Docstoc

February James Bachmann Plant Manager Lafarge Building

Document Sample
February James Bachmann Plant Manager Lafarge Building Powered By Docstoc
					                                                   Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703




February 11, 2011


James Bachmann, Plant Manager
Lafarge Building Materials, Inc.
2609 N. 145th East Avenue
Tulsa, OK 74116


       Re:     Proposed Operations Permit #064558703 for Hazardous Waste Management,
               Lafarge Building Materials, Inc. Tulsa Cement Plant, EPA I.D. #OKD064558703

Dear Mr. Bachmann:

Enclosed please find the Proposed Operations Permit #064558703 for Hazardous Waste
Management (Proposed Permit) prepared by the Land Protection Division (LPD) of the
Oklahoma Department of Environmental Quality (DEQ) for the Lafarge Building Materials, Inc.
Cement Plant (Lafarge). The LPD has prepared this proposed permit as required by 27A OS § 2-
14-304.C.1. The text is unchanged from the language of the draft permit which was provided to
you by a cover letter dated November 10, 2010.

A forty-five day public comment period for the draft permit was announced beginning December
6, 2010 and ending January 21, 2011. Comments were received at a public meeting in Catoosa on
January 13, 2011 and by fax, mail and E-Mail at the LPD. A number of adverse comments were
received. After review and consideration by the DEQ, it was determined that none of the
comments received were relevant to the permit conditions and no changes were made to the permit
language.

The next step in the Tier 3 permitting process is a 20 day opportunity to request an administrative
hearing to be published via legal notice in a local newspaper of general circulation. If desired, this
notice may be combined with the notice of opportunity for the adjacent Systech Environmental
Corporation facility. Attached is a suggested draft of the notice language. This letter and the
enclosed documents are to be made available for public review in the same manner as the permit
application and Draft Permit.

Please notify us of the date of publication of the notice, and provide a Proof of Publication for our
records. We will advise you if a request for hearing is received.




                                                I-1
                                                 Lafarge Building Materials, Inc.
                                                   EPA ID #OKD064558703


Please direct any questions to J. David Lawson of my staff at (405) 702-5104.

Sincerely,



Scott Thompson, Director
Land Protection Division

ST/dah

Enclosures

Copy to:       Terri Kanouse – Systech
               Bob Schreiber – Schreiber Yonley & Associates
               David Vogler – USEPA Region 6 (6PD-O)
               Phillip Fielder – Air Quality Division, DEQ (Without Enclosure)
               Monty Elder – Customer Service Division, DEQ (Without Enclosure)




                     Lafarge Building Materials, Inc.
                                 Tulsa Cement Plant

      PROPOSED OPERATIONS PERMIT #064558703
                                              For
                                               I-2
                                                 Lafarge Building Materials, Inc.
                                                   EPA ID #OKD064558703



                     Hazardous Waste Management


                                       PREPARED BY

       OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

                             LAND PROTECTION DIVISION

                             RELEASEDFOR PUBLIC NOTICE ON

                                       February 11, 2011




              OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
                            OPERATIONS PERMIT
                FOR A HAZARDOUS WASTE MANAGEMENT FACILITY


EPA ID#:       OKD064558703                                Permit Number:         0645558703
Permittee:     Lafarge Building Materials, Inc. Tulsa Cement Plant, Tulsa, Oklahoma

Effective Date of Permit:            to be determined
Expiration Date of Permit:           to be determined

Pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery
Act of 1976, as amended (42 USC 6901 et seq., commonly known as RCRA), including the
Hazardous and Solid Waste Amendments of 1984 (HSWA), and regulations promulgated
thereunder by the U.S. Environmental Protection Agency (EPA) (codified and to be codified in Title
40 of the Code of Federal Regulations) and the Oklahoma Hazardous Waste Management Act (27A
O.S. 2000, §§2-7-101 et seq.) and regulations promulgated thereunder, a permit is issued by the
Land Protection Division of the Oklahoma Department of Environmental Quality (Department) to

                                               I-3
                                                  Lafarge Building Materials, Inc.
                                                    EPA ID #OKD064558703


Lafarge Building Materials, Inc. Tulsa Cement Plant (hereafter called the Permittee). The permit
specifies procedures for the handling of hazardous waste used as fuel in the cement kilns. The
facility is located at 2609 N. 145th East Avenue in Tulsa, Oklahoma at latitude 36°11’38” North and
longitude 95°48’ 42’' West, summarily described as follows: parts of Sections 15, 21,22, 27 and 28,
Township 20 North, Range 14 East, Indian Meridian, Tulsa and Rogers County, Oklahoma.

Lafarge Building Materials, Inc. owns and operates a cement plant and office complex at the above
location in Tulsa, Oklahoma and has air quality permits, an NPDES permit, a solid waste permit and
a hazardous waste permit and is a permitted TSD facility.

The Permittee must comply with all terms and conditions of this permit. This permit consists of the
conditions contained herein (including those in any attachments), and the applicable regulations
contained in 40 CFR Parts 124, 260 through 264, 266, 268, and 270, as specified in the Permit.
Applicable regulations are those which are in effect on the date of issuance of the permit, in
accordance with 40 CFR 270.32(c). Primary responsibility for the enforcement under RCRA of the
provisions of this Permit shall lie with the Department.

This permit is based on the assumption that all the information submitted in the Part B permit
application and other previous reports and submittals to the Department are accurate. Any
inaccuracies found in the submitted information may be grounds for the termination, revocation and
reissuance, or modification of this permit in accordance with 40 CFR 270.41, 270.42, and 270.43
and for enforcement action.




                                               I-4
                                                  Lafarge Building Materials, Inc.
                                                    EPA ID #OKD064558703




This permit is effective as of February 11, 2011 and shall remain in effect until February 11, 2021
unless revoked and reissued under 40 CFR 270.41, terminated under 40 CFR 270.43, or continued
in accordance with 40 CFR 270.51(a), and Title 252, Oklahoma Administrative Code, Chapter 205,
Hazardous Waste Management (OAC 252:205), otherwise known as the Department's Hazardous
Waste Management Rules, and the Oklahoma Administrative Procedures Act 75 O. S. §§ 250 et
seq.


________________________________________________________
Saba Tahmassebi, Chief Engineer                  Date
Land Protection Division
Oklahoma Department of Environmental Quality


________________________________________________________
Scott Thompson, Division Director                Date
Land Protection Division
Oklahoma Department of Environmental Quality


________________________________________________________
Steven A. Thompson, Executive Director           Date
Oklahoma Department of Environmental Quality




                General Permit Conditions

 Section
 I
 A.             General……………………………………………………………………………                                           I-1
                …………
 B.             Basis of                                                                       I-1
                Permit………………………………………………………………………………
 C.             Incorporation by                                                               I-1
                Reference…………………………………………………………………
 D.             Definitions…………………………………………………………………………                                        I-1
                ………..

                                               I-5
                                          Lafarge Building Materials, Inc.
                                            EPA ID #OKD064558703


E.            Effect of                                                      I-4
              Permit……………………………………………………………………………..
F.            Permit                                                         I-4
              Actions……………………………………………………………………………
              …
G.            Severability………………………………………………………………………                        I-5
              ………….
H.            Duties and                                                     I-5
              Requirements……………………………………………………………………
I.            Signatory                                                      I-11
              Requirements……………………………………………………………………..
J.            Reports, Notifications and Submissions to the                  I-11
              ODEQ……………………………………...
K.            Confidential                                                   I-11
              Information……………………………………………………………………
L.            Documents to be Maintained at the                              I-11
              Facility………………………………………………...




Section
              General Facility Conditions
II
A.            Design and Operation of                                        II-1
              Facility……………………………………………………………
B.            Required                                                       II-1
              Notices……………………………………………………………………………
C.            General Waste                                                  II-1
              Analysis…………………………………………………………………….
D.            Security……………………………………………………………………………                          II-2
              ………...
E.            General Inspection                                             II-2
              Requirements…………………………………………………………...
F.            Personnel                                                      II-2
              Training…………………………………………………………………………..
G.            Special Provisions for Ignitable, Reactive, or Incompatible    II-2
              Waste………………………...
H.            Preparedness and                                               II-2
              Prevention………………………………………………………………..
I.            Contingency                                                    II-3
              Plan……………………………………………………………………………
J.            Manifest                                                       II-3
              System…………………………………………………………………………….
K.            General Closure                                                II-4
              Requirements……………………………………………………………...


Section III   Hazardous Waste Burning
A.            Section                                                        III-1

                                        I-6
                                      Lafarge Building Materials, Inc.
                                        EPA ID #OKD064558703


          Highlights………………………………………………………………………….
          .
B.        Permitted and Prohibited Waste                                      III-1
          Identification……………………………………………..




          Special Conditions Pursuant to the 1984
Section   Hazardous and
IV
                Solid Waste Amendments (HSWA)
A.        Preamble and General Comments to HSWA Conditions, Including Solid
          Waste Management Units and Their                                    IV-1
          Status………………………………………………………...
B.        Required RFI                                                        IV-2
          Activities……………………………………………………………………..
C.        Required Corrective Measures                                        IV-2
          Implementation…………………………………………….
D.        Standard                                                            IV-2
          Conditions…………………………………………………………………………
E.        Specific Condition – Closure and Post Closure...                    IV-7
          …………………………………………..
F.        Specific Condition – Information                                    IV-7
          Repository……………………………………………….
G.        Specific Condition – Investigation of Area(s) of                    IV-7
          Concern………………………………….
H.        Corrective                                                          IV-7


                                    I-7
                                       Lafarge Building Materials, Inc.
                                         EPA ID #OKD064558703


          Action……………………………………………………………………………
I.        Reporting                                                          IV-12
          Requirements…………………………………………………………………….
J.        Notification Requirements for and Assessment of Newly-Identified
          SWMUs                                                              IV-13
          and Potential
          AOCs…………………………………………………………………………
K.        Notification Requirements for Newly-Discovered Releases
          at SWMU(s) and                                                     IV-14
          AOC(s)…………………………………………………………………..
L.        Interim                                                            IV-14
          Measures…………………………………………………………………………
          …
M.        RFI                                                                IV-15
          Workplan…………………………………………………………………………
          …….
N.        RFI                                                                IV-17
          Implementation……………………………………………………………………
          ……
O.        RFI Final Report and                                               IV-17
          Summary…………………………………………………………….
P.        Determination of No Further                                        IV-18
          Action………………………………………………………..
Q.        CMS                                                                IV-18
          Plan………………………………………………………………………………
          ……
R.        CMS                                                                IV-19
          Implementation……………………………………………………………………
          …..
S.        CMS Final Report and                                               IV-20
          Summary……………………………………………………………
T.        Corrective Measure (Remedy) Selection and                          IV-21
          Implementation……………………………...
U.        RFI Scope of                                                       IV-21
          Work………………………………………………………………………….
V.        CMS Scope of                                                       IV-36
          Work………………………………………………………………………...

Table 1   RFI/CMS Submission Summary




                                    I-8
                                                     Lafarge Building Materials, Inc.
                                                       EPA ID #OKD064558703




LIST OF ATTACHMENTS

           Attachment
       1…………………               Waste Analysis Plan
Attachment
2…………………                      Procedures to Prevent Hazards
Attachment
3…………………                      Personnel Training
Attachment
4…………………                      Hazardous Waste Contingency Plan
Attachment
5…………………                      Closure Plan




               SECTION I – GENERAL PERMIT CONDITIONS


A.      GENERAL

The Permittee shall monitor and maintain the facility in compliance with all conditions of this Operations
Permit (“Permit”) approved by the Oklahoma Department of Environmental Quality (ODEQ), and with
applicable requirements of the Oklahoma Hazardous Waste Management Act (“OHWMA”), 27A O.S. §
2-7-101 et seq. and the rules promulgated thereunder at Oklahoma Administrative Code (“OAC”)
252:205, incorporating the requirements of the Federal Hazardous Waste Management Regulations, 40
CFR Parts 260-279 (familiarly known as “RCRA”).

B.      BASIS OF PERMIT

This Permit is granted based on the information submitted and the design criteria presented in the
Application. Any inaccuracies found in this information could provide cause for the termination or
modification of this Permit, and for enforcement action. The Permittee is to inform the Land
Protection Division of the Oklahoma Department of Environmental Quality of any deviation from
or changes in the design or operation of the facility which could affect the Permittee's ability to
comply with the applicable regulations or Permit Conditions.


                                                  I-9
                                                       Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


The term of this Permit is ten years. However, this Permit shall be reviewed by the ODEQ five
years after the date of permit issuance and shall be modified as necessary, as provided in 40 CFR
270.41 and OHWMA § 2-7-127(B). Except as provided in condition I.F.3. (40 CFR 270.51) the
term of this Permit shall not be extended by modification beyond the expiration date appearing
on the face of this Permit (40 CFR 270.50(b)).


C.      INCORPORATION BY REFERENCE

All the referenced Code of Federal Regulations (40 CFR) Parts 124, 144, 146, 260 through 266, 268, 270,
273 and 279 as specified in the Permit are, unless otherwise stated, incorporated in their entirety by OAC
252:205-3-1 through OAC 252:205-3-6 and OAC 252:652-1-3.

D.      DEFINITIONS

For purposes of this Permit and the special conditions pursuant to the 1984 Hazardous and Solid Waste
Amendments to RCRA, terms used herein shall have the same meaning as those in 40 CFR Parts 124, 144,
146, 260, 261, 262, 264, 266, 268, 270, 273 and 279; and OAC 252:205-1-2 through OAC 252:205-3-6 and
OAC 252:652-1-3; unless this Permit specifically provides otherwise. Where terms are not defined in the
Oklahoma Administrative Code or the Permit, the meaning associated with such terms shall be defined by a
standard dictionary reference or the generally accepted scientific or industrial meaning of the term.

