AWFCO)

Parameters which will cause an automatic waste feed cutoff are listed in Table E-4 of Exhibit E in

Module I Schedule I. Automatic cutoffs for waste feed are accomplished by turning off the power to the

waste feed conveyor. A distributed control system (DCS), known as the MOD 300, located and operated

from the control room by trained operators, provides the appropriate alarm that a waste feed cutoff has

occurred and indicates the cause for the cutoff.

SHUTDOWN PROCEDURES

Shutdown definitions and parameters for the MHI and SCC are listed in Table D-10. The induced draft

fan will be shut off, and emergency natural draft by-pass stack on the SCC will be opened if conditions trigger an

emergency shutdown. This stack is sufficiently tall to vent and disperse MHI gases directly into the atmosphere.

This will prevent fugitive emissions from escaping either into the building or at ground level.

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

AIR POLLUTION CONTROL EQUIPMENT (APCE)

Flue gases leaving the SCC enter the APCE where particulates, metals and acid gases are

removed in staged equipment consisting of: a quench chamber, a packed bed condenser/scrubber, an

entrainment separator, a variable throat venturi, and a WESP. Planned APCE setpoints -for these

devices during normal operations are summarized in Table D-11. The various emission control

processes of the APCE are described in the following sections.

The hot flue gases from the SCC are first quenched to adiabatic saturation temperature in the

quench. Quench water will be once through and comes from the secondary treatment effluent. The

quench water will be continuously discharged from the quench bottoms sump and returned to the

wastewater treatment plant to prevent build-up of suspended and dissolved solids.

The Condenser, using once through secondary treatment effluent water, is a counter current

flow packed scrubber equipped with a structured packing that resists build up and plugging. As gases

pass through the packed section, they will be sub-cooled and water vapor condensed. In the

condensation process, fine particles are formed which further act as nuclei to promote the growth of

larger particles which are more easily collected downstream by the Venturi Scrubber. The cooled

gases exit the Condenser through a mist eliminator and enter the Venturi Scrubber.

The Venturi is an inertial impaction device where the gases containing particles are accelerated into

the high velocity 'throat' area. At the throat, water injected from above is sheared into millions of droplets,

which collide and encapsulate the gas particles. Particle collection efficiency is directly related or

proportional to the pressure drop across the throat; it is inversely proportional to the size of the particle

contained in the gas stream. As the gas flow varies through the scrubber, a damper in the throat can be

manually or automatically modulated to maintain a constant pressure drop. The venturi differential is

calculated by the MOD300 control system, once every second, by subtracting the inlet pressure (PT 1097)

from the outlet pressure (PT 1091). The scrubber water is supplied by effluent (STE) recycled from the

venturi and the entrainment separator.

The gases and droplets containing particles exit the Venturi and enter into the Entrainment

Separator where water droplets are separated from-the gas stream and more secondary treatment effluent

water is used to clean the separator. Liquid that drains into the sump below is recycled back to the

Venturi. The pH of the recycled liquid is monitored and remaining acid gases are neutralized. Suspended

and dissolved solids build-up is controlled by a continuous blowdown loop.

Drawings 095XX-312-018-Sheet 3 and 095XX-312-018-Sheet 4 respectively, show the plan and

elevation arrangements for the quench, condenser, venturi, and entrainment separator.

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

The gas stream from the Entrainment Separator is next passed through a wet electrostatic precipitator (WESP). The WESP is a final 'polishing' device that removes submicron particulate matter not captured by the venturi. The gas will flow into the region between discharge and collecting electrodes. The particles are charged by high intensity corona. The charged particles will then be driven electrostatically to the grounded collecting electrodes. The collecting tubes of the WESP are periodically flushed with water to remove collected matter. The WESP drains, other APCE drains, and any equipment overflows, drain into an existing sump from which they are pumped back into the wastewater treatment plant for treatment. Drawing V095XX-312-018-Sheet 19 contains the process and instrumentation details for the WESP.

The treated gas exits from the WESP through an ID fan through a silencer in the discharge duct, and is dispersed to the atmosphere by a stack. The venturi is automatically adjusted to control the MHI draft. In addition, the draft can be controlled by changing the fan speed-by the use-of a variable frequency drive (VFD). Specifications for the ID fan, motor and the VFD are shown in Table D-12.

A plume suppression burner reheat stack gases to approximately 175 deg F in order to create adequate gas exit velocity for dispersion. Reheating also minimizes plume formation. A differential pressure element mounted in the stack (described in Table D-36) measures exhaust gas flow. Details of the stack and plume suppression system are provided in Table D-13. Sampling ports are installed in the exhaust stack at rooftop and sub-roof levels and are shown in Drawing E095XX-319-014. A complete process flow diagram is shown in Drawing E095XX-310-025.

FUGITIVE EMISSION CONTROL

Fugitive emissions to the atmosphere are unlikely during normal operation considering the negative draft maintained throughout the MHIS. An alarm for positive MHI pressure warns the operator in the control room if the process or system momentarily pressurizes. In the event of the loss of negative draft, waste feed will be automatically cutoff.

All equipment access doors, inspection openings, and the ductwork leading to the stack following the discharge of the ID fan are sealed with bolted flanges or otherwise secured.

ASH DISCHARGE

Ash is discharged from the #7 hearth through a chute that feeds a crusher. From the crusher, the ash enters an-

eductor and is pneumatically conveyed to an ash bin located on the fourth floor of the building. There are two sets of

crashers/eductors; typically the ash is-conveyed through one crusher/eductor while the other serves as a backup.

There are level indicators on the ash bin that go to the MOD300 to allow timely transfer of the ash to an enclosed

transfer trailer outside the building. Ash is transferred automatically when the bin level reaches 50%. There is an ash

bin high-level alarm that shuts down the MHI and feed system. Also, the transfer trailer is equipped with a level

indicator. The transfer trailer is later emptied into an over-the-road trailer for shipment to a smelter for precious

metals reclamation.

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-1 INCINERATOR FEED LOCATIONS

Feed Stream Inputs to MHI Inputs to SCC

Sludge 1 None

Grit

Natural Gas

1

1(a)

None

1 (b)

(a) Natural gas is supplied to (10) burners inside the MHI; combustion air is available at each burner, supplied by a blower.

(b) Natural gas is supplied to one burner; combustion air is supplied to the

burner by a blower.

TABLE D-2 FEED SYSTEM DESIGN SPECIFICATIONS

Feed Type Feed Sys t em Delivery to MHI

Type CapacityMaterial of Construction

Sludge Bunker Conveyor N A NA NA

NA

Carbon Steel Carbon Steel

Grit Tank Conveyor

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-6 MHI BURNERS SPECIFICATIONS

A total of ten (10) North American gas barriers are located inside the MHI. Fig D-2 shows the location of each burner. The table below lists the burner location, number, dimensions and heat duty.

Location Inside the MHI Number North American

SeriesMax.duty (MM Btu/hr)

each Dimensions/ Flame length

Zero Hearth Two 6422 3.2 8" x 8.2'

Hearths #1 and #2 (Drying Zone)

Two (2) 6422 3.2 , 8" x 8.2'

Hearths #3 and #4 (CombustionZone)

Two (2) 6422 3.2 8" x 8.2'

Hearths #5, #6, (Burnout Zone)

Four (4)

6422 3.2 8" x 12'

Note: Burner dimensions refer to entry diameters; flame lengths will vary .depending on operating conditions.

D8

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Page 9: Attachments D- F (PDF)

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-7 SCC SPECIFICATIONS

The SCC is a top fired downflow unit. Flue gases from the MHI enter the SCC at the top through a tangential entry approximately 6' in diameter and discharge through an outlet approximately 7'6" in diameter, located near the bottom of the unit. The unit is fitted with welded cone bottom with a 60 degree slope for ash collection and removal.

Height 37' (non-dnal)

Shell 0.D. 12' (nominal)

Shell I.D. 101-10" (nominal) Material of

construction 3/8" thick rolled cold steel welded construction, finished with a Carboline Carbo Zinc 11 primer and Carboline 1248 aluminum finish high temperature paint

Refractory The SCC is lined with approximately 7" of refractory; (approximately 41/2" of KALA Refractory brick and 21/2" of KALA insulating brick manufactured by Harbison Walker)

Weight 170,000 pounds (62,000 pounds shell and 108,000 pounds refractory

Drawing V095XX -312-017, Sheet 11 shows SCC arrangement with relief stack.

Emergency Relief Stack:

A refractory lined vertical stack with a refractory lined lid is installed on top of the SCC and held in normally closed position by a pneumatically operated cylinder.

Stack – 1/2" carbon steel, 6' 0.D. x 5' high, rolled and welded

Lid – 1/2" carbon steel, 6.5' O.D. x 4' deep

D9

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-8 SCC BURNER AND BLOWER SPECIFICATIONS

Burner:

A North American 'Magna Flame Lo-Nox' burner is located in the SCC tangentially to the entering gas stream. The burner is rated approximately at 22 MMBtu/hr (model #4796-14), at 3-5 psig gas supply pressure to inlet of piping, and 8 psig air pressure from the combustion air blower. The burner is furnished with a pre-piped and pre-wired fuel train, approximately 10’ long x 4' wide x 7' high. The-fuel train is located inside Building 95.

Manufacturer's bulletin # 4796 is included as Appendix D-5

Combustion Air Blower:

Manufacturer Chicago Blower Co., Type DI 6LS, Size 15

Size 5100 acfm at 23"wc and 70 deg F.

Motor Nominal 25 hp; 230-460/3/60, TEC

Appendix D-6 shows the fan performance curve.

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

Table D-10 Shutdown Definition and Parameters for the MHI and the SCC

SHUTDOWN PARAMETERS SHUTDOVVN ACTIONS

1. Instrument air pressure < 25 psig for 30 sec or

1. Stop all waste feed and fuel to the MHI and SCC.

2. SCC Emergency Cap open. 2.. Maintain all water flows to the APCE.

3. ID fan loss due to loss of electric power or

1. Stop all waste feed and fuel to the MHI and SCC.

4. Quench exhaust gas > 270 F for 30 2. Shutdown ID fan. sec or 3. Open SCC emergency cap.

5. Hearth draft positive for 30 sec 4. Maintain all water flows to the APCE.

TABLE D-11 APCE SPECIFICATIONS

1. Quench

Dimensions 7’ OD, 14’ High

Material of #11 gauge Hastelloy C-276

Primary (up) Nozzles Min 50 GPM by four (4) full cone spray, TF24CY by Bete

Secondary Nozzles Min. 100 GPM by four (4) full cone spray, TF-32C by Bete

Maximum Temperature 1800 F

Quench Gas Exit Temperature 270 F

Reference Drawing No. E095XX-770-005B:

2. Condenser (packed bed)

Dimensions' 10' dia x 24' High

Material of #1l Gauge Hastelloy C-276

Packing Depth 8"

Packing Material Mufflers PPLMGC 45 Pack

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

Flow 1000 GPM through seven (7) teflon Bete TF-72FC full cone spray nozzles

Mist Eliminator Depth

6'' depth of materials as in packing

Mist Eliminator Flow Periodic flow through seven (7) Bete TF-20FC nozzles

Reference Drawing No. E095XX-770-005B: TABLE D-11 APCE SPECIFICATIONS 3. Venturi Scrubber:

Height 10.5'(excluding support legs) Diameter 3'

. Material of Construction

. .3/16" thick plate Hastelloy C276

Flow The scrubber is equipped with 2 Bete Teflon spray nozzles, TF4$FC, one placed above the other concentrically above the throat of the venturi. A minimum of 80 GPM is pumped through each nozzle

Reference Drawing No. E095XX-770-006

4.Separator:

Height 23'

Diameter 9'

Material of Construction 3/16" thick AL6XN alloy

Mist Eliminating Section Consists of 6 Munters T-271 polypropylene chevron style panels are 36 inch x 24 inch in plan, located in the top of

Mist Eliminator Wash Intermittent washdown spray header with 4 Bete Teflon TF24FC spray nozzles providing up to 80 GPM

Reference Drawing No E095XX-770-006

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-11 APCE SPECIFICATIONS

5. Wet Electrostatic Precipitator

Height 35' - 3" (including support legs)

Diameter 10'

Material of Construction 3161 Stainless Steel, Inlet and outlet sections of the WESP are 1/4" thick and the hexagonal tube bundle (collector tubes) are 18 gage if internal and 3/16" thick if on the exterior periphery and exposed atmospheric temperature

Collector Assembly The collector surface consist of (85) 13 ft long hex tubes in a bundle with concentric charge discharge electrode masts (one per tube). The masts are suspended by a high voltage grid that has mast alignment mechanisms to maintain concentricity and prevent arcing. •

Purge Air Heaters .

Four (4) total and two (2) per each insulator compartment are maintained at 150 F. Purge air is blown through the heaters by either the ID fan or by two (2) separate air blowers to prevent moist process gas from condensing out on the high voltage surfaces and dropping DC voltage

Power Supply to Grid and Masts Full-wave rectified DC power to 65 KV voltage, 300 made continuous

current produced by silicon-controlled transformer rectifier. Input primary power is 480 V single-phase 58 AMP DC current

Preconditioning Atomized Water Spray

In the inlet duct to the WESP produces an inlet fog using 80 PSIG compressed air and 0.5 GPM of water running continuously. A nozzles "spider" consisting of 5 Sonic SESNZ-ST47A00 nozzles combines the compressed air and water.

Intermittent Spray Washdown

1to 2 minutes duration approximately 2-3 times per day irrigates the tube bundle using 8 Bete NCM0707W nozzles, material CPVC, 3/4" NPT connections, for cleaning purposes

Reference Drawing No. V095XX-312-018, Sheet 19

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

TABLE D-12 ID FAN AND MOTOR SPECIFICATIONS

ID FAN:

Manufacturer Robinson Industries

RPM 1,750

BHP 279

Design Maximum Air Flow

. 20,500 ACFM at - 60" H2O system pressure

.

Material of Construction 316 SS inlet and discharge housings; fan wheel, hub and shaft sleeve made of Hastelloy C-276

Reference Drawing No. V095XX-312-019, Sheet 2

Appendix D-7 shows the fan curve for static pressure and acfm relationship.

MOTOR:

Manufacturer Reliance Electric Co.

Size Three Phase, 60 Hertz, 460 volts, 300hp, 1800 RPM

Motor Speed Adjustable by a separate variable frequency (VFD)

VFD:

The function of the VHD is to adjust the fan motor speed depending on load conditions. If the drive fails, the motor will be automatically directed to full speed.

Manufacturer Reliance Electric Co.

Size 350 hp, 480 volts, 60 Hz, output rating of 420 amps

Enclosure NEMA I, force ventilated TABLE D-13 STACK AND PLUME ABATEMENT SYSTEM

Stack The cleaned gases exiting from the WESP are exhausted by the ID Fan through a duct

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

system and a stack into the atmosphere.

Material of Construction 316 SS, flanged. and welded sections

Diameter 42" ID

Height Approx. 70' from the roof level, gas discharges at 191' from the base of the terrain

Ports 4

Continuous Emission Monitoring System (CEM)

Located above sampling ports

Reference Drawing No. E095XX-319-014

Plume Abatement System

The plume abatement system consists of a natural gas fired burner Ideated concentrically at the bottom of the APCE discharge stack. The system includes a combustion air blower, pre-piped natural gas train and a spark ignition burner Blower: North American Model 2408-F-TIOD direct drive unit with inlet filter. The blower is rated at 115,000 SCFH at 8 osig. The a 10 hp unit wired at 460 volts, 3 phase, 60 Hz.

Burner:

The natural gas train and the burner.(North American Model 4570-12) consist of Factory Mutual approved and UL listed components and are designed to produce 7 MMBTU/Hr with natural gas-input at 5 psi. At high fire, the burner flame is approximately 2' wide and 6' long. The plume abatement burner usually runs at low fire approximately 8 months of the year and operates between 10 and 25.% the other four months of the year. Gas flow rates shown below are varying slightly to maintain the proper stack exit temperature. The flow rates shown are based on a pitot tube measurements at the 3 damper positions.

