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:r Elkem Metals Company^ Park West Office Center. P O Box 266

Pittsburgh, Pennsylvania 15230« (412) 778-3600Telex: 866-365

January 29, 1987

Mr. Basil G. ConstantelosDirectorWaste Management DivisionUnited States Environmental

Protection AgencyRegion 5230 South Dearborn StreetChicago, Illinois 60604

FES 051387U.S. EPA, REGION V

WASTE MANAGEMENT DIVISIONOFFICE OF THE DIRECTOR

Re: Fields Brook Site, Ashtabula, Ohio

Dear Mr. Constantelos:

Over the past few years, Elkem Metals Company (EM) has receivedvarious inquiries from your office regarding the above-referenced site, thelatest of which was your letter of December 30, 1986 reviewing varioussettlement possibilities.

EM has responded to these inquiries in the past simply by denying anyinvolvement whatsoever with the Fields Brook Site, and that continues to beour position. EM did not take title to its Ashtabula Plant until June 30,1981 in an asset-purchase transaction with Union Carbide Corporation. EMhas never discharged any substances of any nature into Fields Brook, itstributaries, or the drainage basin generally, and to our knowledge neitherdid Union Carbide. All of the waste disposal from EM's furnace operationsat Ashtabula flow into EPA-approved settling ponds, where the waste istreated and ultimately discharged north into Lake Erie.

Nevertheless, it appears that EPA has designated EM as a potentiallyresponsible party (PRP). Under the circumstances, EM would like to takethis opportunity to respond more fully to the most recent informationrequest which we received from EPA, which was dated May 16, 1986. Theanswers to Part III are transcribed following the questions, which arereproduced below.

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III. REQUEST FOR INFORMATION

1. Please provide the date, State of incorporation, Registered agentand his address for Elkem Metals Ohio (hereinafter referred to as EM).

RESPONSE: Elkem Metals Company (hereinafter EM) is a New YorkPartnership, formed on June 18, 1981. Its registered agent in the State of

Ohio is CT Corporation SystemCleveland, Ohio 44114.

815 Superior Avenue, N.E., Cuyahoga County,

2. Provide the addresses of all facilities owned or operated by EM inthe Fields Brook water basin area in Ashtabula, Ohio. If any of thefacilities that have been operated by EM, were not at all times ofoperation owned by EM, provide the name(s) of the other owner(s) of thefacility and a description of each property's location.

RESPONSE: EM owns and operates a ferroalloy production facilityat P.O. Box 40, Lake Road East, Ashtabula, Ohio 44004, for the productionof ferrosilicon, magnesium-ferrosilicon, calcium carbide, and variousspeciality alloys. EM is a successor in interest to the plant to UnionCarbide Corporation, Old Ridgebury Road, Danbury, Connecticut 06817, undera deed executed and recorded on June 30, 1981.

3. If any of the property owned by EM in the Fields Brooks waterbasin has been sold, leased or interests in said property otherwiseconveyed by EM to a third party or by a third party to EM, state thatparty's name and the dates of any conveyance or sale.

RESPONSE: See the answer to question 2. above.

4. Provide a legal description of any EM facilities located in theFields Brook water basin in Ashtabula County, Ohio.

RESPONSE: The legal description of EM's Plant site in AshtabulaCounty, Ohio is contained in the conveyance from Union Carbide Corporation,attached hereto as Exhibit "A".

5. Provide copies of any and all documents pertaining to the use andownership of any EM facility or property in Ashtabula, Ohio including, butnot limited to deeds, contracts, leases, subleases, purchase agreements andrelated correspondence.

RESPONSE: The property, its use and ownership is generallydescribed in Exhibit "A" attached hereto, which describes variousreservations and easements for third party rights. Operation of thefacility consists of currently two furnace operations producing variousgrades of ferrosilicon, magnesium ferrosilicon, and calcium carbide. Inthe course of its business EM procures raw materials, machinery andequipment, services, supplies and utilities, and sells its products, undervarious written agreements, licenses and permits which we presume are notgermane to U.S. EPA's inquiry. In addition, EM provides continuing on-siteservices to Union Carbide and to IMC Chemical Corporation under serviceagreements which commenced June 30, 1981 and continue to the present.These agreements are attached to this response as Exhibit "B"

successor \*\j nit \jn \ \j*\provide the following:

. EPA's understanding that Elkem Metals Company isnion Carbide Metals Division in Ashtabula, Ohio. Please

6. It is U.S. tKA's understanding that tto the Union Carbide Metals Divisione followina:

a. The date of acquisition.