"Action Levels" means health and environmental-based levels of constituent concentrations determined by
the ODEQ to be indicators for protection of human health and the environment. Oklahoma Drinking Water
Maximum Contaminant Levels (MCL’s) or an alternate limit established by the Oklahoma Department of
Environmental Quality as per 40 CFR 264.94(b) will be considered Action Levels for ground and surface
water. The calculation of action levels is specified in the RFI guidance.

"Area of Concern" (AOC) means any discernable unit or area which, in the opinion of the ODEQ, may
have received solid or hazardous waste or waste containing hazardous constituents at any time. The ODEQ
may require investigation of the unit as if it were a SWMU. If shown to be a SWMU by the investigation, the
AOC must be reported by the Permittee as a newly-identified SWMU. If the AOC is shown not to be a
SWMU by the investigation, the ODEQ may determine that no further action is necessary and notify the
Permittee in writing.

"CMS" means Corrective Measures Study.

"Director" means the Executive Director of the Oklahoma Department of Environmental Quality, or his/her
proper designee or authorized representative.

"Division Director" means the Director of the Land Protection Division of the Oklahoma Department of
Environmental Quality, or his/her proper designee or authorized representative.

"EPA" means the United States Environmental Protection Agency.

"Facility" means:

(1) All contiguous land, and structures, other appurtenances, and improvements on the land, used for treating,
storing, or disposing of hazardous waste.

                                                    I - 10
                                                         Lafarge Building Materials, Inc.
                                                           EPA ID #OKD064558703



(2) For the purpose of implementing corrective action under 264.101, all contiguous property under the
control of the owner or operator seeking a permit under subtitle C of RCRA. This definition also applies to
facilities implementing corrective action under RCRA Section 3008(h).

(3) Notwithstanding paragraph (2) of this definition, a remediation waste management site is not a facility
that is subject to 40 CFR 264.101, but is subject to corrective action requirements if the site is located within
such a facility.

"HSWA" means the 1984 Hazardous and Solid Waste Amendments to RCRA.

"Hazardous constituent" means any constituent identified in Appendix VIII of 40 CFR Part 261, or any
constituent identified in Appendix IX of 40 CFR Part 264.

"Hazardous waste" means a solid waste that meets the definition of hazardous waste specified by the
ODEQ in the Oklahoma Hazardous Waste Management Act and at OAC §252:205-3-2 incorporating the
EPA definition found at 40 CFR Part 261.

"Land Protection Division" means the Land Protection of the Oklahoma Department of Environmental
Quality.

"ODEQ" means the Oklahoma Department of Environmental Quality.

“OHWMA” means Oklahoma Hazardous Waste Management Act

"Permit" means this Permit, all Permit Attachments, and all provisions and documents that are incorporated
herein.

"Permittee" means Lafarge Building Materials, Inc. (Lafarge), 2609 N. 145th East Avenue, Tulsa, Oklahoma
EPA ID #OKD064558703.

"RCRA" means the Resource Conservation and Recovery Act of 1980 as amended by HSWA in 1984.

"RFA" means RCRA Facility Assessment.

"RFI" means RCRA Facility Investigation.

"Regional Administrator" means the Regional Administrator of EPA Region VI, or his/her designee or
authorized representative.

"Release" means any spilling, leaking, pouring, emitting, emptying, discharging, injecting, pumping,
escaping, leaching, dumping, or disposing of hazardous wastes or hazardous constituents into the
environment (including the abandonment or discarding of barrels, containers, and other closed receptacles
containing hazardous wastes or hazardous constituents). RCRA Section 3004(u) corrective action authority
does not routinely reevaluate permitted releases.

“Remediation Waste” means all solid and hazardous wastes, and all media (including groundwater, surface
water, soils, and sediments) and debris that contain listed hazardous waste or that themselves exhibit a
hazardous characteristic and are managed for implementing cleanup.


                                                     I - 11
                                                       Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


"Solid Waste Management" means the systematic administration of activities which provide for the
collection, source separation, storage, transportation, transfer, processing, treatment, and disposal of solid
waste.

"Solid Waste Management Unit" (SWMU) means any discernible unit at which solid wastes have been
placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous
waste. Such units include any area at a facility at which solid wastes have been routinely and systematically
released. The definition includes regulated units (i.e., landfills, surface impoundments, waste piles and land
treatment units) but does not include passive leakage or one-time spills from production areas and units in
which wastes have not been managed (e.g., product storage areas).

If, subsequent to the issuance of this Permit, regulations are promulgated which redefine any of the above
terms, the ODEQ may, at its discretion, apply the new definition to this Permit by modifying the Permit in
accordance with 40 CFR Section 270.41.

E.      EFFECT OF PERMIT

The Permittee is allowed to treat, store and dispose of hazardous and non-hazardous waste in accordance with
the conditions of this Permit. Any treatment and/or storage of hazardous waste not authorized in this Permit
is prohibited, unless exempted from permit requirements.

Compliance with a RCRA permit during its term constitutes compliance, for purposes of enforcement,
with subtitle C of RCRA except for applicable requirements not included in the Permit which: (1)
Become effective by statute; (2) Are promulgated under Part 268 of Chapter 40, Code of Federal
Regulations restricting the placement of hazardous wastes in or on the land; and (3) Are promulgated
under Part 264 of this chapter regarding leak detection systems for new and replacement surface
impoundment, waste pile, and landfill units, and lateral expansions of surface impoundment, waste pile,
and landfill units; or (4) Are promulgated under subparts AA, BB, or CC of part 265 limiting air emissions.
Applicable leak detection system requirements under Part 268 include double liners, CQA programs,
monitoring, action leakage rates, and response action plans, and will be implemented through the
procedures of §270.42 Class 1 permit modifications.

The issuance of a permit does not convey any property rights of any sort, or any exclusive privilege. The
issuance of a permit does not authorize any injury to persons or property or invasion of other private
rights, or any infringement of State or local law or regulations.

Compliance with the terms of this Permit does not constitute a defense to orders issued or actions
brought under the Oklahoma Environmental Quality Code to address an imminent and substantial
endangerment, Sections 3008(a), 3008(h), 3013, or 7003 of RCRA; Sections 104, 106(a) or 107 of
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C.
9601 et seq., commonly known as CERCLA), or any other law providing for protection of public
health or the environment from an imminent and substantial endangerment. [40 CFR 270.4,
270.30(g)]

F.      PERMIT ACTIONS

1.      Permit Modification, Revocation and Reissuance, and Termination


                                                    I - 12
                                               Lafarge Building Materials, Inc.
                                                 EPA ID #OKD064558703


This Permit may be modified, revoked and reissued, or terminated for cause, as specified in 40 CFR
270.41, 270.42, and 270.43. The filing of a request for a permit modification, revocation and
reissuance, or termination, or the notification of planned changes or anticipated noncompliance on
the part of the Permittee, does not stay the applicability or enforceability of any Permit Condition.
[40 CFR 270.4(a), 270.30(f)]




                                           I - 13
                                                                             Lafarge Building Materials, Inc.
                                                                               EPA ID #OKD064558703



2.        Permit Renewal

          This Permit may be renewed as specified in 40 CFR 270.30(b) and Permit Condition I.H.2. Review
          of any application for a permit renewal shall consider improvements in the state of control and
          measurement technology, as well as changes in applicable regulations. [40 CFR 270.30(b), HSWA
          Sec. 212]

3.        Permit Expiration

          Pursuant to 40 CFR 270.50, this Permit shall be effective for a fixed term not to exceed ten years. This Permit and all conditions herein will
     remain in effect beyond the Permit's expiration date, if the Permittee has submitted a timely, complete application (see 40 CFR 270.10, 270.13
     through 270.29) and, through no fault of the Permittee, the ODEQ has not issued a new permit, as set forth in 40 CFR 270.51. Permits continued
     under this section remain fully effective and enforceable.



4.        Transfer of Permits
          This Permit is not transferable to any person, except after notice to the Director. The
          Director will consider the information submitted by the Permittee or the proposed
          transferor, as required in 27A O.S. §2-7-109, and may require modification or revocation
          and reissuance of the Permit pursuant to 40 CFR 270.40 to identify the new Permittee
          and incorporate such other necessary requirements. Before transferring ownership or
          operation of the facility, the Permittee shall notify the new owner or operator in writing of
          the requirements of 40 CFR Parts 264 and 270 and this Permit. [40 CFR 270.30(l)(3)
          and 264.12(c)]



G.        SEVERABILITY

The provisions of this Permit are severable, and if any provision of this Permit, or the application
of any provision of this Permit to any circumstance is held invalid, the application of such
provision to other circumstances and the remainder of this Permit shall not be affected thereby. [40
CFR 124.16(a)]

H.        DUTIES AND REQUIREMENTS

1.        Duty to Comply

          The Permittee shall comply with all conditions of this Permit, except to the extent and for the
          duration that noncompliance is authorized by an emergency permit. Any permit noncompliance,
          other than noncompliance authorized by an emergency permit, constitutes a violation of OHWMA
          and RCRA and is grounds for enforcement action; for permit termination, revocation and reissuance,
          or modification; or for denial of a permit renewal application. [40 CFR 270.30(a)]

2.        Duty to Reapply


                                                                        I - 14
                                                     Lafarge Building Materials, Inc.
                                                       EPA ID #OKD064558703


     If the Permittee wishes to continue an activity allowed by this Permit after the expiration date of this
     Permit, the Permittee shall submit a complete application for a new permit at least 180 days prior to
     permit expiration. [40 CFR 270.10(h), 270.30(b)]

3.   Monthly Reports

     The Permittee shall submit monthly reports: Hazardous Waste Treatment, Storage, Disposal Facility
     or Recycling Facilities. [OAC 252:205-9-2] The Permittee shall comply with the manifest
     discrepancy reporting requirements of 40 CFR 264.72 and the unmanifested waste reporting
     requirements of 40 CFR 264.76.

4.   Biennial Report

     The Permittee shall comply with the biennial reporting requirements of 40 CFR 264.75.


     5.      Permit Expiration


     Refer to permit condition I.F.3.

6.   Need to Halt or Reduce Activity Not a Defense

     It shall not be a defense for the Permittee, in an enforcement action, that it would have been
     necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions
     of this Permit. [40 CFR 270.30(c)]

7.   Duty to Mitigate

     In the event of noncompliance with this Permit, the Permittee shall take all reasonable steps to
     minimize releases to the environment and shall carry out such measures as are reasonable to prevent
     significant adverse impacts on human health or the environment. [40 CFR 270.30(d)]

8.   Proper Operation and Maintenance

     The Permittee shall at all times properly operate and maintain all facilities and systems of treatment
     and control (and related appurtenances) which are installed or used by the Permittee to achieve
     compliance with the conditions of this Permit. Proper operation and maintenance includes effective
     performance, adequate funding, adequate operator staffing and training, and adequate laboratory and
     process controls, including appropriate quality assurance/quality control procedures. This provision
     requires the operation of back-up or auxiliary facilities or similar systems only when necessary to
     achieve compliance with the conditions of this Permit. [40 CFR 270.30(e)]

9.   Duty to Provide Information



                                                 I - 15
                                                    Lafarge Building Materials, Inc.
                                                      EPA ID #OKD064558703


       The Permittee shall furnish to the ODEQ, within a reasonable time, any relevant information which
       the ODEQ may request to determine whether cause exists for modifying, revoking and reissuing, or
       terminating this Permit, or to determine compliance with this Permit. The Permittee shall also
       furnish to the ODEQ, upon request, copies of records required to be kept by this Permit. [40 CFR
       270.30(h)]

10 .   Inspection and Entry


       Pursuant to 40 CFR 270.30(i), the Permittee shall allow the ODEQ, or
       an authorized representative, upon the presentation of credentials and
       other documents, as may be required by law, to:


a.    Enter at reasonable times upon the Permittee's premises where a
regulated facility or activity is located or conducted, or where records must be
kept under the conditions of this Permit;

b.    Have access to and copy, at reasonable times, any records that must be
kept under the conditions of this Permit;
c.    Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated or
required under this Permit; and
               d.      Sample or monitor, at reasonable times, for the purposes of assuring permit
                       compliance or as otherwise authorized by RCRA, any substances or parameters
                       at any location.

11 .   Monitoring and Records


a.    Samples and measurements taken for the purpose of monitoring shall
be taken in accordance with the Waste Analysis Plan, Permit Attachment 1.
The method used to obtain a representative sample of the waste to be analyzed
must be the appropriate method from the Waste Analysis Plan, Permit
Attachment 1, Appendix I of 40 CFR Part 261, or an equivalent method
approved by the ODEQ. Laboratory methods must be those specified in Test
Methods for Evaluating Solid Waste: Physical/ Chemical Methods SW-846,
Standard Methods of Wastewater Analysis, or an equivalent method, as
specified in the Waste Analysis Plan (See Permit Attachment 1). [40 CFR
270.30(j)(1)]


                                                I - 16
                                                      Lafarge Building Materials, Inc.
                                                        EPA ID #OKD064558703


b.    The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original printouts
from data logging of monitoring instruments, copies of all reports and records
required by this Permit, the certification required by 40 CFR 264.73(b)(9),
and records of all data used to complete the application for this Permit for a
period of at least 3 years from the date of the sample, measurement, report,
record, certification, or application. These periods may be extended by
request of the ODEQ at any time and are automatically extended during the
course of any unresolved enforcement action regarding this facility. The
Permittee shall maintain records from all groundwater monitoring wells and
associated groundwater surface elevations for the active life of the facility.
[40 CFR 270.30(j)(2)]


c.     Pursuant to 40 CFR 270.30(j)(3), records of monitoring information
shall specify:


1)     The date(s), exact place, and times of sampling or measurements;

2)     The individual(s) who performed the sampling or measurements;

3)     The date(s) analyses were performed;

4)     The individual(s) who performed the analyses;

5)     The analytical techniques or methods used; and

6)     The results of such analyses.