Low Fire 10%

Air Damper Opening

25% Air Damper Opening

Air (scfm)

185 240 370

Gas (scfm)

6.8

13.7

22.4

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TABLE D-50 MHI SYSTEM TEMPERATURE MEASUREMENT

Process Device Description Instrument tag No. Drawing No. Range AccuracyParameter * % of reading

#3 Hearth Thermocouples, TYPE K TE 943S, TE 943N E095XX-770-003K 0-2000 F + / - 0.75 % *

#4 Hearth Thermocouples, TYPE K TE 944S, TE 944N E095XX-770-003K 0-2000 F + / - 0.75 % *

# 6 Hearth Thermocouples, TYPE K TE 946S, TE 946N E095XX-770-003K 0-2000 F + / - 0.75 % *

#0 Hearth Thermocouples, TYPE K TE 940A. TE 940B E095XX-770-003K 0-2000 F + / - 0.75 % *

SCC Outlet Thermocouples, TYPE K TE 1021A,B E095XX-770-004F 0-2000 F + / - 0.75 % *

Quench Exit Resistance Thermal Device TE 1055A,B E095XX-770-005G 0-500 F + / - 0.62 % *

ID Fan inlet Resistance Thermal Device TE 1103 E095XX-770-006H 0-500 F + / - 0.62 % *

Stack Gas Thermocouples, TYPE K TE 910 E095XX-770-007H 0-2000 F + / - 0.75 % *

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TABLE D-51 MHI FLOW MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

Natural gas to MHI (all burners) TEMP Differential flow meter FE 920 E095XX-770-003K 0-25000 SCFH +/- 1 % FS **

Natural gas to SCC burner TEMP Differential flow meter FE 1008 E095XX-770-004F 0-30000 SCFH +/- 1 % FS **

Quench Lower Sprays Vortex flow meter FE 1053 E095XX-770-005G 0-300 GPM +/- 0.8 %*

Condenser (once through) water Vortex flow meter FE 1076 E095XX-770-005G 0-2000 GPM +/- 0.8 %*

Venturi blowdown Vortex flow meter FE 1096 E095XX-770-006H 0-75 GPM +/- 0.8 %*

Venturi approach Vortex flow meter FE 1093 E095XX-770-006H 0-150 GPM +/- 0.8 %*

Venturi Throat Vortex flow meter FE 1092 E095XX-770-006H 0-150 GPM +/- 0.8 %*

Stack Flow, DP flowmeter Anubar, pitot tube FE1147 E095XX-770-007H 0-25000 SCFM +/- 3 % FS **

* % of reading** Full Scale

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TABLE D-52 MHI PRESSURE MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

MHI combustion air Pressure Switch Low PSL 969 E095XX-770-003K ON/OFF, SP=26" wc decr*

MHI natural gas Pressure Switch High PSH 353-1, V095NA-312-002 ON/OFF, SP=6.7 psig risingPressure Switch Low PSL 352-1 (SH. 66) ON/OFF, SP=2 psig decr*

SCC combustion air Pressure Switch Low PSL 1014 E095XX-770-004F ON/OFF, SP=20 wc decr*Pressure Switch Low PSL1005 ON/OFF, SP=12 OSI* decr*

SCC natural gas Pressure Switch High PSH1007 E095XX-770-004F ON/OFF, SP=4 psig risingPT 968 A

Offgas From Hearth Pressure transducers PT 968 B E095XX-770-004F -1" TO +1"wc +/-0.25% FS*PT1091

Venturi differential Pressure transducers PT 1097 E095XX-770-006H -90" TO +10"wc +/-0.25% FS*

Condenser pressure drop Pressure transducers PT 1073 E095XX-770-005GPT 1097 E095XX-770-006H 30" TO +10"wc +/-0.25% FS*

ID fan outlet Gauge (local) PI 1133 E095XX-770-007H 0" TO +10"wc +/-2% FS*

*decr: decreasing, osi: ounces per square inch, FS: Full Scale

TABLE D-53 MHI PROCESS MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

Venturi blowdown pH pH meter AE 1094 E095XX-770-006H 0-14 pH +/-0.03 pH

Oxygen Level O2 sensor AE 990 E095XX-770-003J 0-25% O2 +/-0.5 O20-200 PPM & +/-10% or 10 ppm

Carbon monoxide level CO sensor AE 1146 E095XX-770-007H 0-3000 PPM of PTM

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D23

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D24

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D25

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D26

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D27

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ATTACHMENT D – DRAWING LIST

HWMU‐32B‐95MHIDrawingList

Title  Drawing# Multiple Hearth Incinerator Instrument Controls 

E095XX-770-003

Secondary Combustion Chamber Instrument Controls 

E095XX-770-004

Quench/Condenser Instrumentation  E095XX-770-005

Venturi/Separator/WESP Instrumentation  E095XX-770-006

Stack & Plume Instrumentation  E095XX-770-007

Hearth Burner Controls  E095XX-770-008

SCC General Arrangement  V095XX-312-017, sheet #11

Process Flow Diagram  E095XX-310-025

I.D. Fan/Duct/Stack Fabrication Details  E095XX-319-014

Plan Arrangement of Incinerator Off Gas Condensing Scrubbing System 

V095XX-312-018, sheet #3

Elevation Arrangement of Incinerator Off Gas Condensing Scrubbing System  

V095XX-312-018, sheet #4

WESP Process and Instrumentation Details  V095XX-312-018, sheet #19

Induced Draft Fan  V095XX-312-019, sheet #2

General system Overview  095XX-776-000, sheet 2

General system Overview  095XX-776-000, sheet 3

Rabble Teeth Assembly for MHI  D095NA-313-003

(DRAWINGS IN ATTACHMENT J)  

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Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013

ATTACHMENT D

MULTIPLE HEARTH INCINERATOR - HWMU-32

TRIAL BURN/COMPREHENSIVE PERFORMANCE TEST

RED ROCHESTER, LLC EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

These are separate submissions and are incorporated by reference:

Refer to the Test Reports for HWMU-32

Trial Burn Test Report dated March 2002

Miniburn #7 Test Report dated November 2002

Comprehensive Performance Test Report dated October 2008

and

Comprehensive Performance Test Report dated September 2013

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ATTACHMENT D-2

PROCESS INFORMATION

TANKS - HWMU-33

EASTMAN KODAK COMPANY

EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY

EPA ID NUMBER NYD 980592497

December 13, 2013

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TABLE OF CONTENTS

ATTACHMENT D-2

TANKS

D-2 HWMU-33 TANK STORAGE 2

D-2b DESIGN OF NEW TANK SYSTEM 2

D-2b(1) GENERAL INFORMATION 2

D-2b(2) TANK DESIGN SPECIFICATIONS 3 D-2b(3) ANCILLARY EQUIPMENT DESIGN

SPECIFICATIONS

4

D-2b(4) OVERFILL PROTECTION 4 D-2b(5) FOUNDATIONS AND ANCHORING 6 D-2b(6) CORROSION PROTECTION 6 D-2b(7) TANK SYSTEM INTEGRITY INSPECTIONS 7 D-2c INSTALLATION OF NEW TANK SYSTEM 7 D-2c(1) STORAGE TANKS 7

D-2c(2) ANCILLARY EQUIPMENT 7

D-2d SECONDARY CONTAINMENT FOR TANK

SYSTEM

7

D-2e GENERAL TANK OPERATING REQUIREMENTS 8

D-2e(1) OPERATION OF FLOW CONTROL SYSTEM 8

D-2e(2) LOADING AND UNLOADING PRACTICES 8

D-2f REQUIREMENTS FOR IGNITABLE AND

REACTIVE WASTES

8

D-2g REQUIREMENTS FOR INCOMPATIBLE WASTES 9

D-2h TANK INSPECTIONS 10

D-2h(1) DAILY INSPECTIONS 10

D-2h(2) TANK INTEGRITY ASSESSMENT SCHEDULE 10

D-2i TANKS SPILLS AND LEAKAGE 11

D-2j CLOSURE AND POST CLOSURE 12

D-2k Air Emission Standards 12

APPENDICES

DRAWING LIST

D2-2

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D-2 TANKS

D-2 HWMU-33 TANK STORAGE

D-2b DESIGN OF NEW TANK SYSTEM

D-2b(1) GENERAL INFORMATION

Hazardous Waste Management Unit 33 (HWMU-33) consists of two horizontal underground

storage tanks located in two separate tank farm areas at the Building 322 distillation complex. .

One 30,000 gallon tank is located in the tank farm near the southeast corner of Building 322.

One 35,000 gallon tank is located in a tank farm south of Building 322. These tanks were

installed as part of Kodak’s Storage Tank Improvement Program with oversight from the New

York State Department of Environmental Conservation (NYSDEC). The tanks are used for the

storage of waste solvents prior to reclamation. These solvents come from on-site manufacturing

operations as well as off-site hazardous waste generators. The U.S. Environmental Protection

Agency (U.S. EPA) waste codes, identifying these wastes, are listed in Module IV of this

permit.

The 30,000 gallon horizontal tank, Tank EPV-163 (Division I.D. No. T-682) is buried in washed

stone. The location of the tank is shown on Drawing E322-201-001. Tank 682 is secured to a

concrete hold down slab designed to drain to avoid standing water on the tank exterior for

extended periods of time.

The 35,000 gallon horizontal tank, Tank EPV-160 (Division I.D. No. T-675), is also buried in

washed stone. The location of the tank is shown on Drawing E322-201-001. Tank 675 is also

secured to a concrete hold down slab designed to drain to avoid standing water on the tank

exterior for extended periods of time.

Tank integrity assessments were prepared and certified by an independent, qualified, registered,

professional engineer in January, 2009 in accordance with New York Codes, Rules, and

Regulations (6NYCRR) Part 373-2.10(b). A copy of the integrity assessment certifications for

the tanks is included in Appendix.D-2-1.

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Tank System Service

Process flow/piping and instrumentation diagrams for T-682 and T-675 are shown on the

drawings listed below:

Drawing No. Title

D322TF-700-682 Tank 682 Syn. Chem. Crude HW P&ID

D322TF-700-675 Tank 675 Crude EA HW P&ID

These tanks are used for the storage of on-site and off-site waste solvents prior to recovery.

D-2b(2) TANK DESIGN SPECIFICATIONS

T-682 is a double walled horizontal underground storage tank consisting of a stainless steel

internal wall and a fiberglass coated carbon steel external shell. This tank was installed in 1995

as part of STIP and the design and installation was consistent with the programs requirements.

Construction of the tank was in accordance with American Society of Mechanical Engineers

(ASME) Code Section VIII, Division 1, 1992 and the 1992 Addendum. The physical

characteristics of the tank are given in Appendix.D-2-2. Engineering details for the tank are

shown on the drawing listed below:

Drawing No. Title

V322TF-627-003 30,000 Gallon Underground Storage Tank

T-675 is a double walled horizontal underground storage tank consisting of a stainless steel

internal wall and a fiberglass coated carbon steel external shell. This tank was installed in 1996

as part of STIP. Construction of the tank was in accordance with ASME Code Section VIII,

Division 1, 1995. The physical characteristics of the storage tanks are given in Appendix D-2-2.

Engineering details for the tank are shown on the drawing listed below:

Drawing No. Title

V322TF-627-013 35,000 Gallon Underground Storage Tank

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D-2b(3) ANCILLARY EQUIPMENT DESIGN SPECIFICATIONS

Piping System

The piping system associated with the tanks is constructed of Type 304 stainless steel and Monel

alloy. Pipe connections are lap joint flanges with a standard serrated surface finish. All of the

piping is located above grade and is accessible. Any threaded connections associated with the

tank system are located over secondary containment structures.

Valves

The valves associated with T-682 and T-675 consist of 316 stainless and Monel alloy hand

valves, control valves, check valves and release valves. Valve placements are shown on the tank

P&IDs. All valves are located over secondary containment or are double sealed or sealess.

Pumps

The pumps associated with HWMU-33 tanks are Durco Mark III, Group II, stainless steel pumps

and stainless steel flow switches. The pump seals are a carbon, ceramic mechanical seal. Pump

placements are within the tank collar secondary containment.

D-2b(4) OVERFILL PROTECTION

Level Sensors

Two independent level monitoring devices provide overfill protection for the storage tanks.

Each tank has a high level independent switching device set at 93% of the tank capacity. At

93% of tank capacity the switching device will automatically close the tank fill valves. The tank

fill valves will also close upon loss of power or air supply. In addition, each tank is equipped

with a continuous level monitor which will alarm the control room of a high level event (96% of

tank capacity). These independent level sensors have been selected to be a fail safe design with

system diagnostics to detect problems.

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The catch tank, servicing the tank collars, is equipped with a level monitoring system providing

data directly to the control room. A continuous level sensor will alarm the control room when

the catch tank is filled to a level of twenty five inches. In addition, the inlet and outlet piping to

the catch tank are equipped with vapor sensors. The vapor sensors will alarm the control room

in response to a release.

Pressure Controls

Each of the tanks is protected against over-pressurization by a rupture disc set at 13 PSIG and a

vacuum relief valve set at 0.25 PSIG vacuum.

The catch tank vents to the atmosphere through a conservation vent set at eight inches of water.

Vapor Control System

Both of the tanks are equipped with a vapor recovery system that vents tank vapors to a

scrubbing control device. The tanks are blanketed with nitrogen at a pressure 10 PSIG. When

the tank pressure reaches 2.9 PSIG, tank vapors vent through the vapor recovery system to the

B322 pollution control device. The control valve to the vapor recovery system closes once the

tank pressure drops to 2.9 PSIG. If the tank pressure drops to 2.2 PSIG, the nitrogen purge

system opens and remains open until the tank pressure reaches 2.2 PSIG.

The B322 air pollution control equipment includes a refrigerated vent condenser, a 2-stage

methanol scrubber and a water scrubber that provide greater than 95% control for the Hazardous

Air Pollutants (HAPS) and Volatile Organic Compounds (VOCs) that are vented from the B-322

process equipment and storage tanks. Performance testing on the emission control system

demonstrated compliance with MON MACT requirements. Permit conditions which include

operating parameters and limits for the emission control system are included in Kodak’s Title V

Air Permit. RCRA air emission requirements are met by conforming to the permit conditions

and complying with the MON MACT requirements.

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D-2b(5) FOUNDATIONS AND ANCHORING

T-682 and T-675 are underground storage tanks that are anchored to concrete holdown pads.

The tanks are approximately fifteen feet below grade at the bottom of the tank. The tank systems

were conservatively designed to withstand full hydrostatic pressure based on the assumption

that the ground water level will be at grade level with an empty tank. Typical details of the tank

anchoring are included on Drawing E322TF-201-003 - Tank Foundations and Hold Downs.

D-2b(6) CORROSION PROTECTION

Characteristics of the waste to be stored in the HWMU-33 tanks are provided in Module IV and

Attachment C of the permit. Tank 682 and 675 were installed in 1995 and 1996 respectively and

are constructed with inner shells of Type 316L stainless steel. The stainless steel is considered a

good material selection for the mixed solvent waste and the tanks have stored this type of

material since installation. To ensure corrosion problems are not encountered , an internal

inspection of the tanks is done on a periodic basis. The most recent inspection records for the

tanks are included in Appendix D-2-3. No significant corrosion problems have been observed

for the tanks and the structural properties of the tanks have retained their original capabilities.

Other parts of the system (i.e. valves, pumps, and piping) are constructed of Type 304 stainless

steel and Monel alloy. High fluid velocity through ancillary equipment maintains the corrosion

resistance of stainless steel by removing debris and deposits. Other parts of the system include

Teflon and elastomeric compounds for gaskets, o-rings, etc. Some of the elastomers are

considered marginally resistant to some of the fluids handled but are selected to provide the best

combination of desirable characteristics. Failure due to incompatibility is avoided through

regular preventive maintenance and daily inspections.

These tanks are buried in washed crushed stone. The exterior of each tank is coated with a

fiberglass mastic coating as indicated in Appendix D-2-4 which provides a measure of corrosion

protection to the exterior of the shell.

The burial of tanks in washed gravel or crushed stone has been an approved and common

practice at Eastman Business Park. The specification for the fill material is included in

Appendix D-2-5. This design negates the need for cathodic protection; "soil" conditions are

typically dry, neutral pH, and very high resistivity with low levels of chloride.

A corrosion certification in accordance with 6 NYCRR Part 373-2.10(c)(6) is included as

Appendix D-2-6.

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D-2b(7) TANK SYSTEM INTEGRITY INSPECTIONS

Visual inspections and ultrasonic wall thickness tests were performed on T-682 and T-675 in

July, 2013 and July, 2005, respectively. The testing indicated that the tanks were in favorable

condition. Internal inspections are performed at the discretion of the Materials Engineering

Laboratory, based on the expected life of the tank and any changes in service. Currently, T- 682

has been placed on a three year cycle for internal inspections. T-675 has been placed on a ten

year cycle. Copies of the most recent internal inspections are included in Appendix D-2-3.