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RESPONSE: June 30, 1981.

b. The nature of the acquisition.

RESPONSE: Asset purchase.

c. The products produced at the facility before and after theacquisition.

RESPONSE: See answer to question 2.

d. EM's position regarding its assumption of liability foractions arising out of operations at the plant by Union Carbide.

RESPONSE: EM's position with regard to liabilities regardingoperations conducted at the Ashtabula Plant prior to June 30, 1981 is thatsuch liabilities are retained by Union Carbide, and El kern is entitled toindemnity for them.

e. All documents regarding the change of ownership, including butnot limited to contracts, deeds, leases, subleases, purchase agreements andcorrespondence.

RESPONSE: Contractual documents regarding sale of theAshtabula Plant and related assets, excluding correspondence, arevoluminous and are contained in seven large volumes of documents located atEM's offices in Pittsburgh, Pennsylvania. Ue have included an excerpt fromthe Assets Purchase Agreements consisting of Section 11 thereof (Exhibit"C") which relates to liabilities of Seller and Buyer with respect tocertain environmental issues, and indemnification procedures. We have alsoincluded as a part of Exhibit C a listing of certain settlement ponds whichwere used or are used by Union Carbide or EM at the Ashtabula location.

7. Provide a list of all present and former plant managers,production managers and plant engineers at any of the above describedfacilities. Please state the date of their employment with EM, positionsheld and last known addresses. Also, please indicate the numbers Requestsregarding which they may have information.

RESPONSE:

Plant Managers:

T. W. Lopuszynski 7/1/81 - 3/1/831611 Winterhaven DriveAshtabula, OH 44004

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R. C. Ritter 3/1/83 - Present4024 Edgewater DriveAshtabula, OH 44004

Plant Superintendents:

R. H. Redline 7/1/81 - Present3535 Silvieus StreetAshtabula, OH 44004

H. R. Shoulders 7/1/81 - Present2101 Dearfield DriveAshtabula, OH 44004

C. E. Hemphill 7/1/81 - Present3314 South Maple LaneAshtabula, OH 44004

R. C. Mills 7/1/81 - 2/1/831309 Westminister Avenue (Retired)Ashtabula, OH 44004

8. Provide the names of any predecessor or successor corporations orpartnerships which owned or operated any EM facility, as described above,in Ashtabula County, Ohio.

RESPONSE: Union Carbide Corporation, Old Ridgebury Road, Danbury,Connecticut 06817.

9. On what date did EM commence operations of its facility at or nearLake Road in Ashtabula County, Ohio?

RESPONSE: June 30, 1981.

10. Provide any information you may have regarding contamination fromyour plant entering Fields Brook, or a tributary thereto, either directlyor indirectly.

RESPONSE: EM has no knowledge of any contamination enteringFields Brook or any tributary directly or indirectly, and maintains that nosuch discharge has been made since it assumed operation of the Plant in1981 nor, to its knowledge, prior to that time.

11. Provide any knowledge or information you may have regarding anyproperty owned by you in Ashtabula County, Ohio which may have beencontaminated by prior owners or users. Your response should include, butnot necessarily be limited to:

a. Name of prior owner or user.

RESPONSE: None. As stated above, the plant was owned byUnion Carbide Corporation prior to 1981, but EM has no knowledge ofcontamination by Union Carbide.

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b. Use of facility and property by prior owners or users.

RESPONSE: Principally the same as at present, except that thevolume of products produced by Union Carbide was considerably greater.

c. Disposal practices of prior owners or users.

RESPONSE: Union Carbide used EPA-approved settling ponds andsubstantially similar practices as EM for waste disposal.

d. Volume and nature of sources of such contamination.

RESPONSE: EM is not aware of any contamination of the FieldsBrook site by any predecessor owner.

12. Provide any information you have regarding sources ofcontamination of Fields Brook.

RESPONSE: None.

13. Provide the following information regarding any french drains orsewer lines (including storm), sanitary or combined sewers) which receiveor have received runoff or discharges from the property located near LakeRoad in Ashtabula County, Ohio:

a. The location and nature of each sewer line.

RESPONSE: All discharges including storm, sanitary, coolingwater and treated process wastewater are handled on plant property anddischarged to Lake Erie via NPDES permitted outfalls. EM property is notin the Fields Brook water basin.

b. Whether each sewer line is connected to the main trunk line.