12 .   Reporting Planned Changes

       The Permittee shall give notice to the ODEQ, as soon as possible, of any planned physical alterations
       or additions to the permitted facility. [40 CFR 270.30(l)(1)]

13 .   Reporting Anticipated Noncompliance

       The Permittee shall give advance notice to the ODEQ of any planned changes in the permitted
       facility or activity which may result in noncompliance with permit requirements. Advance notice
       shall not constitute a defense for any noncompliance. [40 CFR 270.30(l)(2)]

14 .   Certification of Construction or Modification


                                                  I - 17
                                                       Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


       The Permittee may not commence treatment or storage of hazardous waste in the modified portion of
       the facility until the Permittee has submitted to the ODEQ, by certified mail or hand delivery, a letter
       signed by the Permittee and a registered professional engineer stating that the facility has been
       constructed or modified in compliance with the Permit; and


a.     The ODEQ has inspected the modified or newly constructed facility and
finds it is in compliance with the conditions of the Permit; or

                        b.      The ODEQ has either waived the inspection or has not within 15 days
                        notified the Permittee of his intent to inspect. [40 CFR 270.30(l)(2)]


15.    Transfer of Permits

       Refer to permit condition I.F.4.

       16 .    Monitoring and Other Periodic Reports

       Monitoring results and the other Periodic Reports required by this Permit shall be reported as
       specified in the table below:

                                           BIENNIAL REPORTING
       Biennial Hazardous Waste Report                      March 1 of evenly numbered years
                                                            for the previous odd numbered
                                                            year
                                           ANNUAL REPORTING
       Waste Minimization Plan                              December 1 for the previous year
                                                            ending September 30

       Financial Assurance                                   Sixty days before receiving
                                                             hazardous waste and annually
                                                             thereafter
                                     QUARTERLY REPORTING
       Quarterly HSWA Report                                 Within 30 days of the end of each
                                                             calendar quarter
                                       MONTHLY REPORTING
       RCRA ODEQ Hazardous Waste TSDF Report                 Within 30 days of the end of each
                                                             month
       [40 CFR 270.30 (l)(4)] [OAC 252:205-5-3, 252:205-9-2]

17 .   Compliance Schedules

       Reports of compliance with, or any progress reports on, interim and final requirements contained in
       any compliance schedule of this Permit shall be submitted no later than thirty (30) days following
       each schedule date. [40 CFR 270.30 (l)(5)]


                                                   I - 18
                                               Lafarge Building Materials, Inc.
                                                 EPA ID #OKD064558703


      18 .   Twenty-Four-Hour Reporting [40 CFR 270.30(l)(6)]


a.    The Permittee shall report to the ODEQ any noncompliance which may
endanger health or the environment. Any such information shall be reported
orally within 24 hours from the time the Permittee becomes aware of the
circumstances. The report shall include the following:


1)   Information concerning release of any hazardous waste that may cause an
endangerment to public drinking water supplies.

2)     Any information of a release or discharge of hazardous waste, or of a fire or
explosion from the hazardous waste management facility which could threaten the
environment or human health outside the facility.


b.    The description of the occurrence and its cause shall include:


1)    Name, address, and telephone number of the owner or operator;

2)    Name, address, and telephone number of the facility;

3)    Date, time, and type of incident;

4)    Name and quantity of materials involved;

5)    The extent of injuries, if any;

6)     An assessment of actual or potential hazards to the environment and human
health outside the facility, where this is applicable; and

7)     Estimated quantity and disposition of recovered material that resulted from the
incident.


c.     A written submission shall also be provided within five days of the time
the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance and its cause; the period(s) of
noncompliance (including exact dates and times); whether the noncompliance
has been corrected; and, if not, the anticipated time it is expected to continue;
and steps taken or planned to reduce, eliminate, and prevent recurrence of the


                                            I - 19
                                                      Lafarge Building Materials, Inc.
                                                        EPA ID #OKD064558703


noncompliance.     The ODEQ may waive the five-day written notice
requirement in favor of a written report within 15 days.

19 .   Other Noncompliance

       The Permittee shall report all other instances of known noncompliance with this Permit not
       otherwise required to be reported above, Permit Conditions I.H.12. - 18, at the time monitoring
       reports related to that activity are submitted. The reports shall contain the information listed in
       Permit Condition I.H.18 [40 CFR 270.30(l)(10)]

       20 .    Other Information

       Whenever the Permittee becomes aware that it failed to submit any relevant facts in the permit
       application, or submitted incorrect information in a permit application or in any report to the ODEQ,
       the Permittee shall promptly submit such facts or information. [40 CFR 270.30(l)(11)]




                                                  I - 20
                                                        Lafarge Building Materials, Inc.
                                                          EPA ID #OKD064558703




I.      SIGNATORY REQUIREMENT

All applications, reports, or information submitted to or requested by the ODEQ, his designee, or authorized
representative, shall be signed and certified in accordance with 40 CFR 270.11 and 270.30(k).

J.      REPORTS, NOTIFICATIONS, AND SUBMISSIONS TO THE ODEQ

All reports, notifications, or other submissions which are required by this Permit to be sent or given to the
ODEQ should be sent by certified mail or overnight delivery or given to:

                         Oklahoma Department of Environmental Quality
                         Land Protection Division
                         707 North Robinson
                         Oklahoma City, Oklahoma 73102
                         Phone Number (405) 702-5100

K.      CONFIDENTIAL INFORMATION

In accordance with 40 CFR 270.12 and OAC 252:205-3-1, the Permittee may claim confidential any
information required to be submitted by this Permit. Any such claim must be asserted at the time of
submission in the manner prescribed on the application form or instructions, or in the case of other
submissions, by stamping the words "confidential business information" on each page containing such
information. If no claim is made at the time of the submission, EPA and ODEQ may make the information
available to the public without further notice. If a claim is asserted, the information will be treated in
accordance with the procedures in OAC 252:205 which incorporates 40 CFR Part 2 (Public Information) and
the Oklahoma Open Records Act. Claims of confidentiality for the name and address of any permit applicant
or Permittee will be denied.

L.      DOCUMENTS TO BE MAINTAINED AT THE FACILITY

The Permittee shall maintain at the facility, until closure is completed and certified by an independent,
registered professional engineer, the following documents and all amendments, revisions and modifications
to these documents. The documents are to be retained in their original format for at least three (3) years from
generation, and may be stored electronically after that, with the original records destroyed.

1.      Waste Analysis Plan, as required by 40 CFR 264.13 and this Permit (See Permit Attachment
1).

2.     Inspection schedules, as required by 40 CFR 264.15(b)(2) and this Permit (See Permit
Attachment 2).

3.     Personnel training documents and records, as required by 40 CFR 264.16(d) and this Permit
(See Permit Attachment 3).


                                                    I - 21
                                                Lafarge Building Materials, Inc.
                                                  EPA ID #OKD064558703


4.    Contingency Plan, as required by 40 CFR 264.53(a) and this Permit (See Permit Attachment
4).

5.    Operating record, as required by 40 CFR 264.73 and this Permit.

6.    Closure Plan, as required by 40 CFR 264.112(a) and this Permit (See Permit Attachment 5).

7.      Manifesting, Reporting and Recordkeeping, as required by 40 CFR 264.70 and this
Permit.

       8.     Procedures, Structures, Equipment for Prevention of Hazards, as required by 40
                      CFR 270.14(b)(8) and (9) and this Permit (see Attachment 2).




                                            I - 22
                                                                       Lafarge Building Materials, Inc.
                                                                         EPA ID #OKD064558703


                 SECTION II – GENERAL FACILITY CONDITIONS

A.        DESIGN AND OPERATION OF FACILITY

The Permittee shall construct, maintain and operate the facility to minimize the possibility of a
fire, explosion, or any unplanned, sudden or non-sudden release of hazardous waste constituents
to air, soil, groundwater, or surface water which could threaten human health or the environment,
as required by 40 CFR 264.31.

B.        REQUIRED NOTICES

1.        Hazardous Waste Imports

          The Permittee may not receive hazardous waste from a foreign source.

2.        Hazardous Waste from Off-Site Sources

          The Permittee may not receive hazardous wastes which are not supplied by the permitted hazardous waste storage facility of Systech
     Environmental Corporation that is located within the property boundary of the Permittee.
     .

C.        GENERAL WASTE ANALYSIS

The Permittee shall meet the waste analysis requirements of 40 CFR 264.13 by following the procedures
set forth in the attached Waste Analysis Plan, Permit Attachment 1.

          1.      At a minimum, the Permittee shall maintain proper functional instruments, use
          approved sampling and analytical methods, verify the validity of sampling and
          analytical procedures, and perform correct calculations.

          2.         The Permittee shall repeat the analysis when it is notified or has reason to believe
                     that the process or operation generating the waste has changed.

          3.       The ODEQ may order modifications of the Waste Analysis Plan to require other
          or additional analyses whenever information becomes available (e.g. Test/Trial
          Burn data under the permit issued by the Air Quality Division of the ODEQ) that
          indicates such modifications are required for compliance with OAC 252:205-9-6.
          Such modifications will be made under the provisions of 40 CFR 270.41 or
          270.42.




                                                                    II-1
                                                       Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


D.        SECURITY

The Permittee shall comply with the security provisions of 40 CFR 264.14(b)(1) and (c) and the
Procedures to Prevent Hazards, Permit Attachment 2.

E.        GENERAL INSPECTION REQUIREMENTS

The Permittee shall follow the inspection schedules set out in Permit Attachment 2. The Permittee shall
remedy any deterioration or malfunction discovered by an inspection, as required by 40 CFR 264.15(c).
Records of inspections shall be kept, as required by 40 CFR 264.15(d).

F.        PERSONNEL TRAINING

The Permittee shall conduct personnel training, as required by 40 CFR 264.16. This training program
shall follow the attached outline set forth in Permit Attachment 3. The Permittee shall maintain training
documents and records, as required by 40 CFR 264.16(d) and (e).

     G.      SPECIAL PROVISIONS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE
                                     WASTE

The Permittee shall comply with the requirements of 40 CFR 264.17(a). The Permittee shall follow the
procedures for handling ignitable, reactive, and incompatible wastes set forth in Permit Attachment 2.

H.        PREPAREDNESS AND PREVENTION

1.        Required Equipment

          At a minimum, the Permittee shall maintain at the facility the equipment set forth in the
          Contingency Plan, Permit Attachment 4, as required by 40 CFR 264.32.

2.        Testing and Maintenance of Equipment

          The Permittee shall test and maintain the equipment specified in the Contingency Plan, Permit
          Attachment 4, as necessary to assure its proper operation in time of emergency, as required by 40
          CFR 264.33.

3.        Access to Communications or Alarm System

          The Permittee shall maintain access to the communications or alarm system, as required by 40
          CFR 264.34.




                                                    II-2
                                                    Lafarge Building Materials, Inc.
                                                      EPA ID #OKD064558703




4.     Arrangements with Local Authorities

       The Permittee shall maintain arrangements with state and local authorities, as required by 40 CFR
       264.37. If state or local officials refuse to enter into preparedness and prevention arrangements
       with the Permittee, the Permittee must document this refusal in the operating record.

I.     CONTINGENCY PLAN

1.     Implementation of Plan

       The Permittee shall immediately carry out the provisions of the Contingency Plan, Permit
       Attachment 4, whenever there is a fire, explosion, or release of hazardous waste or constituents
       which could threaten human health or the environment.

2.     Copies of Plan

       The Permittee shall comply with the requirements of 40 CFR 264.53.

3.     Amendments to Plan

       The Permittee shall review and immediately amend, if necessary, the Contingency Plan, as
       required by 40 CFR 264.54. Such amendment may require permit modification in accordance
       with 40 CFR 270.42.

4.     Emergency Coordinator

       A trained emergency coordinator shall be available at all times in case of an emergency, as
       required by 40 CFR 264.55.

J.     MANIFEST SYSTEM

The Permittee shall comply with the manifest requirements of OAC 252:205-9-7 and 40 CFR Part 262,
Subpart B, and Part 264, Subpart E.




                                                 II-3
                                                   Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


K.   GENERAL CLOSURE REQUIREMENTS

1.   Performance Standard

     As required by OAC 252:205-9-5 and 40 CFR 264.111, the Permittee shall conduct all required
     closure activities for hazardous waste management units in accordance with the Closure Plan,
     Permit Attachment 5.

2.   Amendment to Closure Plan

     The Permittee shall amend the Closure Plan, in accordance with 40 CFR 264.112(c), whenever
     necessary. Such amendment may require permit modification in accordance with 40 CFR 270.42.

3.   Notification of Closure

     The Permittee shall notify the ODEQ in writing at least 60 days prior to the date on which he
     expects to begin closure of the permitted units or final closure of the regulated units, as required
     by 40 CFR 264.112(d).

4.   Time Allowed For Closure

     After receiving the final volume of hazardous waste, the Permittee shall treat, remove from the
     unit, or dispose of on site all hazardous waste and shall complete closure activities, in accordance
     with 40 CFR 264.113 and the schedules specified in the Closure Plan, Permit Attachment 5.

5.   Disposal or Decontamination of Equipment, Structures, and Soils

     The Permittee shall decontaminate or dispose of all impacted equipment, structures, and soils, as
     required by 40 CFR 264.114.

6.   Certification of Closure

     The Permittee shall certify that the regulated unit has been closed in accordance with the
     specifications in Permit Attachment 5, as required by 40 CFR 264.115.




