Siemens Carbon Regeneration Facility
(formerly US Filter Westates)

Frequent Questions and Background Information

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What is spent carbon?
Are there air emissions from Siemens?
Is there wastewater discharge from Siemens?
Are hazardous waste operations at Siemens subject to regulatory control?
What other regulatory controls is Siemens subject to?
What is the time frame for EPA's permit decision?
Have there been any spills at Siemens?
What is Siemens' compliance history?
Are there other carbon regeneration facilities in the United States?

What is spent carbon?

Spent carbon is a granular material used in filtering systems to purify air and water. Contaminants adhere to (or stick to) the carbon, and so are removed from the air or water. When the carbon is no longer able to purify the air or water, it is called “spent” carbon. At Siemens, the spent carbon is heated to high temperatures in a carbon regeneration furnace. This process removes most of the contaminants and reactivates the carbon. The reactivated carbon can be sold as a commercial product to be reused in filtering systems. Information about the spent carbon that Siemens receives can be found in EPA’s fact sheet: Hazardous Waste at Westates (PDF), 2 pp, 50 K).

Are there air emissions from Siemens?

Yes. Tests conducted by Siemens indicate that air emissions from the furnace stack contain contaminants such as dioxins, metals, and hydrogen chloride. More information about the stack emissions can be found in EPA's fact sheet: Air Emissions from Westates (PDF) (2 pp, 60K). Agency for Toxic Substances and Disease Registry (ATSDR) has information about the health effects of contaminants.

Is there wastewater discharge from Siemens?

Yes. Siemens discharges waste waters that are generated during the carbon regeneration process. Most of the waste waters come from air pollution control devices at Siemens. The air pollution control devices remove most of the contaminants from the stack gases before the gases are released to the air. Siemens has installed a new wastewater treatment system which is designed to reduce the amount of contaminants in the wastewater before it is discharged to the local sewer system. More information about wastewater discharge can be found in EPA’s fact sheet: Wastewater at Westates (PDF) (2 pp, 54K).

Are hazardous waste operations at Siemens subject to regulatory control?

Yes. Siemens is subject to regulatory control under the Resource Conservation and Recovery Act (RCRA). RCRA is a federal statute governing the operation of hazardous waste facilities. Under RCRA, Siemens must conduct an air emissions test, and must submit a permit application to EPA. EPA is also requiring Siemens to perform a human health risk assessment and an ecological risk assessment. Using this information, EPA will make a permit decision at Siemens. The permit decision could be a permit denial, or issuance of a permit to allow Siemens to continue operating. For a complete description of the permitting process, see The Hazardous Waste Permitting.

Until EPA makes a permit decision, Siemens must comply with interim status regulations. Interim status is a temporary authorization to operate until EPA makes a final permit decision. Interim status regulations contain general requirements for Siemens to operate safely. EPA’s fact sheet provides details about the process: Permitting Process at Westates (PDF) (2 pp, 48K).

What other regulatory controls is Siemens subject to?

Siemens is also subject to the Clean Air Act, the Clean Water Act, and the Emergency Planning and Community Right-to-Know Act (EPCRA). Under the Clean Air Act, Siemens must report estimated air emissions of certain contaminants annually to EPA. Under the Clean Water Act, Siemens must treat waste waters before discharging them to the local waste water treatment system, and must have a storm water management plan. Under EPCRA, Siemens must provide information to local emergency response agencies about hazardous materials stored at the facility. Under the Toxic Release Inventory (which is part of EPCRA), Siemens must report to EPA releases of certain contaminants. For general information about each of these regulatory programs, see the following web pages:

What is the time frame for EPA's permit decision?

Siemens conducted their air emissions test in March 2006 and submitted a revised Part B Permit Application in February 2007. Siemens submitted their human health and ecological risk assessment to EPA in late July 2007.

USEPA submitted comments to the Siemens facility on the Part B application in September 28, 2011 and comments on the Closure Plans and the Financial Assurance mechanism on December 14, 2011. Siemens is in the process of revising the Part B application to incorporate USEPA’s both sets of comments into the Part B application. The revised Part B is due to USEPA on April 30th, 2012.

Once EPA receives the revised permit application and reviews it, we will determine if the permit application is complete and technically accurate, EPA will make a proposed decision on whether to deny or grant the permit and open a 45 day Public Comment Period.

Have there been any spills at Siemens?

Yes. Siemens has reported four spills since they began operating in 1992. Siemens reports that these spills were controlled soon after they occurred, and that Siemens removed affected soils and sampled remaining soils where necessary. Information about the spills and emergency response can be found in EPA’s fact sheet: Emergency Response at Westates (PDF) (2 pp, 60K).

What is Siemens' compliance history?

Between 1992 (Siemens’ first year of operation) and 2000, EPA inspected the facility 8 times. In 1993, EPA found many violations, and required Siemens to pay a fine. From 1994 through 1998, EPA found few violations at Siemens. A summary of violations and EPA's enforcement actions from 1992 through 2000 appears in EPA’s fact sheet: Compliance History of Westates, 1992 - 2000 (PDF) (2 pp, 76K).

Beginning in 2001, EPA has conducted 6 inspections or site visits at Siemens. A summary of EPA inspections from 2001 through 2003 appears in EPA's fact sheet: Compliance History of Westates 2001 - 2003 (PDF) (2 pp, 39K).

On June 30, 2006, EPA issued a Consent Agreement / Final Order (CA/FO) to Siemens. This order listed alleged violations in three counts. Count 1 notes Siemens storing discarded samples of hazardous waste in an open drum. Count 2 notes failure of Siemens to record the presence of cracks in their secondary containment pads, and failure to remedy the cracks. Count 3 notes failure of Siemens to provide sufficient capacity in one of their secondary containment pads. The CA/FO requires three compliance tasks. Within 180 days of the CA/FO, Siemens must install approved secondary containment in one area of the facility and must replace an existing tank with a double-walled tank. In addition, within 45 days of the CA/FO, Siemens must submit to EPA inspection procedures they will follow for inspections of their tanks and ancillary equipment. The CA/FO requires Siemens to pay a fine of $27,059 within 30 days of the CA/FO. Siemens completed installing the approved secondary containment in November 2006 and replaced an existing tank with a double-walled tank in February 2007.

Full text of the Consent Agreement / Final Order (CA/FO) dated June 30, 2006 (PDF). (16 pp, 545K)

The following inspection reports provide more information about recent inspections at Siemens:

EPA's Inspection Report from the June 2001 Inspection (PDF) (16 pp, 108K)
EPA's Inspection Report from the January 2002 Inspection (PDF) (7 pp, 17K)
EPA's Inspection Report from the August 2002 Inspection (PDF) (9 pp, 77K)
EPA's Inspection Report from the March 2003 Inspection (PDF) (5 pp, 60K)
EPA's Inspection Report from the February 2004 Inspection (PDF) (6 pp, 48K)
EPA Inspection Report from the September 2007 Inspection (PDF) (5 pp, 657K)
EPA Inspection Report from the June 2009 Inspection (PDF) (10 pp, 1.2M)

Are there other carbon regeneration facilities in the United States?

In addition to Siemens, there are five other carbon regeneration facilities that treat hazardous spent carbon currently in operation in the U.S. Three additional carbon regeneration facilities have been proposed for operation.