RESPONSE: Not applicable.

c. Does any sewer line have direct or indirect access to FieldsBrook or a tributary thereof?

RESPONSE: All plant drainage is north to Lake Erie. No sewerline has direct or indirect access to Fields Brook or any tributary.

14. Provide the following information regarding any drainage ditcheswhich receive or have received runoff or discharges from the propertylocated near Lake Road in Ashtabula County, Ohio:

a. The location of each drainage ditch.

RESPONSE: The Russell Road ditch receives some surfacerun-off which is discharged to Lake Erie. Exhibit "D" shows theapproximate location of this ditch.

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b. Whether runoff or discharge from each drainage ditch hasdirect or indirect access to Fields Brook or a tributary thereof.

RESPONSE: Surface run-off has no direct or indirect access toFields Brook or any tributary.

c. Any information regarding the presence, or potential forreleases, of hazardous substances or constituents in the ditches.

RESPONSE: EMC is not aware of any presence, or potential forrelease, of hazardous substances or constituents in the surface run-off.

15. Does you company have, or did your company ever have, an NPDESpermit for discharges to Fields Brook or a tributary thereto? Pleaseidentify any such permits.

RESPONSE: No NPDES permit has ever been held by EM or itspredecessor for discharges to Fields Brook.

16. Describe each manufacturing process that EM has operated at eachof its Ashtabula County, Ohio facilities, including the facility on LakeRoad. For each facility and process provide the years that the operationsoccurred and all the raw materials associated with or relating to theprocess.

RESPONSE: EM's Ashtabula facility has produced lime, calciumcarbide, ferrosilicon, magnesium ferrosilicon and related specialty alloysfrom July 1981 - current.

Lime is produced by calcining limestone. Most of the lime is usedon site where it is charged, along with coke, to an electric submerged arcfurnace for the production of calcium carbide.

Ferrosilicon is produced from quartz (gravel), scrap steel, coke,coal, and woodchips in an electric submerged arc furnace.

Magnesium ferrosilicon is produced by the addition of magnesium tomolten ferrosilicon.

17. Describe each manufacturing process that Union Carbide operated atthe facility to which EM is a successor in Ashtabula County, Ohio. Foreach process provide the years that the operations occurred and all the rawmaterials associated with or relating to the process.

RESPONSE: Union Carbide operated the same processes which EM nowoperates. In addition, acetylene was produced from calcium carbide andacetylene black was produced from acetylene.

Ferromanganese and silicomanganese were also produced. Rawmaterials used were quartz, coke, manganese ore, and millscale.

Specific information on years that the Union Carbide operationsoccurred is not available; however, the approximate time period was between

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1950-1975, after which time the products produced at the plant weresubstantially the same as EM now produces.

18. Describe any hazardous substances that may have been contained inany by-products or wastes from each of the manufacturing processesdescribed in Request 16 and 17. Also describe the amounts of wastes,by-products or hazardous substances generated by each of such processes ona yearly basis.

RESPONSE: Wastewater from the calcium carbide and ferrosiliconproduction operations contains small amounts of phenol and cyanide. Thesematerials are destroyed by breakpoint chlorination in the NPDES permittedtreatment system. The NPDES permit allows some discharge of the materialsto Lake Erie and the plant maintains compliance with the requirements.

A report prepared by U.S. EPA by Research Triangle Institute (EPAContract No. 68-02-3152, Task No. 7, August 1983) concerning the EMCwastewater treatment system states that our discharge contains little to noconcentration of any priority pollutants.

19. Describe the storage, treatment and disposal practices for anyby-products or wastes associated with each of the manufacturing processesdescribed in response to Request 15 and 16. This description shouldidentify any use of drums, tanks, lagoons, ponds, wastepiles, ditches,marshes, swamps, land treatment or disposal areas, public sewers,landfills, creeks, or waterways used or affected by such practices.

RESPONSE: See Exhibit "E" - Waste Water Treatment Block Diagram.

20. Describe the nature of any records and recordkeeping practicesthat have ever been maintained relating to any storage, treatment ordisposal practices for any by-products or wastes associated with eachmanufacturing process in response to Requests 16 and 17.

RESPONSE: EM records such as wastewater treatment, waste sol idsstorage, and NPDES permit reports are available since July, 1981.

21. Describe each chemical reclamation process that EM has operated atits Ashtabula, Ohio facilities. For each process state the years duringwhich operation of the process occurred, the type of process equipmentused, the types of chemical associated with each reclamation process andthe volume processed annually by each process.