D-2c INSTALLATION OF NEW TANK SYSTEM

A quality assurance program was conducted in conjunction with the installation of the HWMU-

33 tank system. Qualified inspectors audited each phase of the vault and tank system

installations.

D-2d SECONDARY CONTAINMENT FOR TANK SYSTEMS

The two HWMU-33 storage tanks are double walled in construction. Top mounted equipment

(pumps, mixers, piping, valves etc.) are contained in the tank collars. The tank collars drain to a

36,000 gallon catch tank which may be pumped back into the storage tanks or to the industrial

sewer. Each tank has been designed as an integral structure such that a release from the inner

tank will be totally contained by the outer shell. The interstitial space of each tank is

continuously monitored for the presence of vapors. Sensors monitoring the interstitial space on

each tank will warn of wastes leaking into the interstitial space. Upon detection of a leak, an

alarm is immediately given to the control room. The integrity of the double walled tank can also

be checked using a pressure transmitter and air pressurization of the interstitial space.

The vapor sensors used in the interstitial space of the tanks, and the conveyance piping to the

catch tank, are total hydrocarbon vapor analyzers, model number Tankguard VIII manufactured

by Mine Safety Appliance Company (MSA).

Visual inspections of the tank systems are performed daily for signs of leakage as described in

Attachment F.

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D-2e GENERAL TANK OPERATING REQUIREMENTS

D-2e(1) OPERATION OF FLOW CONTROL SYSTEM

Hazardous waste tanks are rated for Class I Hazards and are clearly labeled "Hazardous Waste".

The fluid levels in the tanks are continuously monitored with readouts available at the control

room in Building 322. When the fluid level in a tank reaches 90 percent of capacity, audible and

visible alarms are activated in the control room and the valves are automatically closed,

preventing further addition to the tanks.

Two methods are available for the detection of spills or leaks in any of the HWMU-33 storage

tanks: (1) the control room operator monitors the level readout of each tank, and (2) the

inventory sheets are monitored for each tank. Inventories for the tanks are taken once each

operating shift and are recorded on log sheets.

D-2e(2) LOADING/UNLOADING PRACTICES

Typically, off-site liquid hazardous wastes arrive at Building 322 in tank trailers. Transfer

operations occur at the trailer unloading station which consists of a curbed concrete pad that

drains to a 36,000 gallon catch tank. When a tank trailer enters the trailer unloading station the

wheels are blocked to prevent movement during unloading. A flexible transfer hose is connected

to the trailer for unloading. The hose is inspected for damage before being connected to the

trailer and is inspected for leaks once the transfer ahs begun. Operator oversight is provided

throughout the trailer unloading process.

D-2f REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE

Reactive wastes are not stored in the HWMU-33 tanks. All tanks have the potential to store

ignitable wastes; therefore, wastes are handled to minimize conditions that may cause the wastes

to ignite. Standard practices to ensure that ignition sources are not present in flammable vapor

areas include a Kodak policy that prohibits smoking and a permitting system for open flames and

other sources of ignition. Ignition sources are allowed in flammable vapor areas only when a

Temporary Open Flame Permit has been issued after a review of existing conditions and the

appropriate precautions have been taken in order to prevent ignition of flammable vapors.

Electrical controls within the vicinity of the tanks are either of explosion-proof design or are

wired to be intrinsically safe. Signs are posted in areas where flammable wastes are stored.

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Only authorized personnel are allowed and employees' protective equipment and clothing are

checked to verify safe operation in these areas. Pipes and pumps in the area are grounded, as are

containers and tank trailers in the unloading stations.

D-2g REQUIREMENTS FOR INCOMPATIBLE WASTES

Compatibility is based on solvent type and characteristics of the wastes. Decisions as to the

compatibility and joint storage of the wastes are based on an evaluation of the solubility and

potential reactivity of the mixture. Compatibility is determined through a review of the

individual processes generating the waste. Where the compatibility of a waste with other wastes

is unknown, it will be determined based on the judgment of a chemist, engineer, or other person

trained, experienced, and designated to make such a determination based upon the known

characteristics of the waste involved. In addition, bench scale and analytical testing may be

conducted to verify the compatibility of material prior to acceptance.

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D-2h TANK INSPECTION

D-2h(1) DAILY INSPECTIONS

An inspection schedule for HWMU-33 is included in Attachment F, Table F-1. The inspection

schedule covers inspection of monitoring equipment, safety and emergency equipment, security

devices, operating equipment, and structural equipment that are important in preventing,

detecting, or responding to environmental and/or human health hazards due to releases. The

schedule identifies the item to be inspected, the types of problems to be addressed during the

inspection, and the minimum frequency of inspection.

The tank system, including valves, pipes, fittings, and other ancillary equipment, is inspected

daily. Results of these inspections are maintained in the HWMU's operating record and are

accessible to operating and inspection personnel. The inspection log includes the date and time

of inspection, the name of the inspector, a notation of the observations made (for each item listed

in the inspection schedule), and the date and nature of any repairs or other remedial measures.

Samples of the inspection logs are presented in Attachment F, Appendix F-1.

D-2h(2) TANK INTEGRITY ASSESSMENT SCHEDULE

Visual inspections and ultrasonic wall thickness tests were performed on T- 682 and T-675 in

July, 2013 and July, 2005, respectively. Internal inspections are performed at the discretion of

the Materials Engineering Laboratory, based on the expected life of the tank and any changes in

service. Currently, T-682 has been placed on a three year cycle for internal inspections. T- 675

has been placed on a ten year cycle. Copies of the most recent internal inspections are included

in Appendix D-2-3.

Leak observation tests and external inspections are performed on the ancillary equipment

annually. Any deterioration or malfunction of equipment or structures revealed as a result of any

inspection is remedied on a schedule to ensure the problem will not lead to an environmental

and/or human health hazard. Where a hazard is imminent or has already occurred, remedial

action will be taken immediately.

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D-2i TANK SPILLS AND LEAKAGE

The Rochester Imaging Chemical Flow maintains a written copy of the Contingency Plan,

Attachment G on file at Eastman Business Park. Employees are trained in its purpose, scope and

application. Periodic review of this plan ensures that established procedures and controls are

operational and current. Hazardous waste regulations [6 NYCRR 373-2.10(g)] require specific

actions in the event of a leak or spill from hazardous waste tank systems. These requirements as

outlined below, apply to both tank and secondary containment systems.

1. When a leak or spill from a tank is discovered, operating personnel will

immediately stop the flow of hazardous waste into the tank and inspect the system

to determine the cause of the release.

2. Hazardous waste will be removed from the tank system as is necessary to prevent

further release and to allow inspection and repair to commence.

3. Hazardous waste will be removed from the secondary containment system within

24 hours of discovering the release or in as timely a manner as is possible to

prevent harm to human health and the environment. (Revised June, 2009)

4. Where visible releases of hazardous waste to the environment are observed, these

releases will be controlled to prevent further migration of the wastes.

5. Any release to the environment from a hazardous tank system will be reported to

the New York State Department of Environmental Conservation (NYSDEC)

Commissioner within 24 hours of its occurrence, unless it is less than or equal to

one pound and it is immediately (within 2 hours) contained and cleaned up.

6. Within 30 days of detection of the release, a report will be submitted to the

Commissioner, containing the following information:

The likely route of migration of the release.

The characteristics of the surrounding soil.

The results of any sampling or monitoring conducted in connection with

the release.

Proximity of the release to downgradient drinking water, surface water,

and populated areas.

A description of response actions taken or planned.

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7. Following a release from a tank system, these provisions will be satisfied, or the

tank will be closed:

If the cause of the release has not damaged the integrity of the system, the

system may be repaired and returned to operation.

If the release was caused by a leak from a primary system into a secondary

system, then the primary system will be repaired prior to being returned to

service.

8. In the event that major repairs are made, such as repair of a ruptured primary or

secondary containment vessel, or installation of an internal liner, then the repairs

will be certified before returning the tank system to service. A qualified,

professional engineer registered in the State of New York will certify that the

repaired system is capable of handling hazardous waste without release for the

intended life of the system. The certification will be submitted to the NYSDEC

Commissioner within 7 days of returning the tank to service.

D-2j CLOSURE AND POST-CLOSURE

Closure and post-closure plans for the Kodak hazardous waste facility are included in

Attachment I of the Kodak Part 373 Permit.

D-2k AIR EMISSION STANDARDS

6NYCRR 373-2.27 Air Emission Standards for Process Vents

All distillation processes are recycling units exempt from RCRA permitting. However, all vents

from these distillation processes are connected to air emission control systems. There are three

separate control systems. The B-322 control system is described in Section D-2b(4). The other

two are the B-120 and the B-142 control systems. Both of these systems have 2-stage methanol

scrubbers followed by a water scrubber. All of the distillation process vents connected to these

three systems comply with the process vent standards of 373-2.27 as provided in 373-2.27a(3)

by complying with the Miscellaneous Organic Chemical Manufacturing NESHAP (Subpart

FFFF – 63.2455 and 63.2460) process vent requirements. Specific conditions for complying

with these requirements are contained in Kodak’s Title V air permit for EBP.

6NYCRR 373-2.28 Air Emission Standards for Equipment Leaks

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All distilling process equipment in hazardous waste service is subject to the leak detection and

repair requirements (LDAR) of 373-2.28. Components (e.g. valves, pumps) are identified,

monitored and repaired as required.

6NYCRR 373-2.29 Air Emission Standards for Tanks, Surface Impoundments and Containers

For the distilling operations at EBP, applicability of 373-2.29 is limited to the two permitted

hazardous waste storage tanks (HWMU-33). The vents for both of these tanks are connected to

the B-322 emission control system that complies with the MON MACT. Specific conditions for

complying with these requirements are contained in Kodak’s Title V air permit for EBP.

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Appendix D-2-1 Independent Professional Engineering

Certification

D2-15

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Appendix D-2-2 Tank Characteristics

D2-17

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Appendix D-2-3 Tanks Inspections

D2-20

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D2-21

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D2-22

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D2-23

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D2-24

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D2-25

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D2-26

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D2-27

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Appendix D-2-4 Engineering Specification FRP Cladding

Metal Tanks

D2-29

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D2-30

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Appendix D-2-5 Engineering Specification Backfill

D2-32

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D2-33

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D2-34

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D2-35

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D2-36

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Appendix D-2-6 Corrosion Certification

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February 12, 2009 Mr. Bryan Gallagher Eastman Kodak Company 1669 Lake Road Rochester, NY 14652 Re: Building 322 Storage Tanks File: 1447/43982 VIA EMAIL: [email protected] Dear Mr. Gallagher: Consistent with O’Brien & Gere’s proposal dated January 16, 2009 please find the accompanying Corrosion Certification performed for the following tanks located outside of Building 322 at the Eastman Business Park: Tank # 682 – 30,000 gallon Tank # 675 – 35,000 gallon Please note that the accompanying certification has been prepared consistent with the requirements outlined within 6 New York Code of Rules and Regulations (NYCRR) Part 373-2.10. If you have any questions regarding this submittal please do not hesitate to contact the undersigned at 585-263-2820 or Mr. Albert Lyons, Jr., P.E. at 716-827-0700. Very truly yours, O’BRIEN & GERE ENGINEERS, INC.

Jamie D. Newtown Managing Scientist

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GREAT LAKES ENVIRONMENTAL & SAFETY CONSULTANTS, INC.

GATEWAY EXECUTIVE PARK 3556 LAKESHORE ROAD BUFFALO, NY 14219 PHONE: (716) 827-0700 FAX: (716) 824-4734

WWW.GREATLAKESENVIRONMENTAL.COM

February 11, 2009

Mr. Jamie Newtown O’Brien & Gere 400 Andrews Street Suite 400 Rochester, NY 14604

RE: Kodak Building 322 Storage Tanks; Corrosion Certification Mr. Newtown: Per your request, Great Lakes Environmental & Safety Consultants, Inc. (Great Lakes) has reviewed the applicable portions of the proposed hazardous waste tank design and installation procedures as presented in the attached information. The tank systems are located belowground at Building 322 and are owned and operated by Eastman Kodak Company in Rochester, New York. The tanks are known as Tank #682 (30,000 gallon) and Tank #675 (35,000 gallon) and were installed in 1995 under the Kodak Park Storage Tank Improvement Program (STIP). Based on information provided, the double wall tanks are constructed of 316L stainless steel and are externally coated with a fiberglass reinforced plastic cladding. Based on my review of the information provided in accordance with 6 NYCRR Part 373-2.10(c)(6), the tank systems are designed and installed in a manner that provides appropriate external corrosion protection. I further certify under penalty of law that I have personally examined and am familiar with the information submitted on corrosion protection requirements and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true accurate and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fine and imprisonment.

If you have any questions or require further information, please do not hesitate to contact me at (716) 827-0700. Sincerely,

Albert G. Lyons, Jr., P.E. Vice President

D2-41

Page 73: Attachments D- F (PDF)

  

 

 

 

ATTACHMENT D2 – DRAWING LIST

HWMU‐33TanksDrawingList

Title  Drawing# 

Tank Foundations & Hold Down Plan  E322TF-201-001G

Tank Foundations & Hold Down Details ‐ South Area 

E322TF-201-003C

Tank 674 Double Wall Tank General Assembly 

V322TF-627-003

Tank 674 Double Wall Tank General Assembly 

V322TF-627-013

Tank 675 Instrumentation and Flow  E322TF-700-675D

TK‐682 Instrumentation and Flow  D322TF-700-682B

(DRAWINGS IN ATTACHMENT J)  

D2-42

Page 74: Attachments D- F (PDF)

June 2014

ATTACHMENT E

CORRECTIVE ACTION REQUIREMENTS

EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY

EPA ID NO. NYD980592497

Master List of SWMUs at Eastman Business Park

E-1

Page 75: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 1 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

E-001 EIA-IS IS

Industrial Sewer components of the Waste

Water Treatment Unit located in KPE B-000 KPE Park Section ACTIVE Open1

E-004 UNGROUPED CS90-Day Container Storage

Area B-006Platform K, North Side, near

column 105. INACTIVE Closed

E-005 UNGROUPED MA Marshaling Area B-006

Platform K, North Side (Loading Dock), near column

98 INACTIVE Closed

E-006 UNGROUPED PMRSilver Recovery Equipment

/ Processes B-006Basement, Near Rm 26, Inside on Concrete Floor. INACTIVE Closed

E-007 UNGROUPED MA Marshaling Area B-007Southeast Corner on Covered

Loading Dock INACTIVE ClosedE-009 UNGROUPED MA Marshaling Area B-009 Northwest Door J INACTIVE ClosedE-010 UNGROUPED MA Marshaling Area B-011 Northeast Corner INACTIVE Closed

E-011 UNGROUPED MA Marshaling Area B-012South Side, Loading Dock

Room B117TENANT

CONTROL Closed

E-013 UNGROUPED MA Marshaling Area B-014 West Wall, Outside on Asphalt INACTIVE Closed

E-016 UNGROUPED MA Marshaling Area B-020B-20 North Interior, on Asphalt

Floor near RR tracks INACTIVE ClosedE-017 UNGROUPED MA Marshaling Area B-021 B-21 North Interior INACTIVE Closed

E-018 UNGROUPED MA Marshaling Area B-023B-23 North Side, Inside Bldg.,

Door I INACTIVE ClosedE-019 UNGROUPED MA Marshaling Area B-025 B-25 East Side INACTIVE ClosedE-020 EIA-27 MA Marshaling Area B-027 West Side, Door L INACTIVE Closed

E-021 EIA-27 TT Trap Tank ID TT0271IS B-027 Under #46 Unit ACTIVE Closed1

E-022 EIA-27 TT Trap Tank ID TT0274IS B-027 West of Salvage Water Tank ACTIVE Closed1

E-023 EIA-27 TT Trap Tank ID TT0272IS B-027 Under #47 Machine ACTIVE Closed1

E-024 EIA-27 TT Trap Tank ID TT0273IS B-027Under #31 Machine, Salvage

Water Tank ACTIVE Closed1

E-025 EIA-27 TT Trap Tank ID TT0275IS B-027 Under #33 Unit ACTIVE Closed1

E-026 EIA-27 TT Trap Tank ID TT0276IS B-027 Under #23 Machine ACTIVE Closed1

E-027 EIA-27 TT Trap Tank ID TT0278IS B-027 Under #34 Unit ACTIVE Closed1

E-028 EIA-27 TT Trap Tank ID TT0277IS B-027 Under #24 Machine ACTIVE Closed1

E-029 UNGROUPED MA Marshaling Area B-029 B-29 South INACTIVE ClosedE-030 UNGROUPED PMR Silver Recovery Rich Pit B-029 B-29-10 East INACTIVE Closed

E-031 UNGROUPED PMR Silver Recovery Rich Pit B-029 B-29-10 West ACTIVE Closed1

E-032 UNGROUPED PMRSilver Recovery Tank

System B-029

B-29-13 Room North, Spill collection sump (Record

updated 7/15/1998 to incl. E-033 tank information) ACTIVE Closed1

E-034 UNGROUPED PMRSilver Recovery Tank

System B-029

B-29-14 Room (Basement level); 3,300 Gal Sec.

