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Fact Sheet
Hazardous Waste Permit
Ash Grove Cement Company
Chanute, Kansas
August, 1996
BACKGROUND: The U.S. Environmental Protection Agency (EPA) and the Kansas Department of Health and Environment (KDHE) have issued a permit to the Ash Grove Cement Company in Chanute, Kansas. The permit allows Ash Grove to continue storing hazardous wastes in tanks and containers and burning the wastes for fuel in their two cement kilns at the Chanute plant. The permit, issued under the Resource Conservation and Recovery Act (RCRA), also requires Ash Grove to look for possible hazardous waste releases to the environment from past waste management practices.
AGENCY ROLES: KDHE is responsible for ensuring that Ash Grove adheres to RCRA requirements for storing hazardous wastes (Part 1 of the permit). EPA is responsible for ensuring that Ash Grove complies with RCRA requirements for burning hazardous wastes and investigating past waste management practices (Part 2 of the permit).
COMMENTS ON DRAFT PERMIT: EPA and KDHE received comments on a variety of issues related to the draft permit, such as air emissions, health concerns, risk assessment, cement kiln dust and environmental monitoring. All comments were reviewed and considered in making permit revisions.
EPA concluded during the review that more restrictive limitations on metals emissions were necessary to protect human health and the environment. This decision was based on the multi-pathway risk assessment that evaluated maximum emission rates of toxic metals for Ash Grove. There- fore, the final permit restricts how much metal can be in the hazardous wastes burned by Ash Grove to less than existing regulations would have allowed.
The revised permit requires Ash Grove to conduct environmental monitoring at Santa Fe Lake and Allen Lake to better evaluate the effect of the facility's emissions on the environment, with a focus on characterizing mercury levels in fish tissue. It also requires Ash Grove to conduct periodic surface soil sampling for mercury and thallium.
Many comments were received on the multi-pathway risk assessment of air emissions that EPA prepared. EPA, in response to those comments, performed additional risk calculations and formally documented its analysis of potential health risks from fugitive emissions associated with hazardous waste storage tanks. EPA and KDHE continue to believe that the risk assessment is a valid measure of the potential health risks posed by burning hazardous wastes at Ash Grove.
EPA is in the process of writing revised regulations on controlling emissions from hazardous waste burners. Emission rate limits include standards for toxic metals and organic compounds. Ash Grove will be required to revise this permit when the new standards for hazardous waste combustors become effective.
Comments about management of cement kiln dust (CKD) were also received. KDHE, which regulates CKD disposal though an industrial solid waste landfill permit, responded to the comments by requiring Ash Grove to prepare and implement a more thorough fugitive dust control plan at its CKD disposal area. KDHE has also required Ash Grove to help avoid surface water contamination by improving its controls on rain seeping through the CKD disposal area.
Citizens of the Chanute area and other parts of southeast Kansas have expressed concern about the potential effects of several facilities burning hazardous waste in this part of the state. EPA believes that the Ash Grove permit is protective of human health and the environment. However, to better address citizen concerns, EPA is initiating a health study to provide additional assurance that this is the case. EPA will share information on the health study as it becomes available.
PERMIT APPEAL: Any appeal of the EPA and KDHE decision to issue a permit or deny a permit application must be made within 30 days of the time the final decision is issued. Procedures for appealing the permit decision may be found in 40 Code of Federal Regulations Part 124. A fact sheet on the permit appeal process is also available.