                                                II-4
                                                                         Lafarge Building Materials, Inc.
                                                                            EPA ID #OKD064558703


                           SECTION III – HAZARDOUS WASTE BURNING

A.        SECTION HIGHLIGHTS


          The Lafarge Tulsa Plant operates two dry process rotary kilns to produce Portland cement
          from limestone, clay, sand, and various raw material substitutes. One of the fuels fed to both
          kilns is hazardous waste fuel. Air emissions from the kilns are regulated under a Title V air
          permit which includes the emission limits of 40 CRF 63, Subpart EEE (HWC-MACT). All
          hazardous waste fuels burned in the kilns are supplied by the permitted hazardous waste
          storage facility of Systech Environmental Corporation (ODEQ Permit#000025452) that is
          located within the Lafarge site. Lafarge has elected to determine compliance with the applicable
          portions of CRF 264 Subpart BB Air Emission Standards for Equipment Leaks by performing the
          required monitoring and inspections in compliance with the relevant provisions of 40 CFR Part 63,
          Subpart DD as specified in 40 CFR 264.1064(m).


B.        PERMITTED AND PROHIBITED WASTE IDENTIFICATION

          1.     The Permittee may burn or accept hazardous waste from the permitted Systech
                 Environmental Corporation hazardous waste storage site located within the Lafarge
                 property subject to the terms of this Permit.

                 2.      The Permittee is prohibited from the use of direct transfer of hazardous waste
                 from trucks to the kilns as defined by 40 CFR 266.111.

                 3.     Results of waste analyses of the hazardous waste fuel obtained from Systech
                 Environmental Corporation must be incorporated in the facility operating record.



SECTION IV - SPECIAL CONDITIONS PURSUANT TO THE 1984
HAZARDOUS AND SOLID WASTE AMENDMENTS (HSWA)


A.        PREAMBLE AND GENERAL COMMENTS TO HSWA CONDITIONS

Lafarge has submitted to the ODEQ a RCRA Facility Assessment (RFA) dated February 2010.
The RFA identified eighteen Solid Waste Management Units (SWMUs) and five Areas of Concern
(AOCs) within the property boundaries of the Tulsa facility. The ODEQ has accepted this RFA
and the recommendation of No Further Action for all listed SWMUs excepting SWMUs #1, #2 and
#18. A listing of the SWMUs (by number) and AOCs (by letter) is presented below.

SWMUs:

     1.          Permitted CKD Landfill. This is an active monofill for disposal of cement kiln dust.
     2.          Old CKD Landfill. This is an inactive monofill for disposal of cement kiln dust.
                                                    IV-1
                                                                       Lafarge Building Materials, Inc.
                                                                          EPA ID #OKD064558703


     3.           East CKD Storm Water Runoff Impoundment.
     4.           West CKD Storm Water Runoff Impoundment.
     5.           Solids Settling Pond for Industrial Storm Water.
     6.           Used Oil Storage Area.
     7.           Maintenance Shop Parts Washer.
     8.           Mobile Garage Parts Washer.
     9.           Laboratory Satellite Accumulation Area.
     10.          T-10 CKD Holding Tank.
     11.          Silo 5 CKD Holding Tank.
     12.          Mobile Garage 1,500-Gallon Used Oil Tank.
     13.          Compressor Room 250-Gallon Used Oil Tank.
     14.          Kiln Pier 500-Gallon Used Oil Tank.
     15.          Plant Truck Wash Area.
     16.          Customer Truck Wash Area.
     17.          Mobile Garage Oil Change Pit.
     18.          Used Oil Tank – ARNCO Site.

AOCs:

     A.          Petroleum Tank Farm Fuel Dispensing Area.
     B.          Abandoned Transformer Area.
     C.          Wash Bay – ARNCO Site.
     D.          10,000 Gallon Above-Ground Storage Tank.
     E.          Plant Surface Water Drainage System.




B.         REQUIRED RFI ACTIVITIES

           Lafarge is required to proceed with the preparation of a RCRA Facility Investigation Work
           plan on SWMUs #1, 2 and 18 and the five AOCs identified in the RFA. The RFI workplans
           are to be submitted within six (6) months of the issuance of the Permit. The Permittee
           shall conduct an RFI in accordance with the provisions of Permit Section IV for any newly
           discovered SWMUs after the issuance of this Permit.

            C.     REQUIRED CORRECTIVE MEASURES IMPLEMENTATION (CMI)

     The Permittee is required to perform corrective measures for SWMUs and AOCs as directed
     by the ODEQ as a result of findings of the RFIs.


D.         STANDARD CONDITIONS

           1.     Waste Minimization

           Annually, by March 1, for the previous year ending December 31, the Permittee shall enter
           into the operating record as required by 40 CFR 264.73(b)(9), a statement certified according
                                                   IV-2
                                                              Lafarge Building Materials, Inc.
                                                                 EPA ID #OKD064558703


to 40 CFR 270.11(d) specifying that the Permittee has a program in place to reduce the
volume and toxicity of hazardous wastes generated by the facility's operation to the degree
determined by the Permittee to be economically practicable; and the proposed method of
treatment, storage, or disposal is that practicable method currently available to the Permittee
which minimizes the present and future threat to human health and the environment. A
current description of the program shall be maintained in the operating record and a copy of
the annual certified statement shall be submitted to the ODEQ. The following are suggested
criteria for the program:

       Any written policy or statement that outlines goals, objectives,
            and/or methods for source reduction and recycling of
            hazardous waste at the facility;

       Any employee training or incentive programs designed to identify
            and implement source reduction and recycling opportunities;

       Any source reduction and/or recycling measures implemented in the
             last five years or planned for the near future;

       An itemized list of the dollar amounts of capital expenditures (plant
             and equipment) and operating costs devoted to source
             reduction and recycling of hazardous waste;

       Factors that have prevented implementation of source reduction
             and/or recycling;

       Sources of information on source reduction and/or recycling received
            at the facility (e.g., local government, trade associations,
            suppliers, etc.);

       An investigation of additional waste minimization efforts that could
             be implemented at the facility. This investigation would
             analyze the potential for reducing the quantity and toxicity of
             each waste stream through production reformulation,
             recycling, and all other appropriate means. The analysis would
             include an assessment of the technical feasibility, cost, and
             potential waste reduction for each option;

       A flow chart or matrix detailing all hazardous wastes it produces by
             quantity, type, and building/area;

                                         IV-3
                                                            Lafarge Building Materials, Inc.
                                                               EPA ID #OKD064558703


       A demonstration of the need to use those processes which produce a
            particular hazardous waste due to a lack of alternative
            processes or available technology that would produce less
            hazardous waste.

       A description of the waste minimization methodology employed for
             each related process at the facility. The description should
             show whether source reduction or recycling is being
             employed.

       A description of the changes in volume and toxicity of waste actually
       achieved during the year in comparison to previous years.

Dust Suppression

       Pursuant to 40 CFR 279.82, the Permittee shall not use waste or used
             oil for dust suppression or road treatment.


Permit Modification

       Agency Initiated Modifications
              If at any time for any of the reasons specified in 40 CFR 270.41, the ODEQ
              determines that modification of this Permit is necessary, the Agency may
              initiate permit modification proceedings in accordance with the regulations set
              forth at 40 CFR 270.41.




                                       IV-4
                                                           Lafarge Building Materials, Inc.
                                                              EPA ID #OKD064558703



      Permittee Initiated Modifications
                The Permittee may, where appropriate, initiate permit modifications in
                accordance with the regulations set forth at 40 CFR 270.42. All applicable
                requirements and procedures as specified in 40 CFR 270.42 shall be
                followed by Permittee in initiating such proceedings.

      Modification of Corrective Action Schedules of Compliance (CASC)

                            The Permittee shall adhere to CASCs developed for
                                 newly identified SWMUs covered by this Permit.
                                 If at any time the Permittee determines that such
                                 schedules cannot be met, the Permittee shall
                                 notify the ODEQ and submit a request for an
                                 extension of time with a justification as to why
                                 the current CACS cannot be met. Such extension
                                 is only effective if approved in writing by the
                                 ODEQ or otherwise approved in accordance with
                                 the provisions of this Permit.
Permit Review

      This Permit may be reviewed by the ODEQ five years after the date of permit
      issuance and may be modified as necessary as provided for in Permit Condition
      VI.D.3. Nothing in this section shall preclude the ODEQ from reviewing and
      modifying the Permit at any time during its term.

Compliance with Permit. Compliance with this Permit during its term constitutes
      compliance, for the purposes of enforcement, with Subtitle C of RCRA except for
      those requirements which become effective by statute.




                                        IV-5
                                                            Lafarge Building Materials, Inc.
                                                               EPA ID #OKD064558703



Specific Waste Ban

       The Permittee shall not place in any land disposal unit the wastes
            specified in 40 CFR 268 after the effective date of the
            prohibition unless the Administrator has established disposal
            or treatment standards for the hazardous waste and the
            Permittee meets such standards and other applicable
            conditions of this Permit.

       The Permittee may store wastes restricted under 40 CFR 268 solely
            for the purpose of accumulating quantities necessary to
            facilitate proper recovery, treatment, or disposal provided that
            it meets the requirements of 40 CFR 268.50(a)(2) including, but
            not limited to, clearly marking each container to identify its
            contents and, for tanks, recording and maintaining the
            required information in the operating record at the facility.

       The Permittee is required to comply with all requirements of 40 CFR
            268.7 as amended. Changes to the waste analysis plan will be
            considered permit modifications at the request of the
            Permittee, pursuant to 40 CFR 270.42.

       The Permittee shall use his knowledge of process, or perform a
            waste analysis at least annually or when a process changes, to
            determine whether the waste meets applicable treatment
            standards. Results of any analysis performed shall be
            maintained in the operating record.
Information Submittal

       Failure to comply with any condition of the Permit, including information submittal,
       constitutes a violation of the Permit and is grounds for enforcement action, permit
       amendment, termination, revocation, suspension, or denial of permit renewal
       application. Falsification of any submitted information is grounds for termination of
       this Permit (40 CFR 270.43).

       The Permittee shall ensure that all plans, reports, notifications, and other
       submissions to the ODEQ required in this Permit are signed and certified in
       accordance with 40 CFR 270.11.           A summary of the planned reporting
       requirements pursuant to this Permit is found in Table 1. One (1) hard copy and,
       at ODEQ’s request, one (1) electronic copy, in Microsoft Word, Excel or other
                                      IV-6
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


format as agreed upon by ODEQ, as appropriate, by e-mail, CD or other method
as agreed upon by ODEQ, for each of these plans, reports, notifications or other
submissions shall be submitted to the ODEQ by Certified Mail, hand delivered or
by other traceable method to:




                              IV-7
                                                            Lafarge Building Materials, Inc.
                                                               EPA ID #OKD064558703


              Oklahoma Department of Environmental Quality
              Land Protection Division
              707 N. Robinson Avenue
              P. O. Box 1677
              Oklahoma City, Oklahoma 73101-1677

Plans and Schedules Incorporated Into Permit

       All plans and schedules and documents incorporated by reference required by this
       Permit are, upon approval by the ODEQ, incorporated into this Permit by reference
       and become an enforceable part of this Permit. Since required items are essential
       elements of this Permit, failure to submit any of the required items or submission of
       inadequate or insufficient information may subject the Permittee to enforcement
       action under the OHWMA which may include fines, suspension, or revocation of
       the Permit.

       Any noncompliance with approved plans and schedules shall be termed
       noncompliance with this Permit. Written requests for extensions of due dates for
       submittals may be granted by the ODEQ in accordance with Permit Condition
       VI.D.3.

       If the ODEQ determines that actions beyond those provided for, or changes to
       what is stated herein, are warranted, the ODEQ may modify this Permit according
       to procedures in Permit Condition VI.D.3.

Data Retention

       All raw data relating to corrective action, such as laboratory reports, drilling logs,
       bench-scale or pilot-scale data, and other supporting information gathered or
       generated during activities undertaken pursuant to this Permit shall be maintained
       at the facility during the specified term of this Permit or for three years after the
       ODEQ approves the final SWMU corrective measure completion report or
       approves no further action.

Management of Wastes


       All solid wastes which are managed pursuant to a remedial measure
       taken under the corrective action process or as an interim measure
       addressing a release or the threat of a release from a solid waste
       management unit shall be managed in a manner protective of
       human health and the environment and in compliance with all
       applicable Federal, State and local requirements.




                                        IV-8
                                                                 Lafarge Building Materials, Inc.
                                                                    EPA ID #OKD064558703




E.   SPECIFIC CONDITION – CLOSURE AND POST-CLOSURE CARE

     1.     Closure

            Permittee shall close the hazardous waste handling system in accordance with the
            Closure Plans, Permit Attachment 5. [40 CFR Subpart G]

     2.     Post-Closure Care

            The ODEQ will require post-closure care requirements should permitted units not
            achieve satisfactory closure standards.


F.   SPECIFIC CONDITION - INFORMATION REPOSITORY

     1.     The Permittee shall maintain an information repository at the local public library or
            other similar facility accessible to the public.

     2.     Additionally, the permittee shall place in the information repository all Permit
            renewal, amendment, or modification applications and supporting documentation,
            which shall be determined through consultation with ODEQ, during the pendency
            of such renewal, amendment, or modification proceeding for this Permit.


G.   SPECIFIC CONDITION - INVESTIGATION OF AREA(s) OF CONCERN

     Within 180 days of the identification of newly identified Areas of Concern (AOCs), the
     Permittee shall submit a plan to determine if the AOCs are SWMUs. The workplan shall
     describe the objectives of the investigation and the overall technical and analytical
     approach to completing all actions necessary to determine if activity at the AOC resulted
     in solid waste management at any time. If such determination is made, the AOC shall be
     designated as a newly-identified SWMU. If hazardous wastes or hazardous constituents
     are determined to have been or are currently being managed at the SWMU, and if the
     ODEQ determines that there are additional adverse impacts to groundwater and further
     investigation is necessary, a plan for the investigation shall be prepared according to
     Permit Condition VI.J.2.