Containment ACTIVE Closed1

E-035 EIA-30 MA Marshaling Area B-030 Door LL, Northeast, Inside INACTIVE Closed

E-036 EIA-30 PMR Silver Recovery Rich Pit B-030 B-30-A ACTIVE Closed1

E-037 EIA-30 PMR Silver Recovery Rich Pit B-030 B-30-C ACTIVE Closed1

E-038 EIA-30 TS HWMU-01 Transfer Station B-030 Northwest Corner INACTIVE Closed

E-039 EIA-30 TAS HWMU-01 Closed Tank B-030Basement, Below Floor Slab;

B-30-C INACTIVE Closed

E-040 EIA-30 TAS HWMU-01 Storage Tank B-030 Vault, Northeast Corner ACTIVE Closed1

E-041 UNGROUPED MA Marshaling Area B-031B-31 West Wall, Outside, on

asphalt INACTIVE Closed

E-042 UNGROUPED MA Marshaling Area B-033B-33 Southwest Wall, Inside,

Loading Dock INACTIVE ClosedE-043 EIA-53 PMR Silver Recovery B-046 B-46, Basement INACTIVE Closed

E-044 UNGROUPED PMR Silver Recovery Rich Pit B-033B-33 South Inside Bldg.,

Basement, on concrete floor INACTIVE ClosedE-045 UNGROUPED MA Marshaling Area B-034 West Side Loading Dock INACTIVE Closed

E-046 UNGROUPED MA Marshaling Area B-035B-35 East Center, west of

door K INACTIVE Closed

E-047 UNGROUPED PMR

Silver Recovery, concrete secondary containment

system B-035B-35, West side of building,

south of door DD ACTIVE Closed1

E-048 UNGROUPED PMR Silver Recovery B-035B-35, West side of building,

east of door DD INACTIVE Closed

E-049 UNGROUPED PMR Silver Recovery B-035B-35, West side of building,

east of door F ACTIVE Closed1

E-050 UNGROUPED MA Marshaling Area B-042Loading Dock, North East

Corner of B-42 INACTIVE Closed

E-2

Page 76: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 2 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

E-051 UNGROUPED PMR Silver Recovery B-036 B-36, Northwest INACTIVE Closed

E-052 UNGROUPED MA Marshaling Area B-038B-38 Northeast Corner, 1st

floor INACTIVE Closed

E-053 UNGROUPED PMR Silver Recovery B-038B-38 Above basement

southwest corner INACTIVE Closed

E-054 UNGROUPED PMR Silver Recovery B-038B-38-RW Center, SW

Basement ACTIVE Closed1

E-055 EIA-27 MA Marshaling Area B-043 North Side, Inside Bldg. INACTIVE ClosedE-056a EIA-27 S Waste Trenches B-043 Northwest of B-43, Inside INACTIVE ClosedE-056b EIA-27 S Waste Trenches B-043 B-43 Southeast, Inside INACTIVE Closed

E-057 EIA-27 MA Marshaling Area B-045

B-45 West Center, inside building, loading dock at Door

M, SW quadrant INACTIVE Closed

E-058 EIA-27 CS Waste Accumulation Area B-046 B-46 South INACTIVE ClosedE-059 EIA-27 MA Marshaling Area B-046 B-46 North Side, Inside INACTIVE Closed

E-061 EIA-53 MA Marshaling Area B-048 B-48 Northwest, Loading Dock NEW OWNER ClosedE-062 UNGROUPED MA Marshaling Area B-049 B-49 South INACTIVE ClosedE-063 UNGROUPED PMR Silver Recovery B-049 B-49 1st Flr., column 55 INACTIVE ClosedE-064 UNGROUPED CS Marshaling Area B-050 B-50 North Platform INACTIVE ClosedE-066 EIA-53 PMR Silver Recovery B-052 B-52, West Corner INACTIVE ClosedE-067 EIA-53 MA Marshaling Area B-053 B-53 South Center INACTIVE Closed

E-068 EIA-53 CS90-Day Container Storage

Area B-054 B-54 East Side INACTIVE ClosedE-069 EIA-53 TT Trap Tank ID TT0100IS B-054 B-54 Northeast Corner INACTIVE ClosedE-070 UNGROUPED MA Marshaling Area B-056 B-56 South Center INACTIVE Closed

E-071a EIA-53 MA Marshaling Area B-057Northeast Corner of B-57,

Door M INACTIVE ClosedE-071b EIA-53 MA Marshaling Area B-057 B-57 Center West INACTIVE ClosedE-071c EIA-53 MA Marshaling Area B-057 South Loading Dock Door F INACTIVE ClosedE-072 EIA-53 PMR Silver Recovery B-057 B-57 Northeast Side INACTIVE Closed

E-073 EIA-53 PMR Silver Recovery B-057West Side (Southern half of

Bldg.) INACTIVE ClosedE-074 EIA-53 PMR Silver Recovery B-057 B-57 North Center INACTIVE ClosedE-075 UNGROUPED MA Marshaling Area B-058 B-58 North Side INACTIVE Closed

E-076 UNGROUPED CS90-Day Container Storage

Area B-059 B-59 West Side INACTIVE Closed

E-077 UNGROUPED MA Marshaling Area B-059B-59 North Side, inside,

loading dock door G ACTIVE Closed1

E-078 UNGROUPED PMR Silver Recovery B-059 Sub-Basement ACTIVE Closed1

E-079 UNGROUPED MA Marshaling Area B-060 B-60 Northwest, Door H INACTIVE Closed

E-084 UNGROUPED PMR Silver Recovery B-069B-69 East Side, Basement,

rm0302 INACTIVE ClosedE-086 UNGROUPED PMR Silver Recovery B-067 B-67 West, Inside INACTIVE Closed

E-088 UNGROUPED CS90-Day Container Storage

Area B-082 B-82D Chemical Stockroom ACTIVE Closed1

E-089 EIA-82 CSHWMU-24 Inactive Lugger

Pad B-082B-82B, Courtyard, south of

loading dock INACTIVE Closed

E-090 UNGROUPED MA Marshaling Area B-082 B-82B South of Loading Dock INACTIVE Closed

E-091 EIA-82 TS HWMU-24 Transfer Station B-082Transfer Pad adjacent to B-82

Tank Farm ACTIVE Closed1

E-093 EIA-82 TT Trap Tank ID TT0200IS B-082B-82 Courtyard tank farm, SW

of B-82A INACTIVE ClosedE-094 EIA-82 UST HWMU-24 Storage Tank B-082 B-82 Tank Farm Vault INACTIVE Closed

E-096 EIA-KL SWaste Water Treament Unit Sump ID SP0091IS B-091

B-91 Floor Drains and B-91 Sanitary Sewage ACTIVE Closed1

E-097 EIA-KL SWaste Water Treament

Unit Sump ID SP00171IS B-093 B-93 Center, outside lab ACTIVE Closed1

E-098 EIA-KL SWaste Water Treament Unit Sump ID SP0099IS B-093 Northeast of B-93 (R-17) ACTIVE Closed1

E-099 EIA-KL SWaste Water Treament

Unit Sump ID SP0200ST B-094 South of B-94 ACTIVE Closed1

E-100 EIA-KL CS90-Day Container Storage

Area B-095B-95, 1st floor, Northeast, by

hearth ACTIVE Closed1

E-101 EIA-KL I

HWMU-32 Multiple Hearth Incinerator/Ash Handling

System B-095 King's Landing (B-95) ACTIVE Closed1

E-102 EIA-KL I Rotary Kiln Incinerator B-095 West of B-95 INACTIVE Closed

E-103 EIA-KL LFormer Landfill Open

Burning Site B-095Current King's Landing Site,

Shed R-(24,9) INACTIVE Closed

E-105 EIA-KL SWaste Water Treament Unit Sump ID SP0089IS B-095 Southeast of B-95, Inside ACTIVE Closed1

E-3

Page 77: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 3 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

E-106 EIA-KL SWaste Water Treament Unit Sump ID SP0097IS B-095 West of B-95 ACTIVE Closed1

E-107 EIA-KL WTSWastewater Treatment

Plant (associated releases) B-095 KLWPP ACTIVE Closed1

E-109 EIA-KL SWaste Water Treament Unit Sump ID SP0013IS B-099 West of B-99 INACTIVE Closed

E-110 EIA-KL S

Waste Water Treament Unit Sump ID SP0090IS,

Return sludge pits B-099 West of B-99 ACTIVE Closed1

E-111 EIA-KL S

Waste Water Treament Unit Sump ID SP0092IS,

Return sludge pits B-099 North of B-99 ACTIVE Closed1

E-112 EIA-KL S

Waste Water Treament Unit Sump ID SP0093IS,

Return sludge pits B-099 North of B-99 ACTIVE Closed1

E-113 UNGROUPED CS Container Storage Area B-060 B-60 Center INACTIVE ClosedE-116 EIA-KL CS Shaker Screens B-095 West of B-99 INACTIVE Closed

E-117 EIA-KL S

Waste Water Treament Unit lift station to aeration basin, Sump ID SP0098IS B-095 South of aeration basins ACTIVE Closed1

E-119 EIA-53 S Sump ID SP0250ST B-053 Northwest Side of B-53 ACTIVE Closed1

E-120 EIA-KL SMultiple Hearth Scrubber

Sump ID SP0096IS B-095 Basement, B-95 West ACTIVE Closed1

E-122 EIA-30 TTTrap Tank ID TT0030IS,

No. C-912 B-030Under cantilever, North,

Center INACTIVE ClosedE-125 UNGROUPED MA Marshaling Area B-069 B-69 South Side, Inside INACTIVE ClosedE-127 UNGROUPED MA Marshaling Area B-087 B-87 North Side INACTIVE Closed

E-128 WIA-KPW RSSeveral releases recorded along distilling pipelines. B-065 South of B-65 (Under Pass) SPILL Closed

E-129 EIA-82 UST Underground Storage Tank B-082 South Side of B-82, Courtyard INACTIVE Closed

E-130 UNGROUPED USTUnderground Storage Tank

C986 B-050 West Side of B-050 INACTIVE Closed

E-131 EIA-27 UST Underground Storage Tank B-045East Side B-045 (Between B-

045 and B-057) INACTIVE Closed

E-132 EIA-30 USTUnderground Storage

Tank. B-030 Basement, Northeast Corner INACTIVE Closed

E-133 EIA-KL RS Underground Storage Tank B-095 Southeast Corner INACTIVE ClosedE-134 EIA-53 RS Release Site B-053 West Side of B-053 SPILL Closed

E-135 EIA-30 RS Between B-30A and B-30C B-030 Between B-30a and B-30c SPILL Closed

E-136 EIA-27 RSTwo 15,000 gallon fuel

storage tanks. B-046 Foundation, Southeast Corner SPILL Closed

E-138 EIA-KL RS

King's Landing Wastewater Treatment Plant - Entire

Facility, including all ancillary equipment B-095

King's Landing Area, Shed (R-24) SPILL Closed

E-139 EIA-30 RS Courtyard north of B-30 B-030 Northwest SPILL ClosedE-140 UNGROUPED RS Release Site B-059 Between B-42 and B-59 SPILL ClosedE-142 EIA-53 RS Release Site B-018 Between B-18 and B-48 SPILL ClosedE-143 EIA-53 RS B-054 Tank Farm B-054 Tank Farm, West of B-54 SPILL ClosedE-144 EIA-27 RS Cooling tower B-027 B-27, Inside, Southwest SPILL Closed

E-147 EIA-KL RSKing's Landing Discharge

to River B-095King's Landing Discharge to

Genesee River ACTIVE Open1

E-148 UNGROUPED SASKPE Sanitary Sewer

System B-000 KPE Park Section ACTIVE Closed1

E-149 EIA-53 TASStorage Tank (Gelatin

Settling Basins) B-047 Area Surrounding B-47 INACTIVE ClosedE-150 UNGROUPED S Sump B-011 Southeast Corner, Inside INACTIVE Closed

E-151 EIA-KL SWaste Water Treament Unit Sump ID SP0088IS B-099 Northwest of B-99 ACTIVE Closed1

E-152 EIA-62 RSSuspected release, Vinyl

Chloride detected. B-062 Southwest of B-62 SPILL ClosedE-153 EIA-53 RS Release Site B-049 B-49 NE SPILL Closed

E-154 EIA-2 RSAssumed Release Site

Unit B-002Northwest of B-2, between B-2

and B-13 SPILL ClosedE-155 UNGROUPED MA Marshaling area B-038 Basement INACTIVE Closed

E-156 UNGROUPED RSLot 40, Petroleum Storage

Tank Release B-092Parking Lot 40, formerly

Spector Tire SPILL Open2

E-157 UNGROUPED MA Marshaling Area B-014 Northwest Corner of B-14TENANT

CONTROL Closed

E-4

Page 78: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 4 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

E-158 EIA-53 S Floor Sump B-046B-46 Basement, Northwest

Corner INACTIVE Closed

E-159 EIA-KL SWaste Water Treament Unit Sump ID SP0087IS B-091 North East Corner B-91, (R-6) ACTIVE Closed1

E-160 UNGROUPED CS90-Day Storage Area/Tube

Crusher B-023 First Floor, Room 109 INACTIVE Closed

E-161 UNGROUPED CS90-Day Storage Area/Tube

Crusher B-009 Inside Room 605 INACTIVE Closed

E-162 EIA-27 S Sewer Building Drainage B-043 Inside, below slab INACTIVE Closed

E-163 EIA-KL CS90-Day Exempt Storage

Area, RO containers B-091Along primary clarifier on

asphalt with diking ACTIVE Closed1

E-164 EIA-KL CS90-Day Storage Area, Totes and RO Boxes B-095

East of R-9. Outside on Asphalt. ACTIVE Closed1

E-165 EIA-27 MA Marshaling Area B-027Inside Building, on Concrete, Next to door GG, East side INACTIVE Closed

E-166 UNGROUPED CS90-Day Container Storage

Area B-059Inside Building, Room 690, 6th

Floor INACTIVE Closed

E-167 EIA-KL CS90-Day Container Storage

Area B-091 By MEMO Shop - Concrete ACTIVE Closed1

E-168 EIA-KL CS90-Day Container Storage

Area B-091Basement Lab - Tile covered

concrete INACTIVE Closed

E-170 EIA-KL CS90-Day Container Storage

Area B-095 Basement - Concrete ACTIVE Closed1

E-171 EIA-KL CS90-Day Container Storage

Area B-095Outside eductor room in

basement - Concrete INACTIVE Closed

E-172 EIA-KL CS90-Day Container Storage

Area B-095 Lab in Basement - Concrete ACTIVE Closed1

E-174 EIA-KL CS90-Day Container Storage

Area B-096 1st Floor ACTIVE Closed1

E-204 UNGROUPED RSRailroad unloading station, NE corner of the building B-049 Northeast corner SPILL Closed

E-210 UNGROUPED RS Release Site B-050 Northwest corner SPILL ClosedE-212 EIA-53 RS Release Site B-052 North SPILL ClosedE-214 EIA-53 RS Release Site B-053 North SPILL ClosedE-222 WIA-KPW RS Release Site B-069 East side SPILL Closed

E-226 EIA-53 RS Release Site B-053Trench located at former shed

E-44, NW of B-054 SPILL ClosedE-227 UNGROUPED R Release B-031 South side of building SPILL Closed

E-229 EIA-53 R Fuel oil unloading station B-024 North side of E-24 SPILL Closed

E-233 EIA-82 CS Container Storage Area B-082P-3 Solvent storage shed, SW corner of B-082A (no waste) INACTIVE Closed

E-234 UNGROUPED TT Sump B-087B-087 west of the locker room

area ACTIVE Closed1

E-235 EIA-KL CS90-Day Container Storage

Area B-095Inside B-095, 1st floor in lab -

Tile covered concrete ACTIVE Closed1

E-236 EIA-KL CS90-Day Container Storage

Area B-093 Inside Shed R-24 INACTIVE ClosedE-237 EIA-27 RS Release Site B-046 North side of B-046 SPILL Closed