RESPONSE: The plant has not operated any chemical reclamationprocess.

22. Describe the nature of any records and recordkeeping practicesthat have ever been maintained relating to the characteristics and natureof the wastes or by-products described in response to Request 21.

RESPONSE: Not applicable.

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23. Describe the characteristics and nature of wastes or by-productsassociated with each reclamation process. Such description should includeany characteristic or listing that such waste would likely have under 40CFR Part 261. The description should also include any hazardous substancesthe waste would likely contain.

RESPONSE: Not applicable.

24. Describe the nature of any records and recordkeeping practicesthat have ever been maintained relating to the characteristics and natureof the wastes or by-products described in response to Request 23.

RESPONSE: Not applicable.

25. Describe the practices and conditions relating to the storage ofhazardous wastes or hazardous substances upon their arrival at EMfsAshtabula County, Ohio facilities, until the time of their reclamation.Such a description should include, along with any dates when anysignificant changes occurred:

a. what types of wastes were/are stored in drums,

b. what types of wastes were/are stored in tanks.

c. what type of containment system for spills or releaseswere provided at the storage areas.

d. the location of any storage areas.

e. whether drums have been marked with the generator ortransporter's name.

f. whether hazardous waste from more than one source wereever mixed or commingled together in a tank. How frequent was thispractice? Did this include emptying drums into tanks?

g. what was the practice regarding the cleanup of spilledmaterials from these stored hazardous wastes.

h. did spills or releases (including those caused by fire) ofthese materials ever occur while they are awaiting processing.

i. whether such wastes were ever stored in lagoons or ponds,

j. what types of such wastes were stored in lagoons or ponds.

k. what types of liners or any other impervious barriers did'lagoons or ponds have to prevent release of the materials.

1. what types of wastes, if any, were ever stored in wastepiles.

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m. what records and recordkeeping practices have ever beenmaintained on storage. What is the state of those records?

RESPONSE: The plant does not accept hazardous wastes orsubstances from others for recycling, treatment or disposal.

26. Describe EM's practices relating to the disposal and treatment ofstill bottoms sludges and other non-reclaimed materials accumulated in anyreclamation process itself. Please include in such a description, alongwith the dates for different practices:

a. whether the non-reclaimed materials were drummed up fordisposal.

b. If such non-reclaimed materials were drummed up, whether theywere normally (or necessarily) put back in the drums of the seller fromwhom they originated.

c. whether the non-reclaimed material was allowed to accumulateand was stored prior to treatment or disposal.

d. the locations and types of storage areas used for storage ofthe non-reclaimed materials. Examples of types of storage areas couldinclude drums, tanks, pits, wastepiles, ponds or lagoons.

e. any containment systems utilized at these storage areas tohelp prevent releases of the stored material to the environment.

f. whether any spills or releases of these stored materials everoccurred. Approximately when.

g. where and how such materials were disposed.

h. what records and recordkeeping practices that have ever beenmaintained in regard to the above practices.

RESPONSE: Not applicable because EM does not generatestill-bottom sludges or other non-reclaimed materials.

27. Describe practices relating to any incineration processes used fordisposal of wastes from each of EM's Ashtabula, Ohio facilities. Thisdescription should include:

a. the location and years during which each incinerator operated,

b. the rated capacity for each incinerator.

c. the normal operating and peak temperature for eachincinerator.

d. the rated retention time for materials during the burn.

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e. the type of fuel used to bring the incinerator up to operatingcapacity,

f. how the material was fed to the incinerator.

g. what types of operating records were kept includingtemperature and feed rate.

h. the types of air pollution control devices that were installedon each incinerator and stock test results.

i. whether any misting or raining from the incinerator stacksever occurred.

j. what quantities of incinerator ashes or sludges were generatedfrom the incineration processes.

k. what types of materials and volumes were burned in theseincinerators.

1. were any PCBs known to have been burned in these incinerators.

m. did the materials that were burned include non-reclaimablematerials from stills.

n. was materials from stills accumulated and stored prior toincineration.

o. did the materials sent to DS, include materials sent theresolely for purposes of incineration.

p. were materials sent to EM for incineration on occasionotherwise disposed. How and why?

q. how and where were by-products of the incineration process(including ash bottoms, flysash, sludges and scrubber water) disposed.

r. any records and recordkeeping practices that have beenmaintained relating to the described practices. What is the state of thoserecords?