H.   CORRECTIVE ACTION

     1.     Corrective Action for Releases: Permits issued after November 8, 1984, address
            corrective action for releases of hazardous waste or hazardous constituents from
            any SWMU at the facility, regardless of when the waste was placed in the unit. (40
            CFR 264.101)

     2.     Action Levels


                                            IV-9
                                                      Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


     a.   Applicability - The concept of action levels, described in the RFI
          guidance document referenced in Permit Condition VI.M.1.c.1
          shall be used by the Permittee to determine the need for
          further corrective actions under this Permit. As specified in
          Permit Condition VI.Q, the Permittee shall conduct a CMS
          whenever concentrations of hazardous constituents associated
          with releases from SWMUs to ground water and surface water
          exceed Oklahoma drinking water MCL action levels, or exceed
          soil or air action levels; or when the ODEQ determines that
          concentrations of contaminants, even if below action levels,
          present a threat to human health or the environment. The
          concept of action levels is not the same as cleanup levels,
          although in some cases a final cleanup level may be set to
          equal the action level.

     b.   Calculation - The Permittee shall adhere to Oklahoma drinking water MCLs
          and action levels for environmental media as obtained from the RFI
          guidance. These action levels shall be updated as new toxicity data and
          promulgated standards (e.g., maximum contaminant levels) are derived.
          The most recent reference doses, reference concentrations, and cancer
          slope factors (e.g., data found in EPA's Integrated Risk Information
          System) shall be utilized in the calculation of action levels. The toxicity
          data available at the time that a determination for further action is made
          (i.e., requirement to conduct a CMS), including interim measures, shall be
          utilized in the calculations. If used as final cleanup levels, action levels
          shall be calculated using the most recent toxicity data and promulgated
          standards existing at the time of implementation of corrective measures.


3.   Risk Assessment



     a.   The Permittee shall conduct human health and ecological risk
          assessments as necessary for the protection of human health
          and the environment. These risk assessments shall be used to
          establish baseline risk at a site and/or to derive final or interim
          cleanup levels at the site, SWMU, or area, as appropriate.
          These risk assessments, if necessary, shall be performed
          concurrently with the corrective action activities specified in
          this Permit, including any activities undertaken during
                                  IV-10
                                           Lafarge Building Materials, Inc.
                                              EPA ID #OKD064558703


     implementation of the activities proposed in the RFI
     Workplan. These risk assessments may also be performed
     concurrently with the RFI Final Report and Summary and the
     CMS Phase of this permit, as specified in Permit Condition
     VI.H.3 and VI.V. respectively, but only after the Permittee has
     determined the full vertical and horizontal extent of
     contamination at the SWMU(s) to which the risk assessment
     applies.



b.   The Permittee shall utilize as guidance, but not be limited to,
     the following EPA documents and publications: "Compendium
     of ORD and OSWER Documents Relevant to RCRA Corrective
     Action"    (EPA530-B-92-003,      April   1992);    "Ecological
     Assessments of Hazardous Waste Sites, A Field and Laboratory
     Reference Document" (EPA/600/3-89/013, March 1989); "ECO
     Update, Ecological Assessment of Superfund Sites: An
     Overview" (Publication 9345.0-05I, Vol. 1, No. 2, December
     1991); and "ECO Update, Developing A Work Scope for
     Ecological Assessments" (Publication 9345.0-05I, Vol. 1, No. 4,
     May 1992); including any subsequent revisions.

               Baseline Risk Assessments - Baseline risk assessments, if
                      required, shall be used to evaluate the risks
                      posed by contaminants at a site prior to the
                      beginning of any corrective actions. This type of
                      risk assessment shall be used in certain
                      circumstances (specified in Permit Condition
                      VI.H.3.b.2) instead of action levels (described in
                      Permit Condition VI.H.2) to determine the need
                      for remedial action.

               Although the action level concept shall serve as a
                     trigger for a CMS (as specified in Permit
                     Condition VI.O) certain exceptions will apply, but
                     not be limited to the following circumstances: 1)
                     In cases where the applicable action levels are
                     not protective enough of sensitive environmental
                         IV-11
                                            Lafarge Building Materials, Inc.
                                               EPA ID #OKD064558703


                      systems; such as wetlands, estuaries, and
                      habitats of endangered or threatened species,
                      the Permittee shall conduct a baseline
                      environmental risk assessment; 2) In cases where
                      there are confirmed releases to ground water,
                      surface water, air, or sediments, a baseline risk
                      assessment shall be required to determine the
                      need     for    stabilization/interim     measures,
                      especially where health advisories have been
                      issued by local/state governments; 3) Action
                      levels may be inappropriate at a site where there
                      are multiple contaminants or where leaching
                      from contaminated soils into ground water poses
                      greater risk than ingestion of the soils.

               If an action level has been exceeded, for any of the
                     environmental media of concern, at any time
                     during the corrective action activities required by
                     this Permit, the Permittee may be required to
                     conduct a risk assessment to determine risks to
                     human health and the environment and the
                     necessity to perform interim measures, as
                     specified in Permit Condition VI.L.            Risk
                     assessments to determine final cleanup levels or
                     to be used in justifying no further action
                     determinations shall be conducted only after the
                     Permittee has determined the full vertical and
                     horizontal extent of contamination from the
                     SWMU(s) in question.


c.   Risk Assessments for Deriving Cleanup Levels - Risk
     assessments, if required, may also be used as a starting point
     for cleanup goals, in addition to the final cleanup level. Risk
     assessments may be required as specified in Permit Condition
     VI.H.3.b.2).   In addition, where cleanup levels fail to
     incorporate significant routes of exposure at a particular site,
     or where remedies cannot meet the 10-4 to 10-6 risk range for


                         IV-12
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


     carcinogens or meet action levels if chosen as final cleanup
     levels, a risk assessment may also be required.

     The ODEQ intends to review risk assessments as part of the CMS Phase
     of the corrective action activities specified in this Permit in deriving final
     cleanup goals, but only after the Permittee has determined the full vertical
     and horizontal extent of contamination from each SWMU(s) in question.


d.   Use of Risk Assessments in Justifying No Further Action - The
     Permittee may submit a risk assessment(s) justifying no
     further action at a SWMU(s) concurrently with submittal of the
     RFI Final Report and Summary specified in Permit Condition
     VI.0., only if the Permittee has determined the full vertical and
     horizontal extent of contamination from each SWMU(s) in
     question.


e.   Corrective Action for Releases Beyond Facility Boundary: State
     and Federal regulations promulgated as 40 CFR 264.101(c),
     require corrective actions beyond the facility property
     boundary, where necessary to protect human health and the
     environment, unless the Permittee demonstrates that, despite
     the Permittee's best efforts, the Permittee was unable to
     obtain the necessary permission to undertake such actions.
     The Permittee is not relieved of all responsibility to clean up a
     release that has migrated beyond the facility boundary where
     offsite access is denied; instead the Permittee must propose
     alternative actions.




                             IV-13
                                                 Lafarge Building Materials, Inc.
                                                    EPA ID #OKD064558703




4.   Dispute Resolution


     a.    The parties shall use their best efforts to informally and in
           good faith resolve all disputes or differences of opinion. If,
           however, disputes arise concerning the corrective action which
           the parties are unable to resolve informally, the following
           procedures shall apply. If Permittee's dispute concerns its
           inability to meet a specified deadline, then Permittee is
           obligated to advise the ODEQ of the issue in advance of the
           deadline.



     b.    The ODEQ shall provide Permittee written notice of its
           disapproval or modification of any interim submission under
           Section VI of this Permit, including, but not limited to,
           implementation of workplans, approval of documents,
           scheduling of any work, or selection, performance, or
           completion of any corrective action. The written notice of
           disapproval or modification shall set forth the reasons for the
           disapproval or modification. If the Permittee disagrees, in
           whole or in part, with any such written notice, the Permittee
           shall notify the ODEQ, in writing, within 30 days of receipt of
           the written notice. The Permittee and the ODEQ permits staff
           shall use their best efforts to informally and in good faith
           resolve the dispute. The Permittee is entitled to meet with
           RCRA permits staff in person at the ODEQ's office or by
           teleconference, if it so desires, in order to resolve the dispute.


     If Permittee and the RCRA permits staff are unable to resolve the
           dispute, the Permittee may request a final decision by the
           ODEQ or an official having been delegated final permit
           approval authority, or other delegate. Within 45 days of
           receipt of the ODEQ's written notice, the Permittee shall
                               IV-14
                                          Lafarge Building Materials, Inc.
                                             EPA ID #OKD064558703


     submit to the permit approval authority, a written statement
     of its arguments and explanations of its position. The written
     statement should include, at a minimum, the specific points of
     dispute, the position the Permittee maintains should be
     adopted as consistent with the Permit requirements and the
     basis therefore, any matters which it considers necessary for
     proper determination of the dispute, and whether the
     Permittee requests a conference in front of the permit
     approval authority. The Permittee's failure to follow the
     procedures set forth in this paragraph will constitute a waiver
     of its right to further consideration of the dispute.



d.   The ODEQ's duly appointed official having final permit
     approval authority, at his/her discretion, will determine
     whether a conference, if requested by the Permittee, will be
     held.



e.   The ODEQ shall consider the written position of the Permittee
     and the oral arguments, if a conference is convened, and shall
     provide a written order of its decision based on the record,
     though the decision and order need not be a formal order of
     the ODEQ. The written order shall respond to the Permittee's
     arguments and shall set forth the reasons for the ODEQ's final
     decision and make all revisions that are necessary to
     implement the decisions of the ODEQ. Such decision shall be
     the final order of the ODEQ and shall be implemented
     immediately by the Permittee according to the schedule
     contained therein.      Nothing in this Section limits the
     Permittee’s right to seek and obtain any judicial review and/or
     judicial relief authorized by law, including a stay of
     requirements pending judicial resolution.



                         IV-15
                                                      Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


          f.    The requirements of this Permit that are the subject of the
                dispute are stayed pending the decision of the ODEQ.
                Notwithstanding the invocation of this dispute resolution
                procedure, the Permittee shall proceed to take any action
                required by those portions of the submission and of the permit
                that are not substantially affected by the dispute.



          g.    The Permittee shall invoke the Dispute Resolution provisions
                of this Permit in good faith and not for purposes of delay.



I.   REPORTING REQUIREMENTS



     1.   The Permittee shall submit signed quarterly progress reports of 1)
          RFI activities, 2) CMS/CMI Activities, 3) CMI Inspection and
          Maintenance, and 4) Post-Closure Care activities conducted pursuant
          to the provisions of this Permit, within thirty days of the end of each
          quarter if an alternative schedule was not specified in submittals or
          otherwise approved by the ODEQ. These reports can be submitted
          as one document and shall contain:



          a.    A description of the work completed and an estimate of the
                percentage of work completed;



          b.    Summaries of all findings, including summaries of laboratory
                data;




                                    IV-16
                                                     Lafarge Building Materials, Inc.
                                                        EPA ID #OKD064558703


          c.    Summaries of all problems or potential problems encountered
                during the reporting period and actions taken to rectify
                problems;



          d.    Projected work for the next reporting period;



          e.    Summaries of contacts pertaining to corrective action or
                environmental matters with representatives of the local
                community, public interest groups or State government during
                the reporting period;



          f.    Changes in key project personnel during the reporting period;
                and



          g.    Summaries of all changes made in implementation during the
                reporting period.



     2.   Copies of other reports relating to or having bearing upon the
          corrective action work, (e.g., inspection reports), drilling logs and
          laboratory data shall be made available to the ODEQ upon request.




J.   NOTIFICATION    REQUIREMENTS    FOR    AND             ASSESSMENT           OF
     NEWLY-IDENTIFIED SWMUs AND POTENTIAL AOCs




                                    IV-17
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


1.   The Permittee shall notify the ODEQ, in writing, of any
     newly-identified SWMU(s) and potential AOCs (i.e., a unit or area not
     specifically identified during the RFA), discovered in the course of
     ground water monitoring, field investigations, environmental audits,
     or other means, no later than thirty (30) calendar days after
     discovery. The Permittee shall also notify the ODEQ of any newly-
     constructed land-based SWMUs (including but not limited to, surface
     impoundments, waste piles, landfills, land treatment units) and
     newly-constructed SWMUs where any release of hazardous
     constituents may be difficult to identify (e.g., underground storage
     tanks) no later than thirty (30) days after construction. The
     notification shall include the following items, to the extent available:



     a.    The location of the newly-identified SWMU or potential AOC
           on the topographic map required in 40 CFR 270.14(b)(19).
           Indicate all existing units (in relation to other SWMUs);



     b.    The type and function of the unit;



     c.    The general dimensions, capacities, and structural description
           of the unit (supply any available drawings);



     d.    The period during which the unit was operated;



     e.    The specifics, to the extent available, on all wastes that have
           been or are being managed at the SWMU or potential AOC;
           and



                                IV-18
                                                                 Lafarge Building Materials, Inc.
                                                                    EPA ID #OKD064558703


            f.      Results of any sampling and analysis required for the purpose
                    of determining whether releases of hazardous waste including
                    hazardous constituents have occurred, are occurring or are
                    likely to occur, to groundwater or surface water, from the
                    newly identified SWMU, or whether the potential AOC should
                    be considered a newly-identified AOC.


     Based on the results of this Notification, the ODEQ will, if necessary, designate a newly-
            identified AOC(s). Based on the results of this notification or investigation
            conducted according to Permit Condition VI.G, the ODEQ will determine the need
            for further investigations or corrective measures at any newly-identified SWMU(s)
            or AOC(s). If the ODEQ determines that such investigations are needed, the
            ODEQ may require the Permittee to prepare a plan for such investigations. The
            plan for investigation of the SWMU(s) or AOC(s) will be reviewed for approval as
            part of the RFI Workplan or a new RFI Workplan under Permit Condition VI.M.3.
            The ODEQ may require the Permit to be modified at that time in accordance with
            Permit Condition VI.D, to incorporate the investigation requirements for the newly-
            identified AOC(s) identified pursuant to Permit Condition J.1 or SWMU(s)
            identified pursuant to Permit Condition VI.G. The ODEQ may also allow this
            modification as part of subsequently required permit/corrective action permit
            modification actions.