E-238 EIA-KL S Sump B-095B-095, in basement near the

grit conveyor INACTIVE Closed

E-239 EIA-82 CS90-Day Container Storage

Area B-082

B-82, inside, west side of Room B004 (due north of B-

wing loading docks). INACTIVE Closed

E-240 EIA-82 CS90-Day Container Storage

Area B-082

B-82, inside, east side of Room B004 (due north of B-

wing loading docks). INACTIVE Closed

E-241 EIA-27 MA Marshaling Area B-027

Bldg. 27, inside and immediately east of door R on

concrete, north side of building. INACTIVE Closed

E-242 UNGROUPED MA Marshaling Area B-031

Bldg. 31, inside and slightly east of Door N on concrete,

north side of building. INACTIVE Closed

E-243 EIA-53 CS90-Day Container Storage

Area B-048Building 48, inside on the 5th

floor NEW OWNER Closed

E-244 UNGROUPED CS90-Day Container Storage

Area B-034

North of Building 6 (in the footprint of where B-34 used

to stand) INACTIVE Closed

E-5

Page 79: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 5 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

E-245 UNGROUPED RSIndustrial Sewer

Compromise B-006

Basement of Building 6, north of Room 26, within portions of Silver Recovery Area (SWMU

E-006) INACTIVE Closed

E-246 EIA-30 MA Marshaling Area B-030

B-30; inside; first floor, south of loading dock LL; located

between columns H2-H3 and G2-G3 ACTIVE Closed1

E-247 EIA-KL CS90-Day Container Storage

Area B-095 Basement, B-95 ACTIVE Closed1

E-248 EIA-30 CS90-Day Container Storage

Area B-030 Building 30, Room 812 INACTIVE Closed

E-249 UNGROUPED CS90-Day Container Storage

Area B-029South of B-29N, at former B-

58 footprint INACTIVE Closed

E-250 EIA-82 CS90-Day Container Storage

Area B-082

B-82, inside, Room A-17 (basement), A-Wing of the

KRL North Complex INACTIVE Closed

E-251 UNGROUPED CS90-Day Container Storage

Area B-020Inside B-20, northeast corner

of 2nd floor INACTIVE Closed

E-252 EIA-53 CS90-Day Container Storage

Area B-052inside northeast corner of B-

52 at loading dock INACTIVE Closed

E-253 UNGROUPED CSHazardous Solids and

Liquids B-019Inside Building 19 at Room

203/1 INACTIVE Closed

E-254 EIA-30 CS90-Day Container Storage

Area B-030 Building 30, Room 726 ACTIVE Closed1

E-255 WIA-KPW CS90-Day Container Storage

Area B-065Inside Building 65, Basement

Level at Door G INACTIVE Closed

E-256 UNGROUPED RS Release Site Area B-023North of the former B-23, near a former heat treatment area SPILL Closed

E-257 EIA-82 CS90-Day Container Storage

Area B-082 B-82, inside room D004 ACTIVE Closed1

E-258 EIA-53 MA Marshaling Area B-053 B-53 Loading Dock K ACTIVE Closed1

E-259 UNGROUPED WTS Water Treatment Filtration B-042 B-42 1st Floor ACTIVE Closed1

M-001 MIA-IS IS

Industrial Sewer components of the Waste

Water Treatment Unit located in KPM B-300 KPM Park Section ACTIVE Closed1

M-002 MIA-301 CS90-Day Container Storage

Area B-301 B-301 West, Bay 7 INACTIVE Closed

M-003 MIA-301 SB-301 Tunnel Scrubber

Sump B-301 Inside, NW Corner INACTIVE Closed

M-004 MIA-301 TSHWMU-09 Temporary

Transfer Station (3-Day) B-301 West of B-302 INACTIVE Closed

M-005 MIA-301 CS HWMU-09 Trailer Station B-302 East of Tank Farm ACTIVE Closed1

M-006 MIA-301 TT Trap Tank ID TT3300IS B-301 Outside, Bay 3, South Side INACTIVE ClosedM-007 MIA-301 TT Trap Tank ID TT3301IS B-301 Outside, Bay 5, South Side INACTIVE ClosedM-008 MIA-301 TT Trap Tank ID TT3302IS B-301 Outside, Bay 10, North Side INACTIVE ClosedM-009 MIA-301 TT Trap Tank ID TT3303IS B-301 Outside, Bay 12 INACTIVE Closed

M-010 MIA-301 TASHWMU-09 Closed Storage

Tanks (2 x 20,000 gal.) B-301 West of B-302 INACTIVE Closed

M-011 MIA-301 SB-302 Tunnel Scrubber

Sump B-302 Inside, Northwest Corner INACTIVE ClosedM-012 MIA-301 TT Trap Tank ID TT3321IS B-302 Outside, South, Bay 5 INACTIVE ClosedM-013 MIA-301 TT Trap Tank ID TT3323IS B-302 Outside, North, Bay 12 INACTIVE ClosedM-014 MIA-301 TT Trap Tank ID TT3325IS B-302 Outside North, Bay 10 INACTIVE ClosedM-015 MIA-301 TT Trap Tank ID TT4000IS B-302 East Side of Yard INACTIVE Closed

M-016 MIA-301 MA Marshaling Area B-303 East Side, Inside Headhouse ACTIVE Closed1

M-017 MIA-301 SB-303 Tunnel Scrubber

Sump B-303 Inside NW Corner ACTIVE Closed1

M-018 MIA-301 TT Trap Tank ID TT3350IS B-303 Outside South, Bay 4 INACTIVE Closed

M-019 MIA-301 TT Trap Tank ID TT3351IS B-303 Outside South, Bay 7 ACTIVE Closed1

M-020 MIA-301 TT Trap Tank ID TT4005IS B-303 North Side, Bay 16 INACTIVE Closed

M-021 MIA-301 TT Trap Tank ID TT4010IS B-303Side Sump (for labs), B-303

East INACTIVE Closed

M-022 MIA-301 TT Trap Tank ID TT4040IS B-303 Outside North, Bay 13 ACTIVE Closed1

M-023 MIA-301 TT Trap Tank ID TT3360IS B-304Outside South, Bay 2 and Bay

3 INACTIVE Closed

M-024 MIA-301 TT Trap Tank ID TT3361IS B-304Outside South, Bay 4, Bay 5,

and Bay 6 INACTIVE Closed

M-025 MIA-301 TT Trap Tank ID TT3362IS B-304Outside South, Bay 7 and Bay

8 INACTIVE Closed

E-6

Page 80: Attachments D- F (PDF)

Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 6 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

M-026 MIA-301 TT Trap Tank ID SP4010IS B-304Outside, North, Bay 9 Side

Sump ACTIVE Closed1

M-027 MIA-301 TT Trap Tank ID TT3364IS B-304Outside North, Bay 10, Side

Sump ACTIVE Closed1

M-028 MIA-301 TT Trap Tank ID TT3365IS B-304Outside North, Bay 11, Side

Sump ACTIVE Closed1

M-029 MIA-301 TT Trap Tank ID TT3366IS B-304Outside South, Bay 1

(Blender) ACTIVE Closed1

M-030 MIA-301 TT Trap Tank ID TT3363IS B-304Outside North, Bay 17

(Blender) ACTIVE Closed1

M-031 MIA-301 TT Trap Tank ID TT4005(2)IS B-304 Trap Tank, West ACTIVE Closed1

M-033 MIA-301 PMRAsh stored in pile on

concrete pad B-305 Near Railroad Tracks INACTIVE Closed

M-034 UNGROUPED MA Marshaling Area B-306B-306, Door J (East), on

Concrete Floor INACTIVE ClosedM-035 MIA-308 MA Marshaling Area B-307 B-307 North, Outside INACTIVE ClosedM-036 MIA-308 TT Trap Tank ID TT3307IS B-307 East of B-307 INACTIVE ClosedM-037 MIA-308 TT Trap Tank ID TT3309IS B-307 East of B-307 INACTIVE ClosedM-038 MIA-308 TT Trap Tank ID TT3310IS B-307 East of B-307 INACTIVE ClosedM-039 MIA-308 TT Trap Tank ID TT3301IS B-307 East of B-307 INACTIVE ClosedM-040 MIA-308 S Sump ID SP3316IS B-307 East of B-307 INACTIVE Closed

M-041 MIA-308 SISWMU-09 DPI Surface

Impoundment B-307 East of B-307 INACTIVE Closed

M-042 MIA-308 TTTrap Tank ID TT4020IS

(catch tank) B-308 Outside, North of B-307 ACTIVE Closed1

M-044 MIA-308 S Sump ID SP4045IS B-308 B-308 INACTIVE Closed

M-045 MIA-308 SI Surface Impoundments B-312North of B-312 and West of M-

56 INACTIVE Closed

M-046 MIA-308 TT Trap Tank ID TT4015IS B-308 B-308 ACTIVE Closed1

M-048 MIA-308 LSWMU-08 DPI Drum

Disposal Site B-312 Northwest of B-312 INACTIVE ClosedM-049 MIA-308 S Sump B-312 North of B-312 INACTIVE ClosedM-050 MIA-308 S Sump ID SP3313IS B-312 B-312 West Side INACTIVE ClosedM-051 MIA-308 S Sump ID SP3314IS B-312 West Side of B-312 INACTIVE ClosedM-052 MIA-308 S Sump ID SP3315IS B-312 West side of B-312 INACTIVE Closed

M-053 MIA-308 TT Trap Tank ID TT4060IS B-312 Shed at M-56, North of B-307 INACTIVE Closed

M-061 MIA-317 CSWaste Luggers &

Containers B-317 Southwest Corner of B-317 INACTIVE Closed

M-062a MIA-317 MA Marshaling Area B-317 Northwest Corner O & P Dock INACTIVE Closed

M-062b MIA-317 MA Marshaling Area B-317B-317 East South, Inside, on

Concrete Floor, C-Dock. INACTIVE Closed

M-062c MIA-317 CS90-Day Container Storage

Area B-317 QQ Dock Door. ACTIVE Closed1

M-063 MIA-317 OBOD Open Burn Area B-317Southeast Corner of Current B-

317site INACTIVE Closed

M-066 MIA-317 TS Trailer Station B-317West of B-317 and South of M-

38 INACTIVE Closed

M-067 MIA-317 TASHWMU-27 Closed Storage

Tanks B-317 B-317 Southeast, Outside INACTIVE Closed

M-068 UNGROUPED MA Marshaling Area B-318Northwest corner of B-318

central warehouse NEW OWNER Closed

M-069 UNGROUPED MA Marshaling Area B-319B-319 Southwest Corner, Inside on Concrete Floor INACTIVE Closed

M-070 UNGROUPED CS90-Day Container Storage

Area B-320B-320, Northeast Corner, Inside on Concrete Floor INACTIVE Closed

M-071 UNGROUPED MA Marshaling Area B-320B-320, Northside, Inside, on

Concrete Floor INACTIVE Closed

M-072 UNGROUPED CSHWMU-29 Container

Storage B-321 Lot 76, South of B-321 INACTIVE Closed

M-076 MIA-308 SI Surface Impoundment B-322

North of B-322. Retention pond. Contiguous with MIA-

308. INACTIVE Closed

M-077 MIA-308 TS West Trailer Station B-322Northwest Trailer Station in B-

322 Courtyard ACTIVE Closed1

M-078 MIA-308 TTTrap Tank ID TT3322IS (Tank removed in 1996) B-322 Southwest of B-322 INACTIVE Closed

M-079 MIA-308 TTTrap Tank ID TT3324IS (Tank removed in 1996) B-322 Southwest of B-322 INACTIVE Closed

M-080 MIA-308 TAS HWMU-20 Storage Tanks B-322 Tank Farm-Waste Tanks INACTIVE Closed

M-083 MIA-301 TT Trap Tank ID TT4055IS B-323 B-323 Southeast Corner ACTIVE Closed1

M-084 MIA-301 TASHWMU-13 Closed Storage

Tank #C-1365 B-323 B-323 North INACTIVE Closed

E-7

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 7 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

M-085 MIA-VH L Ver Hulst Site B-324 North of B-324 INACTIVE Closed

M-086 MIA-301 MA Marshaling Area B-325Loading Dock, West Side, Inside on Concrete Floor ACTIVE Closed1

M-096 MIA-301 TT

Trap Tank ID TT3376IS, Inspected in 1993. Good

condition. B-325Bay 3, Side Sump, Northwest

of B-325 ACTIVE Closed1

M-097 MIA-301 TT Trap Tank ID TT3377IS B-325Bay 8, Side Sump, Northeast

of B-325 ACTIVE Closed1

M-098 MIA-301 TT

Trap Tank ID TT3378IS, Inspected in 1993. Good

condition. B-325Bay 18, Side Sump, Outside,

Southwest ACTIVE Closed1

M-099 MIA-301 TT Trap Tank ID TT3379IS B-325 Southeast Corner of B-325 ACTIVE Closed1

M-100 MIA-301 TT Trap Tank ID TT4350IS B-325Northeast Corner on East Side

of North/South Head House ACTIVE Closed1

M-101 MIA-301 TAS RMMU Tank B-325Solvent Recovery, North of B-

325 INACTIVE ClosedM-102 MIA-301 TAS HWMU-12 Storage Tank B-325 North of B-325 INACTIVE Closed

M-103 UNGROUPED MA Marshaling Area B-326

South Central area of building, "C" section, Door N, Inside on

Concrete Floor INACTIVE Closed

M-105 UNGROUPED TT Trap Tank ID TT4030IS B-326Door R & Q Between Cols 29

& 28, Outside, South ACTIVE Closed1

M-107 MIA-329 CS HWMU-15 Lugger Pad B-329 East of M-31 INACTIVE ClosedM-108 MIA-329 MA Marshaling Areas B-329 Southeast Side, Inside INACTIVE Closed

M-109 MIA-329 PMR Silver Treatment Unit B-329Inside Southeast Corner of B-

329. INACTIVE Closed

M-110 MIA-329 TTTrap Tank ID TT3329IS.

Removed B-329 Southside of B-329 INACTIVE Closed

M-111 MIA-329 TASHWMU-15 Storage Tanks

(Two 270 gal tanks) B-329 Side of M-31 INACTIVE ClosedM-112 UNGROUPED MA Marshaling Area B-332 North Side, Inside INACTIVE Closed

M-113 MIA-333 CS90-Day Container Storage

Area B-333 South Side INACTIVE Closed

M-114 MIA-333 MA Marshaling Area B-333South Side, Inside, Bay 4/Bay

3 INACTIVE ClosedM-115 MIA-333 TT M95 Fuel Oil Site B-333 South of B-326, Near M-95 INACTIVE ClosedM-116 MIA-333 TT Trap Tank ID TT4100ST B-333 South of B-333 INACTIVE Closed

M-117 MIA-WRL LSWMU-10 Solid Waste

Landfill B-334 Weiland Road INACTIVE Closed

M-118 MIA-WRL S

Sump ID SP4060IS,Leachate collection system for

WRLF B-334

West of B-334, Intersection of Latona and Weiland Road, M-

7 ACTIVE Closed1

M-120 MIA-301 MA Marshaling Area B-337North Side, Inside on Concrete

Floor ACTIVE Closed1

M-121 MIA-329 CS90-Day Container Storage

Area B-349

North Side, Inside, on Concrete Floor on the loading

dock, Door J INACTIVE Closed

M-122 MIA-329 TT Trap Tank ID TT4025IS B-349 East Side, Outside ACTIVE Closed1

M-123 UNGROUPED MA Marshaling Area B-350Northeast, Inside, on Concrete

Floor INACTIVE ClosedM-125 MIA-351 MA Marshaling Area B-351 East, Outside INACTIVE Closed

M-126 MIA-351 PMR Silver Recovery vaults (2) B-352 East of B-352, Inside INACTIVE Closed

M-128 MIA-351 TS

Transfer Station (Sludge/Caustic) to tank

wagons. B-351 West Side of B-351 INACTIVE Closed

M-129 MIA-351 TSTransfer Station (Rich

Water) B-351 Dock Area-North Bays INACTIVE ClosedM-130 MIA-317 TS M43 waste lugger pad B-317 NW Corner of B-317 INACTIVE Closed

M-131 MIA-317 TS Lugger Station #317-511 B-317Southwest Corner of B-317,

Outside INACTIVE Closed

M-132 MIA-301 TSSpent Solvent (Transfer

Station) B-325 North of B-325 ACTIVE Closed1

M-133 MIA-301 TSDrum Pad (Associated with HWMU-13, SWMU M-084) B-323 North of B-323 INACTIVE Closed