RESPONSE: Not applicable because EM does not incinerate anymaterials.

28. Has EM ever observed any leachate escaping or being released fromany storage or disposal areas on product owned or operated by EM inAshtabula County, Ohio? If so describe the physical characteristics ofthe leachate such as color, odor or viscuousness. When and by whom hasthis been observed?

RESPONSE: Leachate from waste storage areas is collected andpumped to the process wastewater treatment system prior to discharge to

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Lake Erie via NPDES permitted outfall. The leachate has no color, odor orviscousness.

29. Do you have any information indicating that leachate from any ofthe storage or disposal areas on property owned or operated by EM may haveescaped or been released into surrounding ditches, Fields Brook, or atributary thereto? If so, please state it and include when suchoccurrences took place and who observed them.

RESPONSE: To the best of our knowledge no such leachate has everescaped or been released.

30. Have soil samples been collected and analyzed or monitoring wellsever been installed in or adjacent to the property near Lake Road,Ashtabula County, Ohio, to monitor for releases of pollutants or hazardouswaste constituents? If so, please provide any data you have from suchmonitoring activities.

RESPONSE: Soil samples have not been collected. Groundwatermonitoring wells were installed during 1979-1980. Exhibit "F" presents asketch of the monitoring well locations and designations. A report,prepared for Union Carbide Corporation by Engineering-Science, Inc. datedJune 1980 has been furnished to Ohio EPA's Twinsburg, Ohio office.Monitoring data obtained during the period 1980-1982 indicated minimumimpact from release of pollutants from the Union Carbide-Elkem Metals site.

31. Describe any location on the EM property located in the FieldsBrook water basin at which wastes from EM operations have been disposed.Please state the approximate time of disposal, the types of materials,their chemical characteristics and volumes involved. Also, provide anyinformation you have regarding sample analyses that have been conducted ofmaterials in or adjacent to any other locations on the EM property at whichwastes from EM or Union Carbide operations have been disposed.

RESPONSE: EM property is not in the Fields Brook water basin .All drainage flows away from the Fields Brook water basin; northward towardLake Erie. On-site waste disposal is far to the north of the Fields Brookarea.

32. Describe the location and size of each lagoon, pond, wastepile,trench or pit that has existed on the EM Lake Road property and itspurpose. For each lagoon, pond, wastepile, trench or pit discribe:

a. Any hazardous substances that may be or have been contained inthem.

b. The dates of each structure's existence and use.

c. Any construction properties of each pit, pond, wastepile,trench or lagoon which would help prevent the release of materials from it.

d. If not in use now, explain how it was closed or has beenmodified and the present use of the area.

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e. Any pictures, sketches or maps of these facilities.

RESPONSE: Exhibits "D" and "E" show the plant waste treatment andstorage locations. Details are as follows:

Ponds 1, 1A, and 2

Constructed in 1950 and extended in 1953.Have not been in use since 1978.

Area: Ponds 1 and 1A - 8+ acresPond 2 - 21+ acres

These areas contain calcium hydroxide, calcium carbonate,and hydrous oxides of iron and copper.

Pond 3

Constructed in 1946 and closed during 1981 with a claycover and seeding.

Area: 39 acres with a volume of 2,488,000 yards.

This area contains calcium hydroxide, calcium carbonate,fly ash, plant refuse, ferroalloy furnace scrubber sludge,hydrous titanium dioxide and solium chloride.

Pond 3A

Constructed in 1967 and still in use.

Area: 28 acres

This area contains ferroalloy and calcium carbide furnacescrubber sludges, slurried fume from ferrosiliconproduction, and lime kiln scrubber sludge. Componentsof these materials are calcium hydroxide, calcium carbonate,silica, iron oxides, and carbon.

Pond 4 Complex for Process Wastewater Treatment

Constructed in 1977 and still in use.

Area: 15 acres, depth of 18 feet.

This area contains calcium carbide and ferrosiliconfurnace scrubber sludge and slurried baghouse solids.

33. Provide the name of each customer from whom EM has receivedhazardous substances for purposes of treatment or disposal, including,incineration or reclamation. Further provide any information you have onthe kinds of wasts received, the quantity of each kind of waste received,

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b. the disposal locations used by Reserve Environmental Servicesfor residues, rinse water and solid wastes generated by their operations.This description should include location both on and off their properties.

c. the disposal locations for any drums discarded by the company.

d. the estimated quantity of drums and waste residue disposed ofat each location by the company.

e. whether the company received drums from persons other than EMfor cleaning.