K.   NOTIFICATION REQUIREMENTS FOR NEWLY-DISCOVERED RELEASES AT
     SWMU(s) AND AOC(s)

     The Permittee shall notify the ODEQ in writing, no later than thirty (30) calendar days after
     discovery, of any release(s) from a SWMU or AOC of hazardous waste or hazardous
     constituents discovered during the course of ground water monitoring, field investigation,
     environmental auditing, or other means. Such newly-discovered releases may be from
     newly-identified SWMUs or AOCs, newly-constructed SWMUs, or from SWMUs or AOCs
     for which, based on the findings of the RFA, completed RFI, or investigation of an AOC(s),
     the ODEQ had previously determined no further investigation was necessary. The
     notification shall include information concerning actual and/or potential impacts beyond
     the facility boundary and on human health and the environment, if available at the time of
     the notification. If hazardous wastes or hazardous constituents are determined to have
     been or are currently being managed at the SWMU, and if the ODEQ determines that
     there are additional adverse impacts to groundwater and further investigation is
     necessary, a plan for the investigation shall be prepared. The ODEQ may require further
     investigation and/or interim measures for the newly-identified release(s), and may require
     the Permittee to prepare a plan for the investigation and/or interim measure. The plan will
     be reviewed for approval as part of the RFI Workplan or a new RFI Workplan under
     Permit Condition VI.M.3. The Permit will be modified according to Permit Condition VI.D.3
     and VI.J.2 to incorporate the SWMU, if required.
                                            IV-19
                                                             Lafarge Building Materials, Inc.
                                                                EPA ID #OKD064558703



L.   INTERIM MEASURES

     1.   If the ODEQ determines that a release or potential release of hazardous
          constituents poses a threat to human health and the environment, the ODEQ may
          require interim measures. The ODEQ shall determine the specific measure(s) or
          require the Permittee to propose a measure(s). The interim measure(s) may
          include a permit modification, a schedule for implementation, and a written plan.
          The ODEQ shall notify the Permittee in writing of the requirement to perform
          interim measures. The ODEQ may modify this Permit according to 40 CFR 270.41
          to incorporate interim measures into the Permit. (27A O. S. §2-6-105; OAC
          252:205-9-1 and 252:205-13-1)

     2.   The Permittee may propose interim measures at any time. The proposal shall
          include a written plan and a schedule for implementation. Depending upon the
          nature of the interim measure, a permit modification may not be required.

     3.   The following factors will be considered by the ODEQ in determining the need for
          interim measures and the need for permit modification:

          a.     Time required to develop and implement a final remedy;

          b.     Actual and potential exposure to human and environmental receptors;

          c.     Actual and potential contamination of drinking water supplies and sensitive
                 ecosystems;

          d.     The potential for further degradation of the medium in the absence of
                 interim measures;

          e.     Presence of hazardous wastes in containers that may pose a threat of
                 release;

          f.     Presence and concentration of hazardous waste including hazardous
                 constituents in soil that have the potential to migrate to ground water or
                 surface water;

          g.     Weather conditions that may affect the current levels of contamination;

          Risks of fire, explosion, or accident; and

          Other situations that may pose threats to human health and the
               environment.




                                         IV-20
                                                    Lafarge Building Materials, Inc.
                                                       EPA ID #OKD064558703


M.        RFI WORKPLAN



     1.   For any newly identified SWMU(s), the RFI Workplan as specified in
          Permit Condition VI.U.3 shall be submitted to the ODEQ within 180
          days of identification or ODEQ decision under Section VI.D. The RFI
          Workplan must address releases from SWMU(s) of hazardous waste
          or hazardous constituents to all media as specified below.



          a.   The Workplan shall describe the objectives of the investigation
               and the overall technical and analytical approach to
               completing all actions necessary to characterize the direction,
               rate, movement, and concentration of releases of hazardous
               waste or hazardous constituents from specific units or groups
               of units, and their actual or potential receptors. The RFI
               Workplan shall detail all proposed activities and procedures to
               be conducted at the facility, the schedule for implementing
               and completing such investigations, the qualifications of
               personnel performing or directing the investigations, including
               contractor personnel, and the overall management of the RFI.
               The Scope of Work for a RCRA Facility Investigation (RFI) is in
               Permit Condition VI.U.



          b.   The RFI Workplan shall describe sampling, data collection
               quality assurance, and data management procedures,
               including formats for documenting and tracking data and other
               results of investigations, and health and safety procedures.



          c.   Development of the RFI Workplan and reporting of data shall
               be consistent with the following EPA guidance documents or
               the equivalent thereof:

                                   IV-21
                                                                 Lafarge Building Materials, Inc.
                                                                    EPA ID #OKD064558703


                                RCRA Facility Investigation Guidance Document (EPA
                                     530/SW-89-031, May 1989);

                                RCRA     Ground-Water Monitoring: Draft Technical
                                        Guidance (EPA/530-R-93-001, November 1992;

                                RCRA Groundwater Monitoring Technical Enforcement
                                     Guidance Document (OSWER 9950.1) September
                                     1986; and

                                Test     Methods for Evaluating Solid Waste,
                                        Physical/Chemical Methods, SW-846, 3rd Edition,
                                        November 1992, with revisions.



     2.     After the Permittee submits the Workplan, the ODEQ will either approve,
            disapprove, or modify the Workplan in writing.

            If the ODEQ approves the Workplan, the Permittee shall implement the plan in
            accordance with its approved schedule contained in the plan. All approved
            Workplans become incorporated into this Permit.

            In the event of disapproval (in whole or in part) of the Workplan, the ODEQ shall
            specify deficiencies in writing. The Permittee shall modify the plan to correct these
            within the time frame specified in the notification of disapproval by the ODEQ. The
            modified Workplan shall be submitted in writing to the ODEQ for review.

     3.     The ODEQ shall review for approval as part of the RFI Workplan or as a new
            Workplan any plans developed pursuant to Permit Condition VI.J. addressing
            further investigations of newly-identified SWMUs or AOCs, or Permit Condition
            VI.K. addressing new releases from previously-identified SWMUs or AOCs.

N.          RFI IMPLEMENTATION

     Upon receipt of written approval from the ODEQ for the RFI Workplan, the Permittee shall
     implement the RFI according to the schedules and in accordance with the approved RFI
     Workplan and the following:

     1.     The Permittee shall notify ODEQ at least 10 days prior to any field sampling, field
            testing, or field monitoring activity required by the Workplan to give Agency
            personnel the opportunity to observe investigation procedures and/or split
            samples.




                                            IV-22
                                                             Lafarge Building Materials, Inc.
                                                                EPA ID #OKD064558703


     2.   Deviations from the approved RFI Workplan which are necessary during
          implementation of the investigations must be approved by the ODEQ and fully
          documented and described in the progress reports and in the RFI Final Report.

O.   RFI FINAL REPORT AND SUMMARY

     1.   Within ninety (90) calendar days after the completion of the RFI, or in accordance
          with an alternative schedule approved by the ODEQ in the RFI Workplan, the
          Permittee shall submit an RFI Final Report and Summary. The RFI Final Report
          shall describe the procedures, methods, and results of all investigations as
          described in Permit Condition VI.U.5. This includes SWMUs and their releases,
          the type and extent of contamination at the facility, sources and migration
          pathways, action levels, and actual or potential receptors. The RFI Final Report
          shall present all information gathered under the approved RFI Workplan. The RFI
          Final Report must contain adequate information to support further corrective action
          decisions at the facility. The Summary shall summarize the RFI Final Report.

     2.   After the Permittee submits the RFI Final Report and Summary, the ODEQ shall
          provide written notice of approval or disapproval.

          If the ODEQ determines the RFI Final Report and Summary do not fully meet the
          objectives stated in Permit Condition VI.U, the ODEQ may disapprove the RFI
          Final Report and Summary. If the ODEQ disapproves the Report, the ODEQ shall
          notify the Permittee in writing of the Report's deficiencies and specify a due date
          for submittal of a revised Final Report and Summary or the ODEQ shall modify the
          report before approval.

     3.   Action levels, as discussed in Permit Condition VI.H.2, shall be used by the
          Permittee to determine the need for further corrective action under this Permit.
          Action levels are one criteria which can be used to determine if a CMS is required.
          The concept of action levels is not the same as cleanup levels, although in some
          cases a final cleanup level may be set to equal the action level.

P.   DETERMINATION OF NO FURTHER ACTION

     1.   Based on the results of the RFI and/or other relevant information, the Permittee
          may submit an application to the ODEQ for a permit modification under 40 CFR
          270.42 to terminate the RFI/CMS process for a specific unit. This permit
          modification application must contain information demonstrating that there are no
          releases of hazardous waste including hazardous constituents from a particular
          SWMU at the facility that pose threats to human health and/or the environment, as
          well as additional information required in 40 CFR 270.42. The proposal for no
          further action for specific units may be proposed as a permit modification
          accompanying a proposed permit modification in accordance with Permit Section
          VI-T "Corrective Measures (Remedy) Selection and Implementation."

          If, based upon review of the Permittee's request for a permit modification, the
          results of the RFI, and other information, the ODEQ determines that releases or
          suspected releases which were investigated either are non-existent or do not pose

                                         IV-23
                                                                   Lafarge Building Materials, Inc.
                                                                      EPA ID #OKD064558703


            a threat to human health and/or the environment, the ODEQ may grant the
            requested modification.

     2.     If necessary to protect human health or the environment, a determination of no
            further action shall not preclude the ODEQ from requiring continued or periodic
            monitoring of air, soil, ground water, or surface water, when site-specific
            circumstances indicate that releases of hazardous waste or hazardous
            constituents are likely to occur.

     A determination of no further action prior to completion of corrective action for all
            SWMUs specifically identified in this Permit, as determined by ODEQ approval of
            the CMS Implementation Completion Report, shall not preclude the ODEQ from
            requiring further investigations, studies, or remediation at a later date, if new
            information indicates a release or likelihood of a release from a SWMU at the
            facility that is likely to pose a threat to human health or the environment. In such a
            case, the ODEQ shall initiate a modification to the Permit in accordance with 40
            CFR 270.41.

Q.          CMS PLAN

     1.     If the ODEQ has reason to believe that a SWMU has released concentrations of
            hazardous constituents, or if the ODEQ determines that contaminants present a
            threat to human health or the environment given action levels or site-specific
            exposure conditions, the ODEQ may require a CMS and shall notify the Permittee
            in writing. The notification may also specify remedial alternatives to be evaluated
            by the Permittee during the CMS.

     2.     The Permittee shall submit a CMS Plan to the ODEQ within ninety (90) calendar
            days from notification of the requirement to conduct a CMS. The Scope of Work
            for a CMS Plan is in Permit Condition VI.V.

            The CMS Plan shall provide the following information:

            a.      A description of the general approach to the investigation, and potential
                    remedies;

            b.      A definition of the overall objectives of the study;

            c.      Specific plans for evaluating remedies to ensure compliance with remedy
                    standards;

            d.      Schedules for conducting the study; and

            e.      The proposed format for the presentation of information.

     3.     After the Permittee submits the CMS Plan, the ODEQ will either approve,
            disapprove, or modify the plan in writing.


                                             IV-24
                                                                 Lafarge Building Materials, Inc.
                                                                    EPA ID #OKD064558703


            If the ODEQ approves the CMS Plan, the Permittee shall implement the plan per
            Permit Condition VI.R.

            In the event of disapproval (in whole or in part) of the CMS Plan, the ODEQ shall
            specify deficiencies in writing. The Permittee shall modify the plan to correct these
            within the time frame specified in the notice of deficiency. The modified CMS Plan
            shall be submitted in writing to the ODEQ for review. Should the Permittee take
            exception to the disapproval, decision, or directive, the Permittee shall submit a
            written statement of the grounds for the exception in accordance with dispute
            resolution provisions of Permit Condition VI.H.4.

R.          CMS IMPLEMENTATION

     After the Permittee has received written approval from the ODEQ for the CMS Plan, the
     Permittee shall begin implementation of the Corrective Measures Study and execute the
     plan according to the schedules therein. All approved plans become incorporated into this
     Permit.




                                            IV-25
                                                               Lafarge Building Materials, Inc.
                                                                  EPA ID #OKD064558703



S.   CMS FINAL REPORT AND SUMMARY

     1.     Within ninety (90) calendar days after the completion of the CMS, the Permittee
            shall submit a CMS Final Report and Summary. The Summary shall summarize
            the Final Report. The CMS Final Report shall discuss the results of investigations
            of each remedy studied and of any bench-scale or pilot tests conducted. It must
            include an evaluation of each remedial alternative. The CMS Final Report shall
            present all information gathered during the CMS, and must contain adequate
            information to support the remedy selection process. In the CMS Final Report, the
            Permittee shall propose a corrective action program that shall:

            a.     Attain compliance with corrective action objectives for hazardous
                   constituents in each medium, as established in Permit Condition VI.V;

            b.     Control sources of releases;

            c.     Meet acceptable waste management requirements;

            d.     Protect human health and the environment; and

            e.     Provide for submission for approval of a CMS Implementation Completion
                   Report describing implementation of the corrective measures and a
                   schedule for submission of the Completion Report.             If any post-
                   implementation monitoring is required under an approved CMS Final
                   Report and/or CMS Implementation and Completion Report, the CMS
                   Implementation and Completion Report may be submitted after all required
                   remedial actions have been taken notwithstanding any future monitoring
                   requirements. Permitee may also submit Partial Completion Reports upon
                   completion of particular corrective/remedial measures or milestones.

     2.     After the Permittee submits the CMS Final Report and Summary, the ODEQ will
            either approve or disapprove them in writing. Should the Permittee take exception
            to the disapproval, decision, or directive, the Permittee shall notify the ODEQ
            according to Permit Condition VI.H.4.