M-135 MIA-301 TT Trap Tank ID SP3320IS B-302 Out side South, Bay 3 INACTIVE ClosedM-136 MIA-301 S Sump ID SP3324IS B-302 Bay 4, Ejector Sump INACTIVE ClosedM-137 MIA-301 S Sump ID SP3325IS B-302 Bay 11, Ejector Sump INACTIVE Closed

M-138 MIA-301 S

Sump ID SP3326IS, Scrubber sump for A-115

Blender B-302East Side, Outside of Room

102-1 INACTIVE Closed

M-139 MIA-301 S Sump ID SP3355IS B-303 Bay 3, Ejector Sump ACTIVE Closed1

E-8

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 8 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

M-140 MIA-301 S Sump ID SP3356IS B-303 Bay 16, Ejector Sump, North ACTIVE Closed1

M-141 MIA-301 S Sump ID SP4005SA B-303 Northwest Corner of B-303 INACTIVE Closed

M-142 MIA-301 CS Empty Drum Storage Area B-325 Outside, East Side of B-325 INACTIVE ClosedM-143 MIA-301 CS Drum Storage Area B-337 West of B-337 INACTIVE Closed

M-144 MIA-301 CS Drum Storage Area B-337 West Wall, Outside of B-337 INACTIVE ClosedM-145 MIA-329 S Sump ID SP4080IS B-329 South Courtyard INACTIVE Closed

M-146 UNGROUPED S Sump ID SP4000ST B-332 Southeast Corner, Basement ACTIVE Closed1

M-148 MIA-351 TAS90-Day Storage (Portable

Lugger) B-351Located near southwest

corner of distillation complex INACTIVE Closed

M-149 UNGROUPED TAS Septic Tank B-306 Northeast of B-306, Outside INACTIVE Closed

M-150 MIA-329 USTUnderground Storage

Tanks B-329 South Courtyard INACTIVE ClosedM-151 MIA-333 OBOD M-104 OB/OD's (2) B-333 South of B-326, M-95 INACTIVE Closed

M-152 MIA-308 UST Underground Storage Tank B-322 Tank Farm, South of B-322 ACTIVE Closed1

M-153 UNGROUPED UST

Underground Storage Tank, (Tank Closed) and

associated piping. B-350 East of B-350 INACTIVE Closed

M-154 MIA-333 UST

Underground Storage Tanks(5), removed 1992-

1993 B-333Outside, Southeast Courtyard.

B-333 INACTIVE Closed

M-155 MIA-329 UST Underground Storage Tank B-349 Between B-329 and B-349 INACTIVE ClosedM-156 MIA-351 RS Release Site B-351 Undetermined SPILL ClosedM-157 MIA-329 RS Release Site B-329 South end of west wing SPILL ClosedM-158 MIA-333 RS Release Site B-333 Northside of B-333 SPILL Closed

M-160 MIA-317 RSSeveral releases west of

Bldg-317 B-317 West End of B-317 SPILL ClosedM-161 MIA-317 RS Release Site B-317 East of B-317 SPILL ClosedM-162 MIA-308 RS Release Site B-322 B-322 area SPILL ClosedM-163 MIA-351 RS Release Site B-351 B-351/B-352 Area SPILL ClosedM-164 MIA-301 RS Release Site B-302 East of B-302 SPILL ClosedM-165 MIA-301 RS Release Site B-325 B-325 North Courtyard SPILL Closed

M-166 MIA-301 RS Release Site B-325South of B-325, Several

releases recorded. SPILL ClosedM-167 UNGROUPED RS Release Site B-321 B-321, South SPILL Closed

M-169 MIA-351 SI Retention Pond B-352 West of B-352 ACTIVE Closed1

M-170 UNGROUPED SASKPM Sanitary Sewer

System B-300 KPM Park Section ACTIVE Closed1

M-171 MIA-308 RS Release Site B-307East, Tank Farm, Sub-

Basement SPILL Closed

M-173 MIA-308 RS

Misc. releases to Storm Sewer, and releases from

tank farm B-312West side of B-312 Tank

Farm SPILL Closed

M-174 MIA-WRL R Release B-334 Near M-32 Tractor Shed ACTIVE Closed1

M-175 MIA-301 CS90-Day Container Storage

Area B-304 Inside B-304, West, Bay 14 INACTIVE Closed

M-176 MIA-301 CS90-Day Container Storage

Area B-325Headhouse, Inside East of B-

325, on Concrete Floor INACTIVE Closed

M-177 UNGROUPED MA Marshaling Area B-321 West Side of B-321 ACTIVE Closed1

M-178 UNGROUPED CS90-Day Tube Crushing

Area (Container) B-318 Northwest Side of B-318 NEW OWNER Closed

M-179 UNGROUPED CS90-Day Tube Crushing unit,

portable B-326

Northwest area of Building, "D" section, Inside on

Concrete Floor, 1st floor INACTIVE ClosedM-181 MIA-301 CS Drum Storage Areas B-331 South of B-331 INACTIVE Closed

M-182 MIA-329 MA Marshaling Area B-349Southwest Corner of B-349,

Inside INACTIVE ClosedM-183 MIA-308 RS Release Site B-308 North of B-308 SPILL Closed

M-184 UNGROUPED CS 90-Day Storage Area B-324Southwest Corner, Inside on

Concrete Floor INACTIVE Closed

M-185 MIA-351 TS Sewer Station B-351South of B-351 (Near RR

tracks) INACTIVE Closed

M-186 MIA-351 CS Container Storage Area B-351Southwest side of B-351/352

Complex. on cinder area. INACTIVE ClosedM-187 UNGROUPED MA Marshaling Area B-319 Located Inside on concrete. INACTIVE ClosedM-188 MIA-317 MA Marshaling Area B-317 M38, Southeast Dock INACTIVE Closed

M-189 MIA-333 USTUST (5 tanks) at M95 Fuel

Site B-333 At M95 Fuel Site INACTIVE Closed

E-9

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 9 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

M-192 UNGROUPED RS Release Site B-349

Storm Sewer Out Fall West of B-349, SPDES Discharge-

003. SPILL Closed

M-193 MIA-329 RS Release Site B-349B-349 Roof on west Side to

Storm Sewer Below SPILL ClosedM-196 MIA-333 RS Release Site B-333 B-333, Bay 15 SPILL Closed

M-199 MIA-329 RS Release Site B-329Off of the Northeast corner of

B-329, road/shoulder SPILL ClosedM-200 MIA-329 RS Release Site B-329 South end, west wing SPILL ClosedM-228 MIA-301 RS Release Site B-304 North of B-304 SPILL Closed

M-235 MIA-317 RRoutine and systematic

release site B-321 Near M-41 fuel tanks SPILL Closed

M-240 MIA-329 RS Release Site B-349From B-349 passivating area

(Rm 118C) SPILL Closed

M-243 MIA-301 CS90-Day Container Storage

Area B-325B-325, 1st Floor Head House, adjacent to Marshaling Area ACTIVE Closed1

M-244 MIA-301 CS90-Day Container Storage

Area B-303B-303, 1st Floor Head House, adjacent to Marshaling Area ACTIVE Closed1

M-245 MIA-317 MA Marshaling Area B-317 West end of B-317, Dock PP INACTIVE Closed

M-246 MIA-317 MA Marshaling Area B-317Northeast corner of B-317,

Dock N INACTIVE Closed

M-247 MIA-301 CS90-Day Container Storage

Area B-325

Inside B-325, 1st floor in the Southeast corner of the

building, in the Cold Room INACTIVE Closed

M-248 UNGROUPED MA Marshaling Area B-319B-319, inside on the 1st floor

near Door G INACTIVE Closed

M-249 MIA-351 MA Marshaling Area B-351B-351, outside on the SW

corner of the Bldg. INACTIVE Closed

M-250 MIA-351 TS

Draw-off valve which is opened to fill drums -

"Screen Pot" B-351Outside, near the northeast

corner of M-77 INACTIVE Closed

M-251 MIA-329 TS

Transfer Station. Concrete pad draining to IS. It is

used for caustic cleaning of load luggers. B-329

B-329, outside near the southeast corner INACTIVE Closed

M-252 MIA-308 CS90-Day Container Storage

Area B-310

Bldg. 310, inside on the west side of the building, just off the

loading dock. INACTIVE Closed

M-253 UNGROUPED CS90-Day Container Storage

Area B-320

Building 320, Rm 253, Northeast wing of building (overlooking the interior

courtyard). INACTIVE ClosedM-255 MIA-351 RS Release Site B-351 South side of Building 351 SPILL Closed

M-256 UNGROUPED CS90-Day Container Storage

Area B-320

Building 320, loading dock area in "recycling room",

accessed through door "S" INACTIVE Closed

M-257 MIA-308 CS90-Day Container Storage

Area B-308

Inside B-308, east of Dock G in the NE corner of the

building. INACTIVE Closed

M-258 MIA-301 CS90-Day Container Storage

Area B-304

Outside, west side of building 304, where building 331 used

to stand on a concrete foundation. INACTIVE Closed

M-259 MIA-301 TT Trap Tank B-304West side of Building 304 (Old

Building 331 pad) INACTIVE Closed

M-261 MIA-329 CS90-Day Container Storage

Area B-329southside of M31, in

containment area INACTIVE Closed

M-262 MIA-308 CS90-Day Container Storage

Area B-308Bld 308, 1st floor, near

overhead door "J" INACTIVE Closed

M-263 MIA-301 TSDecon Pad : with drain to

industrial sewer B-312DPI Decon Pad north of shed

M-56, near bld 312 INACTIVE Closed

M-264 MIA-308 CS90-Day Container Storage

Area B-325Outside NE corner of B325 in

cinder lot INACTIVE Closed

M-265 MIA-308 MA Marshalling Area B-308

Inside B-308, near docks U and V (south west corner of

the building) INACTIVE Closed

M-266 MIA-308 CS

180-Day Container Storage Area operated by

Nexpress B-308Inside B-308, northwest-side,

near door L INACTIVE Closed

M-267 MIA-329 CS

180-Day Container Storage Area operated by

Nexpress B-349Inside B-349, East side of

building, near door E INACTIVE Closed

M-268 MIA-301 TT Trap Tank ID TT3367IS B-304 East of Building 303 ACTIVE Closed1

E-10

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 10 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

M-269 MIA-308 CS90-Day Container Storage

Area B-308At the northwest corner of the

B-308 Train Shed ACTIVE Closed1

M-270 MIA-301 CS90-Day Container Storage

Area B-337Inside room 122, southwest

corner of B-337 INACTIVE Closed

M-271 MIA-301 CS90-Day Container Storage

Area B-301 B-301 1st floor, center aisle INACTIVE Closed

M-272 MIA-301 CS90-Day Container Storage

Area B-301 B-301/302 Courtyard Corridor INACTIVE Closed

M-273 UNGROUPED CS90-Day Container Storage

Area B-319Inside B-319, adjacent to

Dock N and O INACTIVE Closed

M-274 UNGROUPED TaS Waste Storage Tank B-319Inside B-319, southwest quadrant of the building INACTIVE Closed

M-275 UNGROUPED MA Marshaling Area B-326 B-326 at Loading dock E-1 ACTIVE Closed1

M-276 UNGROUPED CS90-Day Container Storage

Area B-350 B-350, on the west dock area INACTIVE Closed

M-277 MIA-329 CS90-Day Container Storage

Area B-349 B-349, south side of room 118 ACTIVE Closed1

M-278 MIA-308 CS90-Day Container Storage

Area B-322 B-322 Trailer Unloading Area ACTIVE Closed1

M-280 MIA-308 TaS HWMU-33 Tank Storage B-322B-322 Tanks, TK-682 and TK-

675 ACTIVE Closed1

M-281 UNGROUPED RS Release Site B-333North of B-333 in gravel trailer

area SPILL Closed

W-001 WIA-IS IS

Industrial Sewer components of the Waste

Water Treatment Unit located in KPW B-100 KPW Park Section ACTIVE Open1

W-002A WIA-KPW PMR40' and 60' Silver Recovery

Clarifiers B-110 B-110 East Side ACTIVE Closed1

W-002B WIA-KPW PMR70' Silver Recovery

Clarifiers B-110 North of B-145 ACTIVE Closed1

W-003 WIA-KPW MA Marshaling Area B-112 North of B-112, Inside INACTIVE Closed

W-005 WIA-KPW LSWMU-2 KPW Cinder Fill

Area B-105 B-105 Southeast Corner INACTIVE ClosedW-007 WIA-KPW MA Marshaling Area B-110 B-110 East Side INACTIVE Closed

W-008 WIA-KPW PMR Silver Recovery Pit B-110 Center of B-110 ACTIVE Closed1

W-009 WIA-KPW TTSump identified as a Trap

Tank, ID TT1300IS B-111East Side of B-111. (Building

demolished in 1996). INACTIVE ClosedW-010 WIA-KPW S Sump ID SP1480IS B-115 North Side of B-115 INACTIVE ClosedW-011 WIA-KPW S Sump ID SP1490IS B-115 North of B-115 INACTIVE Closed

W-012 WIA-KPW TS HWMU-03 Transfer Station B-107 East Side- Station 1 INACTIVE Closed

W-013 WIA-KPW TAS HWMU-03 Closed Tanks B-115 B-115 Tank Farm INACTIVE ClosedW-016 WIA-KPW TT Trap Tank ID TT1120IS B-117 B-117 South Courtyard INACTIVE Closed

W-017 WIA-KPW CS J-wing Lugger Station B-119Northeast Corner of B-119,

Outside INACTIVE Closed

W-018A WIA-KPW MA Marshaling Area B-119Northeast Dock, Door AD/AE,

H-wing INACTIVE ClosedW-018B WIA-KPW MA Marshaling Area B-119 South, B-Wing Dock INACTIVE ClosedW-019 WIA-KPW S Sump ID SP1001IS B-119 B-Wing, Basement INACTIVE Closed

W-021 WIA-KPW TS M-wing Station B-119Outside Northwest corner of B-

119 INACTIVE Closed

W-022 WIA-KPW TSE-wing Station TS # 119-

419 B-119 Outside Southeast Corner INACTIVE ClosedW-023 WIA-KPW TT Trap Tank ID TT1000IS B-119 D-Wing, West INACTIVE ClosedW-024 WIA-KPW TT Trap Tank ID TT1005IS B-119 B-119, J-Wing, Outside INACTIVE Closed

W-025 WIA-KPW TT Trap Tank ID TT1010IS B-119Outside, West of E-Wing, Side

Sump INACTIVE Closed

W-026 WIA-KPW TT Trap Tank ID TT1050IS B-119East Side M-Wing, Bay 10,

Side Sump INACTIVE Closed

W-027 WIA-KPW TT Trap Tank ID TT1060IS B-119I-Wing, West Side Sump,

Outside INACTIVE Closed

W-028 WIA-KPW TT Trap Tank ID TT1070IS B-119M-Wing, West Side, LEL

Monitor Well INACTIVE ClosedW-029 WIA-KPW TT Trap Tank ID TT1122IS B-119 L-Wing, Bay 6, Outside INACTIVE ClosedW-030 WIA-KPW TT Trap Tank ID TT1123IS B-119 L-Wing, Bay 8 INACTIVE ClosedW-031 WIA-KPW TT Trap Tank ID TT1124IS B-119 D-Wing, East Side Sump INACTIVE Closed

W-032 WIA-KPW TT Trap Tank ID TT1126IS B-119 M-Wing, Bunker, Side Sump ACTIVE Closed1

W-033 WIA-KPW TT Trap Tank ID TT1166IS B-119 J-Wing, West Side Sump INACTIVE ClosedW-034 WIA-KPW TT Trap Tank ID TT4090IS B-119 F-Wing, West Trap Tank INACTIVE Closed

W-035 WIA-KPW TT Trap Tank ID TT4200IS B-119 M-Wing, Courtyard, Trap Tank INACTIVE Closed

E-11

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 11 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

W-036 WIA-KPW TT Trap Tank ID TT4250IS B-119 I-Wing, Courtyard, Trap Tank INACTIVE Closed

W-037 WIA-KPW TAS90-Day Storage Area

(Tank) B-119Outside, Southeast Corner of

B-119, E-Wing Vault INACTIVE Closed

W-038 WIA-KPW TAS HWMU-02 Closed Tanks B-119 Outside Southeast of E-Wing INACTIVE Closed

W-039 WIA-KPW TAS Storage Tanks B-119 M-Wing, Outside, Northwest INACTIVE ClosedW-040 WIA-KPW DT HWMU-03 Still B-120 Still INACTIVE Closed

W-042 WIA-KPW S Sump ID SP1450IS B-120 B-120, Northwest Side ACTIVE Closed1

W-043 WIA-KPW S Sump ID SP1460IS B-120 South of B-120 Bay 11, Inside ACTIVE Closed1

W-045 WIA-KPW S Sump ID SP14856I B-120 B-120 Bay 4 ACTIVE Closed1

W-046 WIA-KPW TSTransfer Station TS #120-

264 B-120B-121 Courtyard, North of B-

121 ACTIVE Closed1

W-047 WIA-KPW TTTrap Tank ID TT1350IS.