RESPONSE: EM has no information concerning the disposal ofhazardous substances from operations at Reserve Environmental Services,Inc.

We believe this response answers in full and to the best of ourknowledge and belief all the questions contained in your most recent letterto EM dated May 16, 1986. However, we have not notarized or certified theanswers as requested in the letter because we cannot find any requirementto this effect under either CERCLA or RCRA. We are unable to visualize anyreason why USEPA has designated EM as a Potentially Responsible Party otherthan the proximity of its extensive Plant site to Fields Brook, and wesubmit that this is not a basis on which to draw such a conclusion,tentative as it may be. We respectively request that you withdraw thedesignation on the basis of information supplied in this letter.

Yours very truly,

TT, -PV^jAXu - W TU^Francis A. King, Esq. \General Counsel *

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the processes used by EM in handling these wastes, the period during whicheach kind of waste was received and processed and the likely disposition ofany residues from that process.

RESPONSE: EM has not received hazardous substances from customersfor purposes of treatment or disposal, including incineration orreclamation.

34. Provide copies of any documents that you now have that containinformation indicating the receipt of hazardous wastes for reclamation,incineration, or other treatment by EM. Such documents would include,logs, invoices, bills of lading, purchase orders, work orders, truckingrecords, correspondence, contracts or other agreements.

RESPONSE: Not applicable.

35. Provide the names of all other off-site facilities that have beenused by EM for the disposal of unreclaimed chemical wastes and hazardouswastes, incineration process wastes and manufacturing process wastes.Provide the dates during which such disposal has occurred and the kinds ofwastes sent to each facility.

RESPONSE: Off-site facilities used by EM for waste disposal:

Asherty Landfill, Geneva, Ohio — 1981-Current

Hauler: Tanner Trucking, Ashtabula, Ohio

Wastes: Miscellaneous plant clean-up, ferroalloy and calciumcarbide furnace dig-out and other furnace room scrapand small scrap steel items (large scrap steel itemssent to Ashtabula Salvage).

Northeastern Disposal Company, Thompson, Ohio — 1981-Current

Hauler: Northeastern Disposal Company

Wastes: Plant refuse and garbage hauled via containers.

Cecos International, Inc., Cincinnati, Ohio -- 1981-Current

Hauler: Cecos International, Inc.

Wastes: PCB oil or PCB contaminated oil or electricalequipment.

36. Describe any information EM may have obtained regardingcontaminated fill material or debris deposited in or near Fields Brook orits tributaries. Such should include any information regarding fillallegedly disposed by Brenkus Excavating at or near the residence of SandraHer!, 935 East 19th Street, Ashtabula, Ohio.

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RESPONSE: EM has no information regarding contaminated fillmaterial or debris deposited in or near Fields Brook or its tributaries.

37. Provide a list and description of all liability insurance coveragethat is or was carried by you or any predecessor or successor corporationsor partnerships including any self-insurance provisions that relate tohazardous substances and/or the above referenced sites. Provide copies ofall of these insurance policies.

RESPONSE: See Exhibit "G". Copies of the insurance policies arenot attached due to the bulk, but are available for inspection.

38. Provide any information you have regarding the waste disposalmethods utilized by any surrounding property owners or users.

RESPONSE: EM has no information regarding the waste disposalmethods utilized by any surrounding property owners or users,

39. Has EM disposal or arranged for the disposal of any materials inthe Reserve Environmental Services, Inc. disposal facility located inAshtabula County, Ohio? If so, please state:

a. When the disposal occurred.

b. The nature of the solid wastes.

c. The nature of the liquid wastes.

d. Whether the wastes contained hazardous substances.

e. The amount of wastes involved.

f. If known, where at the Reserve disposal for the disposalfacility the wastes were disposed.

g. Describe all terms of any arrangement for the disposal ofthese materails.

h. What records, if any, have ever been maintained documentingsuch disposal and arrangements for the disposal? What is the state ofthose records?

RESPONSE: EM has never disposed or arranged for disposal of anymaterials in the Reserve Environmental Services, Inc. facilities.

40. Provide any information that you have concerning the disposal ofhazardous substances from operations at Reserve Environmental Services,Inc. including:

a. description of the method of operations at the site (e.g.howdrums were rinsed, materials used in drum cleaning, methods disposal ofwaste residues from drums, disposal of rinse water, etc.)

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