            If the ODEQ determines the CMS Final Report and Summary do not fully meet the
            objectives stated in Permit Condition VI.V., the ODEQ may disapprove the CMS
            Final Report and Summary. If the ODEQ disapproves the Report, the ODEQ shall
            notify the Permittee in writing of the Report's deficiencies and specify a due date
            for submittal of a revised Final Report and Summary.

     3.     Based on preliminary results and the CMS Final Report, the ODEQ may require
            the Permittee to evaluate additional remedies or particular elements of one or
            more proposed remedies.

T.   CORRECTIVE MEASURE (REMEDY) SELECTION AND IMPLEMENTATION

     Within sixty (60) calendar days after approval of CMS Final Report and Summary, the
     Permittee shall initiate modification of the Permit in accordance with 40 CFR 270.42, for
                                              IV-26
                                                                   Lafarge Building Materials, Inc.
                                                                      EPA ID #OKD064558703


     corrective measure (remedy) selection, based on the approved CMS Final Report. The
     resultant modified permit will include schedules for remedy implementation. Upon
     completion, a CMS Implementation Completion Report shall be submitted in accordance
     with the approved schedule in the CMS Final Report. Partial Completion Report(s) may
     be submitted upon completion of particular corrective/remedial measures or milestones.

U.   RFI SCOPE OF WORK

     1.      Purpose

     The purpose of the RFI is to determine the nature and extent of releases of hazardous
     wastes or hazardous constituents from solid waste management units. The required
     information shall include each item specified under Tasks I-VI. The Permittee shall furnish
     all personnel, materials, and services necessary for, or incidental to, performing the RFI.

     If the Permittee believes that certain requirements of the Scope of Work are not
     applicable, the specific requirements shall be identified and a detailed rationale for
     inapplicability shall be provided.

     2.      Scope

     The RFI consists of three tasks:

     Task I: RFI Workplan

     a.                   Introduction
     b.                   Environmental Setting
     c.                   Source Characterization
     d.                   Contamination Characterization
     e.                   Potential Receptor Identification
     f.                   Data Collection Quality Assurance Plan
     g.                   Data Management Plan
     h.                   Health and Safety Plan
     i.                   Community Relations Plan
     j.                   Project Management Plan

     Task II:        RCRA Facility Investigation

     Task III:       RFI Final Report and Summary

     3.      Task I: RFI Workplan

     The Permittee shall prepare a RFI Workplan as specified in Permit Condition VI.M.
     Unless otherwise authorized by the ODEQ based on previously submitted information or
     lack of need, the RFI Workplan shall provide for and address the following information
     needs:

             a.      Introduction

                     1)      Facility Description
                                               IV-27
                                               Lafarge Building Materials, Inc.
                                                  EPA ID #OKD064558703



The introduction shall summarize the regional location, pertinent boundary
features, general facility physiography, hydrogeology, and historical use of
the facility for the treatment, storage, or disposal of solid and hazardous
waste. Information from existing reports and studies is acceptable, as long
as the source of this information is documented, pertinent, and reflective of
current conditions. This section shall include:

       Map(s) depicting the information specified below. All maps shall be
              consistent with requirements set forth in 40 CFR 270.14 and
              shall be of sufficient detail and accuracy to locate all current and
              future work performed at the site.

               general geographic location;

               property lines, with the owners of all adjacent property
                      clearly indicated, and all land previously owned
                      and/or used by the Permittee around the facility;

               topography, waterways, wetlands, floodplains, water
                      features, and drainage patterns;

               all tanks, buildings, utilities, paved areas, rights-of-way, and
                       other features;

               all solid waste management units;

               all known past solid or hazardous waste treatment, storage
                      and disposal areas or units regardless of whether
                      they were active on November 19, 1980;

               surrounding land uses (residential, commercial, agricultural,
                      recreational); and

               the location of all production and ground water monitoring
                      wells. These wells shall be clearly labeled and
                      ground and top of casing elevations included (these
                      elevations may be included as an attachment).

       A history and description of ownership and operation, solid and
              hazardous waste generation, treatment, storage and disposal
              activities at the facility.

       A summary of approximate dates or periods of past waste releases,
             identification of the materials released, the amount released,
             the location released, and a description of the response actions
                         IV-28
                                            Lafarge Building Materials, Inc.
                                               EPA ID #OKD064558703


            conducted (local, state, or Federal response units, or private
            parties), including any inspection reports or technical reports
            generated as a result of the response.

     A reference to all environmental, geologic, and hydrogeologic studies
            performed by all parties, at or near the facility, with a short
            summary of the purpose, scope, and significant findings thereof.

     A reference to all environmental permits, applied for and/or received,
             the purpose thereof, and a short summary of requirements.


2)   Nature and Extent of Contamination



     a)     The Introduction shall summarize all possible source areas of
            contamination. This, at a minimum, should include all SWMUs
            listed in Part A of Section III. For each area, the Permittee shall
            identify the following:

            location of unit/area on a facility map;

            quantities of solid, hazardous, and radiochemical wastes;

            quantities of radiochemical and hazardous constituents, to
                   the extent known; and

            identification of areas where additional information is
                    necessary.


     b)     The Permittee shall prepare an assessment and description
            of the existing degree and extent of contamination. This
            should include:


            i       available monitoring data and qualitative
                    information on locations and levels of contamination
                    at the facility;



            ii      all potential migration pathways including
                    information on geology, pedology, hydrogeology,

                      IV-29
                                                      Lafarge Building Materials, Inc.
                                                         EPA ID #OKD064558703


                            physiography,     hydrology,      water           quality,
                            meteorology, and air quality; and



                    iii     the potential impact(s) on human health or the
                            environment, including demography, ground water
                            and surface water use, and land use.



     3)                     Implementation of Interim Measures

            The Permittee shall document and report on all interim measures,
            which have been or are being undertaken at the facility, including
            under state or Federal compliance orders, other than those
            specified in the Permit. The report shall include, as applicable:

            a)      Objectives of the interim measures: how the measure is
            mitigating a potential threat to human health or the environment
            and/or is consistent with and integrated into requirements for a long
            term solution;

            b)      Schedules for design, construction and monitoring;

            c)      Schedule for progress reports;

            d)      Stabilization that has occurred at the site;

            e)      Proposed further investigation and/or action; and

            Justification for limiting the scope of the RFI.


b.          Environmental Setting

     The Workplan shall provide for collection of information to supplement and
     verify existing information on the environmental setting at the facility. The
     Workplan shall provide for characterization of the following:

     1)     Hydrogeology

            The Workplan shall describe in detail a program to evaluate
            hydrogeologic conditions at the facility. This program shall provide
            for least the following information needs:




                              IV-30
                                           Lafarge Building Materials, Inc.
                                              EPA ID #OKD064558703


     a)      A description of the regional, local, facility-wide, and SWMU-
     specific geologic and hydrogeologic characteristics affecting ground
     water flow beneath the facility.

     b)     An analysis of any topographic features including surface
     water bodies that might influence the ground water flow system.

     c)      A representative and accurate classification and description
     of the hydrogeologic units which may be part of migration pathways
     at the facility (i.e., the aquifers and any intervening saturated and
     unsaturated units) based on field data, tests (e.g., gamma and
     neutron logging of existing and new wells, piezometers and
     borings), and cores.

     d)     The extent (depth, thickness, lateral extent) of hydrogeologic
     units which may be part of migration pathways based on field
     studies and cores, structural geology, and hydrogeologic cross
     sections, including:

             Unconsolidated sand and gravel deposits;

             Zones of fracturing or channeling in consolidated or
                   unconsolidated deposits; and

             Zones of high permeability or low permeability that might
                   direct and restrict the flow of contaminants.


     e)      A description of representative water level or fluid pressure
             based on data obtained from ground water monitoring
             wells and piezometers installed upgradient and
             downgradient of the potential contaminant source.
             Information needs include: potentiometric surface maps;
             hydrologic cross sections showing vertical gradients; vertical
             and horizontal components of flow; and temporal changes
             in hydraulic gradients.



     f)      A description of man-made influences that may affect site
             hydrogeology such as active and inactive local water-supply
             and production wells, pipelines, french drains, and ditches.



2)   Soils

                      IV-31
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


            The Permittee shall describe in detail a program designed to
            characterize soil and rock units above the water table. Such
            characterization may include, but is not limited to, the following
            information: surface soil distribution; soil profile, including ASTM
            and USCS classifications of soils; transects of soil stratigraphy;
            saturated hydraulic conductivity; porosity; cation exchange capacity
            (CEC); soil pH; particle size distribution; depth to water table;
            moisture content; effect of stratification on unsaturated flow;
            infiltration;  evapotranspiration;    residual     concentration   of
            contaminants in soil; total natural organic carbon content; and
            mineral and metal content.

c.   Source Characterization

     The Permittee shall describe in detail a program designed to completely
     characterize the wastes and the areas where wastes have been placed,
     including: type, quantity, physical form, composition, disposition
     (containment and nature of wastes), and the facility characteristics affecting
     releases (e.g., facility security, engineered barriers). This shall include
     quantification of the following specific characteristics, at each source area:

     1)     Unit/disposal area characteristics, including but not limited to:
            location of unit/disposal area; type of unit/disposal area; design
            features; operating practices (past and present); period of
            operation; age of unit/disposal area; general physical conditions;
            and method used to close the unit/disposal area.

     2)     Waste characteristics, including but not limited to: type of waste
            placed in unit (hazardous classification, quantity, chemical
            composition); physical and chemical characteristics (physical form,
            physical description, pH, general chemical class, density, boiling
            point, viscosity, cohesiveness, vapor pressure).

d.          Contamination Characteristics

     The Permittee shall describe in detail a program to collect analytical data
     on ground water, soils, surface water, sediment, and subsurface gas
     contamination when necessary to characterize contamination from a
     SWMU. The data shall be sufficient to define the extent, origin, direction,
     and rate of movement of contaminant plumes. Data required shall include
     time and location of sampling, media sampled, concentrations found,
     conditions during sampling, and the identity of the individual(s) performing
     the sampling and analysis. All media (ground water, surface water and
     sediments, soil, air, and gas) must be investigated. If the Permittee
     believes certain media could not be affected by a release from a specific
     unit, a detailed justification for not investigating those media must be
     provided. The Permittee shall address the following types of contamination
     at the facility as appropriate:

     1)     Ground Water Contamination
                          IV-32
                                           Lafarge Building Materials, Inc.
                                              EPA ID #OKD064558703



     The Workplan shall describe in detail a program of ground water
     investigation to characterize any ground water plumes of
     contamination at the facility that are not subject to corrective action
     requirements of 40 CFR Section 264.100 or that are not already
     being addressed through implementation of the Permittee's
     Groundwater Remediation Program described in Provision VI.C.5.
     The program shall at a minimum provide for the following
     information needs:

     a)     a description of the horizontal and vertical extent of any
            immiscible or dissolved plume(s) originating from the facility;

     b)     the horizontal and vertical direction of contamination
            movement;

     c)     the velocity of contaminant movement;

     d)     the horizontal and vertical concentrations of any 40 CFR
            264 Appendix IX constituents, or more focused constituent
            list approved by the ODEQ;

     e)     an evaluation of factors influencing the plume movement;
            and

     f)     an extrapolation of future contaminant movement.

2)   Soil Contamination

     The Permittee shall, if necessary, describe in detail a program to
     characterize contamination of soil and rock units above the water
     table in the vicinity of the contaminant release. The program shall
     provide for the following information needs:

     a)     a description of the vertical and horizontal extent of
            contamination;

     b)     a description of contaminant and soil chemical properties
            within the contaminant source area. This may include
            contaminant solubility, speciation, adsorption, leachability,
            exchange capacity, biodegradability, hydrolysis, photolysis,
            oxidation, natural total organic carbon content, and other
            factors that might affect contaminant migration and
            transformation.

     c)     plume migration and transformation; specific contaminant
            concentrations; the velocity and direction of contaminant
            movement; and an extrapolation to future contaminant
            movement.

                      IV-33
                                           Lafarge Building Materials, Inc.
                                              EPA ID #OKD064558703


3)   Surface Water and Sediment Contamination

     The Permittee shall, if necessary, describe in detail a program to
     characterize contamination in surface water bodies and sediment
     resulting from contaminant releases at the facility. The investigation
     shall at minimum include the following:

     a)     a description of the surface water body including location,
            elevation, flow, velocity, depth, width, seasonal fluctuations,
            flooding tendencies and drainage patterns.

     b)     a description of sediment characteristics including
            depositional area, thickness, mineralogy, grain size, density,
            ion exchange capacity, and total natural organic carbon
            content.

     c)     maps for all areas included in surface water and sediment
            investigations which meet requirements in 40 CFR 270.14
            and which are sufficiently detailed and accurate to depict all
            the information required.

     d)     a description of the horizontal and vertical extent of any
            immiscible or dissolved plumes originating from the facility,
            and the extent of contamination in the underlying sediments;

     e)     the horizontal and vertical direction and velocity of
            contaminant movement;

     f)     an evaluation of the physical, biological, chemical, and
            radiochemical factors influencing contaminant movement;


     an extrapolation to future contaminant movement;

     a description of the chemistry of the contaminated surface waters and
             sediments. This includes pH, temperature, total dissolved
             solids, total suspended solids, biochemical oxygen demand,
             alkalinity, conductivity, dissolved oxygen profiles, nutrients,
             chemical oxygen demand, total organic carbon, and specific
             contaminant concentrations.


4)   Air Contamination

     The Permittee shall, if necessary, describe in detail a program to
     characterize particulate and gaseous contaminants potentially
     released into the atmosphere as a result of corrective action
     activities on SWMUs.