(Tank has been removed) B-120 B-120 Southwest, Outside INACTIVE Closed

W-048 WIA-KPW TTTrap Tank ID TT4100IS.

(Tank has been removed) B-120 B-120 Southwest, Outside INACTIVE Closed

W-049 WIA-KPW TAS HWMU-03 Closed Tanks B-120 Northwest of B-120, Vault 50 INACTIVE Closed

W-050 WIA-KPW TASHWMU-03 Storage Tank/

Decant Tank B-120

Outside of B-120, Vault 50, Outside; Also includes

Decanter-Outside; INACTIVE ClosedW-051 WIA-KPW TT Trap Tank ID TT1150IS B-122 B-122 North INACTIVE Closed

W-052 WIA-KPW TT Trap Tank ID TT1250IS B-123

North of B-123, Inside (Building has been

demolished) INACTIVE Closed

W-053 WIA-KPW TAS HWMU-03 Closed Tanks B-123

West Side of B-123, Outside (Building has been

demolished) INACTIVE ClosedW-054 WIA-KPW MA Marshaling Area B-126 B-126 West INACTIVE Closed

W-055 WIA-KPW CSSWMU-6 Drum Storage

Area B-129 NE of B-129, on Concrete Pad INACTIVE ClosedW-056 WIA-KPW MA Marshaling Area B-129 B-129 North Addition INACTIVE Closed

W-057 WIA-KPW CS90-Day Container Storage

Area B-130 B-130 South Side INACTIVE Closed

W-058 WIA-KPW CS Waste Solvent Lugger Pad B-130South side of the former B-130

(south of B-148) INACTIVE ClosedW-059 WIA-KPW MA Marshaling Area B-130 B-130 Headhouse INACTIVE ClosedW-060 WIA-KPW TT Trap Tank ID TT1155IS B-130 South, East Side INACTIVE Closed

W-061 WIA-KPW TT Trap Tank ID TT1100IS B-130Side Sump, B-130, Northeast,

East Side INACTIVE Closed

W-062 WIA-KPW TT

Trap Tank ID TT4150IS. Steam Condensate from B-

148 B-130 B-130 Southeast, Outside INACTIVE Closed

W-063 WIA-KPW MA Marshaling Area B-130Headhouse (B-130 & 131),

Inside Bldg. on Concrete Floor INACTIVE ClosedW-064 WIA-KPW TT Trap Tank ID TT1131IS B-131 Northeast of B-131 INACTIVE ClosedW-065 WIA-KPW MA Marshaling Area B-132 B-132 Southwest, Outside INACTIVE Closed

W-067 WIA-KPW MA Marshaling Area B-135west side of B-135 to the north

of door "R" INACTIVE Closed

W-068 WIA-KPW TT Trap Tank ID TT1135IS B-135Inside B-135, North Central

Wall INACTIVE Closed

W-069 WIA-KPW TT Trap Tank ID TT1136IS B-135Solvent Room, E, Inside

Building INACTIVE Closed

W-070 WIA-KPW CSSWMU-6 Syn. Chem.

Container Accumulation B-137 Northeast Corner, Outside INACTIVE Closed

W-072 WIA-KPW TT Trap Tank ID TT1100IS B-137East Wall, Lab 5, Outside B-

137 INACTIVE Closed

W-073 WIA-KPW TT Trap Tank ID TT1110IS B-137East Wall, Lab 9, Outside B-

137 INACTIVE Closed

W-074 WIA-KPW TT Trap Tank ID TT1125IS B-137East Wall, Lab 8, Outside B-

137 INACTIVE Closed

W-075 WIA-KPW TT Trap Tank ID TT1130IS B-137East Wall, Lab 7, Outside B-

137 INACTIVE Closed

W-076 WIA-KPW TT Trap Tank ID TT1137IS B-137East Wall, Lab 6, Outside B-

137 INACTIVE Closed

W-077 WIA-KPW TT Trap Tank ID TT1220IS B-137Outside B-137, Lab 1, East

Wall INACTIVE Closed

W-078 WIA-KPW TT Trap Tank ID TT1230IS B-137East Wall, Lab 3, Outside B-

137 INACTIVE Closed

E-12

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 12 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

W-079 WIA-KPW TT Trap Tank ID TT1240IS B-137East Wall, Lab 2, Outside B-

137 INACTIVE Closed

W-080 WIA-KPW TT Trap Tank ID TT1260IS B-137East Wall, Lab 4, Outside B-

137 INACTIVE Closed

W-081 WIA-KPW CSSWMU-5 PCB Storage

Area B-138 Demolished Bldg. 138 INACTIVE ClosedW-082 WIA-KPW I SWMU-4 Incinerator B-138 Demolished B-138 INACTIVE Closed

W-083 WIA-KPW MA Marshaling Area B-140 Inside, B-140 Southwest Dock INACTIVE Closed

W-084 WIA-KPW TT Trap Tank ID TT1140IS B-140B-140 North Wall Inside

Building INACTIVE Closed

W-087 WIA-KPW ISWMU-3 Solid Waste

Incinerator B-145 B-145 INACTIVE Closed

W-088 WIA-KPW IWastewater Treatment

Plant Sludge Dryer B-145 B-145 West INACTIVE Closed

W-089 WIA-KPW MA Marshaling Area B-145B-145 Southeast Corner

Courtyard INACTIVE Closed

W-090 WIA-KPW TT Trap Tank ID TT1141IS B-145B-145 Southwest Corner,

Outside INACTIVE ClosedW-092 WIA-KPW TT Trap Tank ID TT1145IS B-145 Outside B-145, East Wall INACTIVE Closed

W-093 WIA-KPW TT Trap Tank ID TT1146IS B-145B-145 Southeast Corner,

Outside INACTIVE Closed

W-095 WIA-KPW MA Marshaling Area B-148 North Addition, Loading Dock INACTIVE ClosedW-096 WIA-KPW TS Transfer Station B-148 B-148 North Side INACTIVE ClosedW-097 WIA-KPW TT Trap Tank ID TT1105IS B-148 Outside, North of B-148 INACTIVE Closed

W-098 WIA-KPW TT Trap Tank ID TT1165IS B-148 Outside, B-148, South ACTIVE Closed1

W-099 WIA-KPW TT Trap Tank ID TT1170IS B-148 Outside, B-148, South ACTIVE Closed1

W-100 WIA-KPW TT Trap Tank ID TT1180IS B-148 Outside B-148, South ACTIVE Closed1

W-101 WIA-KPW TT Trap Tank ID TT1190IS B-148 Outside B-148, South ACTIVE Closed1

W-102 WIA-KPW TT Trap Tank ID TT1200IS B-148 Outside B-148, South ACTIVE Closed1

W-103 WIA-KPW TT Trap Tank ID TT1210IS B-148 South ACTIVE Closed1

W-104 WIA-KPW TAS HWMU-05 Storage Tank B-148 North Side of B-148 INACTIVE ClosedW-105 WIA-KPW MA Marshaling Area B-151 B-151 South Side INACTIVE ClosedW-108 WIA-KPW MA Marshaling Area B-155 B-155 East Side INACTIVE Closed

W-109 WIA-KPW PMR Silver Recovery B-156 B-156 ACTIVE Closed1

W-110 WIA-KPW TSTransfer Station TS #120-

273 B-120 Southwest of B-120 INACTIVE Closed

W-111 WIA-KPW TSTransfer Station TS # 110-

287 B-110 B-110 North Side ACTIVE Closed1

W-112 WIA-KPW TAS HWMU-03 Tank Storage B-115 North of B-115 West of B-107 INACTIVE Closed

W-113 WIA-KPW TSTransfer Station TS # 101-

338 B-101 South of B-101 INACTIVE Closed

W-115 WIA-KPW S Sump ID SP1130IS B-117Northeast Corner, Outside B-

117 ACTIVE Closed1

W-116 WIA-KPW S Sump ID SP1006IS B-119 Inside F-Wing, Eastside INACTIVE Closed

W-117 WIA-KPW S Sump ID SP1119IS B-119F-Wing, West Trench, Inside

West Wall INACTIVE Closed

W-118 WIA-KPW S Sump ID SP1121IS B-119Inside East Wall, F-Wing, East

Trench INACTIVE Closed

W-119 WIA-KPW SSump ID SP1125IS;

Steam Jet Ejector Sump B-119 Outside, West Wall, E-Wing INACTIVE Closed

W-120 WIA-KPW S Sump ID SP1128IS B-119D-Wing, West Ejector Hot

Well INACTIVE Closed

W-121 WIA-KPW S Sump ID SP1260IS B-129 Lab 19 and Lab 21, Outside INACTIVE Closed

W-122 WIA-KPW S Sump ID SP1410IS B-143 Outside B-143, South Wall ACTIVE Closed1

W-123 WIA-KPW S Sump ID SP1420IS B-108Center of B-108 (Building

demolished in 1996) INACTIVE Closed

W-124 WIA-KPW CS Drum Storage Area B-134 East and Southeast of B-134 INACTIVE Closed

W-125 WIA-KPW S Sump ID SP1400IS B-109South Side of B-109 (Building

demolished in 1996) INACTIVE ClosedW-143 WIA-KPW CS Drum Storage Area B-148 Along South Wall - West INACTIVE ClosedW-144 WIA-KPW CS Drum Storage Area B-148 North of B-148 INACTIVE ClosedW-145 WIA-KPW CS Drum Storage Area B-148 East of B-148 INACTIVE Closed

W-146 WIA-KPW CS Drum Storage Area B-148 West of B-148 along Railroad INACTIVE Closed

W-147 WIA-KPW S Sump ID SP1145IS B-145B-145 Southwest Corner,

Outside INACTIVE Closed

W-149 WIA-KPW SSump - West Shredder

Pump; SP2495IS B-145 B-145 Northwest INACTIVE Closed

E-13

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 13 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

W-150 WIA-KPW SRefuse Pit Sump,

SP2496IS B-145 North Center B-145 INACTIVE ClosedW-151 WIA-KPW S Sump ID SP1380IS B-138 Southeast of B-138 INACTIVE ClosedW-152 WIA-KPW S Sump ID SP1390IS B-138 South of B-138 INACTIVE Closed

W-155 WIA-KPW S Sump ID SP1430IS B-120 Southwest of B-120 ACTIVE Closed1

W-156 WIA-KPW S Sump ID SP1510IS B-142 Outside, West of B-142 ACTIVE Closed1

W-157 WIA-KPW TT Trap Tank ID TT1320IS B-114Basement East Wall Between

Cols 301 and 302 ACTIVE Closed1

W-158 WIA-KPW S Sump ID SP1117IS B-117Northeast Corner of B-117

(Room 115) ACTIVE Closed1

W-159 WIA-KPW MA Marshaling Area B-101 East Side of B-101 INACTIVE ClosedW-160 WIA-KPW MA Marshaling Area B-102 East Side of B-102 INACTIVE Closed

W-162 WIA-KPW S Sump ID SP1116IS B-117North-Center of B-117, Rm 110, Reactor Room East ACTIVE Closed1

W-163 WIA-KPW S Sump ID SP1270IS B-129 B-129 Lab 34 INACTIVE ClosedW-164 WIA-KPW S Sump ID SP1280IS B-129 Lab 36, outside INACTIVE ClosedW-165 WIA-KPW S Sump ID SP1290IS B-129 Lab 40, outside INACTIVE ClosedW-166 WIA-KPW S Sump ID SP1300IS B-129 Lab 44, outside INACTIVE ClosedW-167 WIA-KPW S Sump ID SP1310IS B-129 Lab 48, outside INACTIVE Closed

W-168 WIA-KPW S Sump ID SP1320IS B-129Outside B-129, Between Labs

20 and 21 INACTIVE ClosedW-169 WIA-KPW S Sump ID SP1330IS B-129 Lab 47, outside INACTIVE ClosedW-170 WIA-KPW S Sump ID SP1340IS B-129 Lab 43, outside INACTIVE ClosedW-171 WIA-KPW S Sump ID SP1350IS B-129 Lab 37, outside INACTIVE ClosedW-172 WIA-KPW S Sump ID SP1360IS B-129 Lab 35, outside INACTIVE ClosedW-173 WIA-KPW S Sump ID SP1365IS B-129 Labs 9 and 11, outside INACTIVE Closed

W-174 WIA-KPW PMRSilver Recovery Pond.

(Pond has been filled in) B-110 B-110 Northeast INACTIVE Closed

W-175 WIA-KPW PMR

Precious Metals Recovery Filters (Walnut Filter

System) B-144 B-144 ACTIVE Closed1

W-176 WIA-KPW UST Underground Storage Tank B-123West side of B-123 (Building

has been demolished) INACTIVE Closed

W-177 WIA-KPW USTUnderground Storage

Tank. B-120 B-120 SW Tank Farm INACTIVE Closed

W-178 WIA-KPW USTUnderground Storage

Tank. B-120B-120 Northwest of Tank

Farm INACTIVE Closed

W-179 WIA-KPW USTUnderground Storage Tank

Farm. B-115 East Side of B-120 INACTIVE Closed

W-180 WIA-KPW UST Underground Storage Tank B-142 South of B-142, Tank Farm INACTIVE Closed

W-181 WIA-KPW UST

Underground Storage Tank with Secondary

Containment B-110 East Side of B-110, outside INACTIVE Closed

W-182 WIA-KPW UST Underground Storage Tank B-119 E-Wing, Bunker INACTIVE Closed

W-183 WIA-KPW UST Underground Storage Tank B-119 B-119 Courtyard INACTIVE Closed

W-184 WIA-KPW USTUnderground Storage

Tanks (5 Tanks in Vault) B-119 M-Wing, Bunker INACTIVE ClosedW-185 WIA-KPW RS Release Site B-114 North of B-114 SPILL ClosedW-186 WIA-KPW RS Release Site B-107 Northeast of B-107 SPILL ClosedW-187 WIA-KPW RS Release Site B-145 Northwest Corner SPILL ClosedW-188 WIA-KPW RS Release Site B-108 West of B-108 SPILL ClosedW-189 WIA-KPW RS Release Site B-110 B-110 SPILL ClosedW-190 WIA-KPW RS Release Site B-115 B-115 Tank Farm SPILL ClosedW-191 WIA-KPW RS Release Site B-123 B-123 SPILL ClosedW-192 WIA-KPW RS Release Site B-119 B-119 North Courtyard SPILL Closed

W-194 WIA-KPW RS Release Site B-119B-119 Central, Under H-Wing,

I-Wing and K-Wing SPILL ClosedW-195 WIA-KPW RS Release Site B-119 F-Wing and G-Wing SPILL ClosedW-196 WIA-KPW RS Release Site B-119 B-119 West Courtyard SPILL ClosedW-197 WIA-KPW RS Release # NH00284 B-140 Outside B-140, South Wall SPILL Closed

W-198 WIA-KPW USTUnderground Storage

Tanks (2 X 11,000 gal.) B-119 West of B-119, D-Wing INACTIVE ClosedW-200 WIA-KPW RS Railroad System B-151 West Side of KPW SPILL Closed

W-201 WIA-KPW SASKPW Sanitary Sewer

System B-100 KPW Park Section ACTIVE Closed1

W-202 WIA-KPW S Sump ID SP1100SA B-129 North Wing-3rd from West INACTIVE ClosedW-203 WIA-KPW RS Release Site B-107 Northeast corner of B-107 SPILL Closed

W-204 WIA-KPW CS90-Day Container Storage

Area B-119 K-Wing INACTIVE Closed

W-205 WIA-KPW CS90-Day Container Storage

Area B-130 Northeast of B-131 INACTIVE Closed

E-14

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 14 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

W-206 WIA-KPW CS90-Day Container Storage

Area B-148 B-148 INACTIVE ClosedW-207 WIA-KPW R Rich Water Release B-143 Southwest of B-143 SPILL Closed

W-208 WIA-KPW CS90-Day Container Storage

Area B-137 B-137 INACTIVE ClosedW-209 WIA-KPW MA Marshaling Area B-117 B-117 Courtyard, in Shed INACTIVE Closed

W-210 WIA-KPW MA Marshaling Area B-151Southeast Corner, B-151,

Inside, Loading Dock INACTIVE Closed

W-211 WIA-KPW LDrum Excavation Area,

drums removed B-119Central, H-Wing, I-Wing, K-

Wing INACTIVE Closed

W-212 WIA-KPW CS90-Day Container Storage

Area B-129Outside, West Side of B-129

(Center) INACTIVE Closed

W-213 WIA-KPW S Sump ID SP1118IS B-117Inside B-117, Room 110 (Reactor Room West) ACTIVE Closed1

W-214 WIA-KPW S Sump WSP117020ISI B-117 Inside B-117, Room 118 ACTIVE Closed1

W-215 WIA-KPW S Sump WSP117024ISI B-117 Door M ACTIVE Closed1

W-216 WIA-KPW CS90-Day Container Storage

Area B-135 Inside, North INACTIVE ClosedW-217 WIA-KPW TT Trap Tank ID TT1150IS B-145 Outside, South B-145 INACTIVE ClosedW-218 WIA-KPW TT Catch Tank B-151 South of B-151 INACTIVE ClosedW-219 WIA-KPW TT Catch Tank B-151 South of B-151 INACTIVE Closed

W-220 WIA-KPW S Tunnel Scrubber Sump B-119 Northwest Corner of D-Wing INACTIVE ClosedW-221 WIA-KPW S Tunnel Scrubber Sump B-129 Inside Shed D-5 INACTIVE ClosedW-222 WIA-KPW S Tunnel Scrubber Sump B-130 West of B-130 INACTIVE ClosedW-223 WIA-KPW S Tunnel Scrubber Sump B-131 North of B-130 INACTIVE ClosedW-224 WIA-KPW S Tunnel Scrubber Sump B-137 Southwest Corner of B-137 INACTIVE ClosedW-225 WIA-KPW S Tunnel Scrubber Sump B-119 Southeast end of B Wing INACTIVE Closed

W-226 WIA-KPW MA Marshaling Area B-117 Inside B-117, Room 164GTENANT

CONTROL Closed

W-228 WIA-KPW RS Release Site B-107North side, near railroad

tracks SPILL Closed

W-232 WIA-KPW RSRailroad tracks southwest

of B-109. B-109Southwest corner; in the

railroad yard SPILL ClosedW-233 WIA-KPW RS Release Site B-109 North, near B-108 SPILL ClosedW-238 WIA-KPW RS Release Site B-119 East side; center dock SPILL Closed

W-244 WIA-KPW RS Release Site B-132West side, near center of the

Bldg SPILL ClosedW-252 WIA-KPW RS Release Site B-140 North side of building SPILL ClosedW-253 WIA-KPW RS Release Site B-140 Northwest SPILL ClosedW-255 WIA-KPW RS Release Site B-140 Northeast corner SPILL Closed

W-258 WIA-KPW CS90-Day Container Storage

Area B-110 Southwest side of B-110 INACTIVE Closed

W-259 WIA-KPW CS90-Day Container Storage

Area B-116Center of B-116 at D-32 which

is a dock attached to B-116 ACTIVE Closed1

W-260 WIA-KPW CS90-Day Container Storage

Area B-119H-Wing Cold Room in B-119 and south wall spotting area INACTIVE Closed

W-261 WIA-KPW MA Marshaling Area B-143SE Corner of B-143, inside

loading dock area INACTIVE Closed

W-262 WIA-KPW RS Release Site B-119

Pumping wells on the North side of B-119. Approximated

SWMU location shown on map. Specific site was not

documented. SPILL ClosedW-263 WIA-KPW MA Marshaling Area B-110 B-110, Rm 128 INACTIVE Closed

W-264 WIA-KPW CS90-Day Container Storage

Area B-148 Bldg. 148 North of Building INACTIVE Closed

W-265 WIA-KPW CS90-Day Container Storage

Area B-119 Bldg. 119 North Court Yard INACTIVE Closed

W-266 WIA-KPW TAS 90-Day Tank Storage B-115

Surge Tank STK-77 used to collect relief valve discharge on pipeline 20 inside B-115 INACTIVE Closed

W-267 WIA-KPW TAS 90-Day Storage Tank B-120

Surge tank STK-64, used to collect a variety of streams in

B-120 ACTIVE Closed1

W-268 WIA-KPW CS90-Day Container Storage

Area B-102Located on the former B-102

floor slab INACTIVE Closed

W-269 WIA-KPW RS Release Site B-101B-101 exhaust stack. Located

between B-101 and B-110 INACTIVE Closed

W-270 WIA-KPW CS90-Day Container Storage

Area B-101North of B-101, and west of B-

145 INACTIVE Closed

E-15

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 15 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

W-271 WIA-KPW CS90-Day Container Storage

Area B-110 Bld 110, Room 129 INACTIVE Closed

W-272 WIA-KPW MA Marshaling Area B-101Building 101, under B-101

stack area INACTIVE Closed

W-273 WIA-KPW MA Marshaling Area B-148 B-148, Door M ACTIVE Closed1

W-274 WIA-KPW RS Release Site B-156 B-156, south side SPILL Closed

X-001 XIA-IS IS

Industrial Sewer components of the Waste

Water Treatment Unit located in KPX B-200 KPX Park Section ACTIVE Closed1

X-004 XIA-202 OBODFormer Open Burn &

Refuse Management Site B-202Vicinity of B-202, B-215 and B-

217 INACTIVE Closed

X-005 XIA-202 PMR Silver Recovery Burner B-202

Was formerly located in the center of B-202. Building 202 has been demolished, so this is now just the site. Building

demolished April, 2002 INACTIVE Closed

X-006 UNGROUPED CS HWMU-22 Drum Storage B-203 B-203 East, Inside INACTIVE ClosedX-007 UNGROUPED MA Marshaling Area B-203 B-203 Northwest Side INACTIVE ClosedX-009a UNGROUPED MA Marshaling Area B-205 B-205 East Side, Inside INACTIVE ClosedX-009b UNGROUPED MA Marshaling Area B-205 B-205 West Side, Inside INACTIVE ClosedX-010 UNGROUPED TT Trap Tank ID TT2000IS B-205 B-205 Southeast INACTIVE Closed

X-011 UNGROUPED TT Trap Tank ID TT2205IS B-205 B-205, East Center, Outside INACTIVE ClosedX-013 UNGROUPED TT Trap Tank ID TT2206IS B-206 Northwest of B-206 INACTIVE ClosedX-014 UNGROUPED MA Marshaling Area B-207 B-207 Southwest Corner INACTIVE ClosedX-016 UNGROUPED MA Marshaling Area B-209 B-209 Center INACTIVE Closed

X-017 XIA-202 CS Drum Storage Area B-210North of Current B-202 and B-

217 Site Building 202 INACTIVE Closed

X-018 XIA-202 ISWMU-07 B-210 Drum

Decontaminator B-210 Northeast of B-202 INACTIVE Closed

X-020 XIA-208 CS

HWMU-08 Storage Area (Container), Exempt and

permitted B-212 Inside, B-212 INACTIVE Closed

X-022 XIA-208 CS HWMU-08 Drum Storage B-212 Inside, B-212 INACTIVE Closed

X-023 XIA-208 WP Salvage Yard B-212B-212, Metal Salvage Yard on

Cinder Base. INACTIVE ClosedX-024 XIA-208 SI Truck Wash Station B-213 South East of B-213 INACTIVE ClosedX-025 XIA-208 MA Marshaling Area B-213 B-213 Outside, North Side INACTIVE Closed

X-028 XIA-218 CS90-Day Container Storage

Area B-218B-218 Northwest, Outside, on

Concrete INACTIVE Closed

X-030 XIA-218 CS HWMU-07 Drum Storage B-218 B-218 Indoor ACTIVE Closed1

X-031 XIA-218 CSHWMU-07 Container

Storage B-218 Northeast of B-218, Outside ACTIVE Closed1

X-033 XIA-218 I HWMU-07 Rotary Kiln B-218 B-218 INACTIVE Closed

X-034 XIA-218 TS

Tank Farm Trailer Station with secondary

containment B-218 Trailer station west of B-218 INACTIVE ClosedX-035 XIA-218 TS Transfer Station B-218 Northwest of B-218 INACTIVE ClosedX-036 XIA-218 TT Trap Tank ID TT4075IS B-218 West of B-218 INACTIVE Closed

X-037 XIA-218 TASHWMU-07 Closed Storage

Tanks B-218 B-218 Northwest INACTIVE Closed

X-038 XIA-218 TASHWMU-07 Receiving

Tanks B-218 B-218 (outside west wall) INACTIVE Closed

X-039 XIA-218 TAS HWMU-07 Storage Tanks B-218 B-218 Northwest INACTIVE ClosedX-040 XIA-218 TS West Lugger B-218 B-218 INACTIVE Closed

X-041 XIA-218 TS Sewer Station B-218 South of B-218 ACTIVE Closed1

X-042 XIA-202 TSSewer Station TS #202-

326 B-202 South west of B-202 INACTIVE ClosedX-043 XIA-218 TS East Lugger B-218 B-218 INACTIVE ClosedX-046 UNGROUPED TAS Storage Tanks B-209 North of B-209 INACTIVE Closed

X-048 XIA-218 UST Underground Storage Tank B-218 West side of B-218 INACTIVE ClosedX-049 UNGROUPED RS Release # DC00016 B-203 Southwest of B-203 SPILL ClosedX-051 UNGROUPED RS Release Site B-205 Northeast side of B-205 SPILL ClosedX-052 XIA-218 RS Release Site B-218 West of B-218 SPILL Closed

X-053 UNGROUPED SASKPX Sanitary Sewer

System B-200 KPX Park Section ACTIVE Closed1

X-054 UNGROUPED RS Release Site B-207 B-207 SPILL Closed

E-16

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Attachment E - Corrective Action RequirementsEastman Business Park : SWMU Master List

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 16 of 16 SWMU Master List

ID INVESTIGATION AREA UNIT TYPE GENERAL DESCRIPTION BUILDING

NUMBER LOCATION NOTES OPERATIONAL STATUS

CORRECTIVE ACTION STATUS

X-057 XIA-208 CS Container Crushing Area B-213 Southeast of B-213. INACTIVE ClosedX-059 XIA-208 TS Wash Pad B-213 East of B-213 INACTIVE ClosedX-061 UNGROUPED RS H-42 Train Fueling Area B-202 West side of shed H-42 SPILL ClosedX-064 UNGROUPED RS Release Site B-205 Northwest side of B-205 SPILL ClosedX-065 UNGROUPED RS Release Site B-205 West side center of B-205 SPILL ClosedX-066 UNGROUPED RS Release Site B-206 Northeast of B-206 SPILL ClosedX-067 UNGROUPED RS Release Site B-216 East of B-216 SPILL Closed

X-069 UNGROUPED CS90-Day Container Storage

Area B-205

IMM Purchasing, Investment Recovery Dept., Bldg. 205

(inside), Room C, near Dock 16 INACTIVE Closed

X-070 UNGROUPED CS90-Day Container Storage

Area B-205

Bldg. 205 Loading Dock on the South West end of the

building INACTIVE Closed

X-071 XIA-208 CS90-Day Container Storage

Area B-213

South of B-218 and coincidental with former B-213

site INACTIVE ClosedX-073 UNGROUPED MA Marshaling Area B-205 B-205, West Side, Dock 55 INACTIVE Closed

X-074 XIA-218 CS90-Day Container Storage

Area B-218B-218 at the north side loading

dock ACTIVE Closed1

X-075 XIA-208 CS90-Day Container Storage

Area B-213Decontamination and Disposal Facility, south of former B-213 ACTIVE Closed1

Notes:1. Closed - previously designated as No Further Action ("NFA"). Releases from these units have been evaluated and remedies have been implemented where necessary.

Unit is no longer in active service.2. Closed 1 -

previously designated as No Further Action ("NFA"). Releases from these units have been evaluated and remedies have been implemented where necessary.

Unit remains in active service and potentially subject to corrective action in event of future release. Unit subject to decommissioning inspection when removed from active service.

Corrective action in event of future release is Permittee responsibility.3. Open 1 -

"Pre-existing contamination" from SWMU is active EBP-ET obligation per Exhibit B-3.

However, unit remains in active service and potentially subject to corrective action in event of future release. Unit subject to decommissioning inspection when removed from active service.

Corrective action in event of future release is RED responsibility.4. Open 2 -

"Unit is inactive. "Pre-existing contamination" from SWMU is active EBP-ET obligation per Exhibit B-3.

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ATTACHMENT F

PROCEDURES TO PREVENT HAZARDS

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

Table of Contents

Attachment F: Procedures to Prevent Hazards (HWMU-32 & HWMU-33)

Appendices

Appendix F-1: Inspection Schedule (HWMU-32 & HWMU-33) Appendix F-2: Sample Inspection Forms (HWMU-32 & HWMU-33)

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Attachment F: Procedures to Prevent Hazards

Building 95 Multiple .Hearth Incinerator Operated by RED (HWMU-32) &

Building 322 Hazardous Waste Storage Tank System Operated by Kodak (HWMU-33)

Provided below are the sections/items off of the checklist that pertain to HWMU-32 & HWMU-33, outlining the procedures used to prevent hazards for those particular hazardous waste management-units at the Eastman Business Park facility. Overall Kodak is responsible for security at both permitted units and at EBP in general.

F-1a(2)(a) Barrier

The active portions of HWMU 32 & HWMU-33 are completely enclosed with a chain link fence, by building walls, by natural barriers, by controlled entry [Section F-1a(2)(b)] or by another similar and suitable, barrier preventing unauthorized access to the HWMUs.

F-1a(2)(b) Means to Control Entry

A 24-hour surveillance system (e.g., television monitoring or surveillance by guards or facility personnel) that continuously monitors and controls entry onto the active portion of the facility, including Building 322 in the KPM section of Eastman Business Park (HWMU-33).

. .

Access to Building 95 at King's Landing (HWMU-32) is only allowed through an entrance that is electronically monitored with a security camera 24 hours/day, 7 days/week.

F-1a(3) Warning Signs

Warning signs that are legible from a distance of 25 feet are posted at the HWMUs.

There is no smoking allowed within the Eastman Business Park facility except in designated areas specifically selected or arranged for this purpose, and all facility entrances are posted with signs indicating "No Smoking Beyond This Point".

All signs are in English; there is no requirement for bilingual signs in Monroe County.

F-2c Remedial Action

Any deteriorated or malfunctioning equipment revealed during an inspection will be repaired or replaced in an appropriate time frame, or the equipment will be removed from service. Where an

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environmental and/or human health hazard is imminent, the response will take place immediately. Where a spill or environmental and/or human health hazard has occurred, spill response procedures described in Attachment G will be followed for remedial action.

F-3a(1)(2) Internal and External Communications

HWMU-32 and HWMU-33 have communication systems and alarms that are capable of providing emergency instruction/notification in case of an emergency situation.

F-3 a(4) Water for Fire Control .

Eastman Business Park has a water system owned and operated by RED that services fire control and provides water at an adequate volume and pressure to supply water hose streams. Building 95 (HWMU-32) has an internal sprinkler system for portions of the building and outside responders would-provide any additional control measures needed. In addition, Building 322 (HWMU-33) in the West Distilling complex is equipped with an automatic fire suppression system, as well as a hardwired Emergency Shutdown System (ESD). The ESD automatically shuts down all equipment within the West Distilling complex when it is activated by pushing one of the approximately dozen dedicated buttons located throughout the complex.

F-4d Equipment and Power Failure In the event of a power failure at HWMU-32, "fail-safe" operation of fuel feed equipment and combustion air equipment would stop the transfer of waste and/or fuel. In the event of a power failure at HWMU-33, all equipment would be shut down to a “fail-safe” state.

F-4e Personal Protective Equipment (PPE)

Handling of the HWMU-32 and HWMU-33 waste streams does not require any special PPE.

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ATTACHMENT F - APPENDIX F-1

INSPECTION SCHEDULE (HWMU-32 & HWMU-33)

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSINESS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497.

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ATTACHMENT F - APPENDIX F-2

SAMPLES INSPECTION FORMS (HWMU-32 & HWMU-33)

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSIENSS PARK

HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

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Appendix F-2 Sample Inspection Forms (HWMU-33)

Unit No: Condition No: Record ID: Schedule: Time Period: HWMU-33 HWMU-33.TAS-Employee 2009-12-31 Daily 12/31/2009

Requirement Daily storage tank inspections

Last Update:

Monitoring Description Hazardous Waste Storage Tank System Tank 675 and 682

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