                      IV-34
                                                     Lafarge Building Materials, Inc.
                                                        EPA ID #OKD064558703


                  Subsurface Gas

            The Permittee shall, if necessary, describe in detail a program to
            characterize the nature, rate and extent of potential releases of
            reactive gases from the SWMU as a result of corrective action
            activities on a SWMU. Such a program may include, but is not
            limited to: provisions for monitoring subsurface gases released from
            the unit, and an assessment of the potential for threat to human
            health and/or the environment.

e.          Potential Receptors

     The Permittee shall describe in detail a program to collect data to describe
     human populations and environmental systems that are susceptible to
     contaminant exposure from the facility. Chemical and radiochemical
     analysis of biological samples may be needed. Data on observable effects
     in ecosystems may also be required. The following characteristics shall be
     identified:

     1)     Local uses and possible future uses of ground water, including:

            type of use (i.e., potable, domestic, agricultural, residential, industrial,
                    municipal)

            location of all ground water wells, names of owners or tenants at those
                    locations, USGS/DODT well designations, and current use of
                    those wells within a 1 mile radius of facility.



     2)     Local uses and possible future uses of surface waters within a 1.5 mile
            radius of the facility, including domestic and municipal, recreational,
            agricultural, industrial, and environmental.



     3)     Human use of or access to the facility and adjacent lands, including but
            not limited to recreation, hunting, residential, commercial, and
            industrial.



     4)     A description of the local ecology, including biota in surface water
            bodies on, adjacent to, or affected by the facility, and a description of
            any endangered or threatened species near the facility.



f.   Data Collection Quality Assurance Plan
                              IV-35
                                               Lafarge Building Materials, Inc.
                                                  EPA ID #OKD064558703



The Permittee shall prepare a plan to document all monitoring procedures:
sampling, field measurements, and sample analysis performed at the
facility during the investigation to characterize the environmental setting,
source, and contamination, so as to ensure that all information, data, and
resulting decisions are technically sound, statistically valid, and properly
documented.

1)     The strategy section of the Data Collection Quality Assurance Plan
       shall include but not be limited to the following:

       a)     description of the intended uses for the data, and the
              necessary level of precision and accuracy for those intended
              uses;

       b)     description of methods and procedures to be used to assess
              the precision, accuracy and completeness of the
              measurement data; and

       schedule and information to be provided in quality assurance reports,
              including at least:

              periodic assessment of measurement data accuracy,
                     precision, and completeness;

              results of performance audits;

              results of systems audits; and

              significant quality assurance problems and resolutions.


2)     The Sampling and Field Measurements Section of the Data
       Collection Quality Assurance Plan shall at least discuss:



       a)     selecting appropriate sampling and field measurements
              locations, depths, etc.;



       b)     providing a statistically sufficient number of sampling and
              field measurement sites;




                        IV-36
                                  Lafarge Building Materials, Inc.
                                     EPA ID #OKD064558703


c)   determining conditions under which sampling or field
     measurements shall be conducted;



d)   determining which parameters are to be measured and
     where;



e)   selecting the frequency of sampling and length of sampling
     period, including quality control samples (duplicate
     samples);



f)   selecting the types of sample (e.g., composites vs. grabs)
     and number of samples to be collected, including field,
     equipment and trip blanks;



g)   delineating procedures designed to prevent contamination
     of sampling or field measurements equipment and cross
     contamination between sampling points;



h)   documenting field sampling operations and procedures;



i)   selecting appropriate sample containers;



j)   preserving samples;



k)   controlling chain-of-custody; and




              IV-37
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


            l)     disposing of all contaminated materials generated by
                   activities in a manner compliant with all state and Federal
                   regulations.



     3)     The Sample Analysis shall include:



            a)     chain-of-custody procedures;



            b)     sample storage procedures and holding times;



            c)     sample preparation methods;



            d)     analytical procedures;



            e)     calibration procedures and frequency;



            f)     data reduction, validation and reporting; and



            g)     frequency of internal quality control checks and laboratory
                   performance audits.



g.   Data Management Plan

     If specifically requested by the ODEQ, the Permittee shall develop and
     initiate a Data Management Plan to document and track investigation data
     and results. This plan shall identify and set up data documentation
     materials and procedures (data record), project file requirements, and
     project-related progress reporting procedures and documents.

                            IV-38
                                                  Lafarge Building Materials, Inc.
                                                     EPA ID #OKD064558703


     1)     The data record shall include at least the following for all sample
            and field measurements: unique measurement code; measurement
            location; measurement type; laboratory ID number; property or
            component analyzed; and results of analysis.

     2)     The Data Management Plan shall provide the format to be used to
            present the data and conclusions of the investigation, etc.

            a)     The following shall be presented in tables: raw data; data
                   sorted by significant features such as location, media,
                   constituent; data reduction for statistical analysis; and
                   summary data.

            b)     The following shall be presented in graphical formats (e.g.,
                   bar graphs, line graphs, plan maps, isopleth plots, cross-
                   sections, three-dimensional displays, etc.): sampling
                   location and grid; levels of contamination at each sampling
                   location; geographical extent of contamination; and changes
                   in concentration relative to source, time, depth, and other
                   parameters.

h.   Health and Safety Plan

     1)     The Permittee shall prepare a facility Health and Safety Plan, which
            shall include:

            a)     a description of the facility including availability of resources
                   such as roads, water supply, electricity and telephone
                   service;

            b)     a description of the known hazards and evaluation of the
                   risks associated with each activity conducted, including but
                   not limited to on and off-site exposure to contaminants
                   during implementation of interim measures;

            c)     a list of key personnel and alternatives responsible for site
                   safety, response operations, and for protection of public
                   health;

            d)     a delineation of the work area;

            e)     a description of levels of protection to be worn by personnel
                   in the work area;

            f)     procedures established to control site access;

            g)     decontamination procedures for personnel and equipment;

            h)     site emergency procedures;

                              IV-39
                                                    Lafarge Building Materials, Inc.
                                                       EPA ID #OKD064558703


              i)      emergency medical care procedures for injuries and
                      toxicological problems;

              j)      requirements for an environmental field monitoring program;

              k)      routine and special training requirements for responders;
                      and

              l)      procedures for protecting workers from weather-related
                      problems.

       2)     The Facility Health and Safety Plan shall be consistent with:

              a)      NIOSH Occupation Safety and Health Guidance Manual for
                      Hazardous Waste Site Activities (1985);

              b)      EPA Order 1440.1 - Respiratory Protection;

              c)      EPA Order 1440.3 - Health and Safety Requirements for
                      Employees engaged in Field Activities;

              Approved Facility Contingency Plan;

              EPA Operating Safety Guide (1984);

              OSHA regulations, particularly 29 CFR 1910 and 1926;

              State and local regulations; and

              Other EPA guidance as provided.



i)     Community Relations Plan

If specifically requested by the ODEQ, the Permittee shall prepare a plan for
dissemination of information to the public regarding investigation activities and
results.

Project Management Plan
If specifically requested by the ODEQ, the Permittee shall prepare a Project
Management Plan which will include a discussion of the technical approach,
schedules, budget, and key project personnel. The project management plan will
also include a description of qualifications of key project personnel performing or
directing the RFI, including contractor personnel. This plan shall also document
the overall management approach to the RFI.


                               IV-40
                                                                 Lafarge Building Materials, Inc.
                                                                    EPA ID #OKD064558703



     4.   Task II: RCRA Facility Investigation

          The facility investigation activities shall follow the RFI Workplan. All sampling and
          analyses shall be conducted in accordance with the Data Collection Quality
          Assurance Plan. All sampling locations shall be documented in a log and
          identified on a detailed site map. During the RFI, it may be necessary to revise the
          RFI Workplan to increase or decrease the detail of information collected to
          accommodate the facility specific situation. All changes to the RFI Workplan must
          be approved by the ODEQ and may require a modification of the permit as
          required by 40 CFR 270.42.

          The Permittee shall conduct investigations of SWMUs previously identified with
          known or suspected releases of contamination to characterize the facility
          (Environmental Setting), define the source (Source Characterization), define the
          degree and extent of contamination (Contamination Characterization), and identify
          actual or potential receptors.

          The investigations should result in data of adequate technical quality to develop
          and evaluate corrective measures alternatives during the Corrective Measures
          Study, when necessary.

     5.   Task III: RFI Final Report and Summary

          The Permittee shall analyze all facility investigation data collected during the RFI
          process and prepare a detailed report on the type and extent of contamination at
          the facility including sources and migration pathways. All information generated
          during the investigation shall be presented and analyzed. All evidence and
          procedures used for making any determinations (e.g., velocity of groundwater,
          extent of contamination) shall be fully documented. The report shall describe
          extent of contamination (qualitative/quantitative) in relation to background levels
          indicative for the area. The report shall contain the results of all tests, calculations,
          inspections, record searches, and observations. It shall contain soil and ground
          water contamination profiles, statistical comparisons, and the results of all
          sampling events conducted as part of the investigation. It shall display results in
          tables, graphs, maps, and cross sections as discussed in the Data Management
          Plan and Permit Condition VI.U.3.g.2, if applicable.

          The Permittee shall identify all relevant and applicable standards for the protection
          of human health or the environment (e.g., National Ambient Air Quality Standards,
          Federally-approved State water quality standards, ground water protection
          standards, etc.)

          Data shall be evaluated to ensure it is sufficient in quality (e.g., quality assurance
          procedures have been followed) and quantity to describe the nature and extent of
          contamination, to evaluate the potential threat to human health or the environment,
          and to support a CMS, if required. The report shall present all data in an
          Appendix.

V.        CMS SCOPE OF WORK
                                           IV-41
                                                              Lafarge Building Materials, Inc.
                                                                 EPA ID #OKD064558703



1.     Purpose

The purpose of the CMS, if required, is to develop and evaluate corrective measures
alternatives and to recommend the corrective measure or measures to be taken. The
required information shall include each item specified under CMS Tasks IV-VI. The
Permittee will furnish the personnel, materials, and services necessary to prepare the
CMS, except as otherwise specified.

If the Permittee believes that certain requirements of the Scope of Work are not
applicable, the specific requirements shall be identified and the rationale for inapplicability
shall be provided.

2.     Scope

The Corrective Measure Study consists of three tasks:

Task IV:       CMS Plan

a.                     Description of Current Situation
b.                     Establishment of Corrective Action Objectives
c.                     Description of Approach to CMS
d.                     Schedule for CMS

Task V:        Corrective Measures Study

a.                     Identification of Corrective Measures Alternatives(s)
b.                     Screening of Corrective Measures Alternatives(s)
c.                     Development of Corrective Measures Alternative(s)
d.                     Evaluation of Corrective Measures Alternative(s)
e.                     Selection of Corrective Measures Alternative(s)

Task VI:       CMS Final Report and Summary

3.     Task IV:        CMS Plan

       a.      Description of Current Conditions

               The Permittee shall briefly describe current conditions at the facility to
               update information provided in the RFI Final Report and Summary. This
               shall include previous and/or ongoing remedial activity or interim measures.

       b.      Establishment of Corrective Action Objectives

               The Permittee shall propose to the ODEQ for review and approval, facility-
               specific objectives for the corrective action. These objectives shall be
               based on public health and environmental criteria, information gathered
               during the RFI, EPA guidance, and the requirements of any applicable
               Federal statutes and regulations.

                                        IV-42
                                                           Lafarge Building Materials, Inc.
                                                              EPA ID #OKD064558703


     c.     Description of Approach to CMS

            The Permittee shall describe the general approach to the corrective
            measures study. The approach shall include identification, development,
            screening, and evaluation of the corrective measures alternatives, as
            discussed in detail in Permit Condition VI.0.4. The Permittee shall describe
            specific plans for laboratory and bench-scale studies, or field studies, if
            needed. Specific plans for evaluating remedy effectiveness shall also be
            developed. The approach shall specify formats to be used for data
            presentation, including raw data, maps, charts, graphs, engineering
            schematics, construction design, etc.

     d.     Schedule

            The Permittee shall develop a schedule for implementing the corrective
            measures study, and a schedule for submitting quarterly progress reports
            on the study implementation.

4.   Task V:       Corrective Measures Study

     The CMS consists of five parts: identification, screening, development, evaluation,
     and selection of the corrective measures alternative(s).

     a.     Identification of Preliminary Corrective Measures Alternative(s)

                   Based on the results of the RFI and the CMS Plan objectives, the
                   Permittee shall identify all possible alternatives for removal,
                   containment, treatment and/or other remediation of the
                   contamination.

     b.     Screening of Preliminary Corrective Measures Alternatives

            The Permittee shall screen the identified preliminary corrective measures
            alternatives to eliminate those that may not prove feasible to implement,
            that rely on technologies unlikely to perform satisfactorily or reliably, or that
            do not achieve the corrective action objective within a reasonable time
            period. This screening process focuses on eliminating those technologies
            which have severe limitations for a given set of waste and site-specific
            conditions. The screening step may also eliminate technologies based on
            inherent technological limitations.

            Site, waste, and technological characteristics which are used to screen
            inapplicable technologies are described in more detail below:

                   Site Characteristics. Site data should be reviewed to identify
                          conditions which may limit or promote the use of
                          certain technologies. Technologies whose use is


                                     IV-43
                                                                                              Lafarge Building Materials, Inc.
                                                                                                 EPA ID #OKD064558703


                                                    clearly precluded by site characteristics should be
                                                    eliminated from further consideration;

                                          Waste Characteristics. Identification of waste characteristics
                                               that limit the effectiveness or feasibility of
                                               technologies is an important part of the screening
                                               process.    Technologies clearly limited by waste
                                               characteristics     should     be    eliminated    from
                                               consideration.

                                          Technological Limitations.   The level of technology
                                                development, performance record, and operation and
                                                maintenance problems shall be identified for each
                                                technology considered.     Technologies that are
                                                unreliable, perform poorly, or are not fully
                                                demonstrated may be eliminated in the screening
                                                process.


                    c.                    Development of Corrective Measures Alternatives

                               The Permittee shall develop corrective measures alternatives based on
                               corrective measures objectives, and identification and screening of
                               preliminary alternatives. The Permittee shall rely on engineering practice
                               to determine which of the previously identified and screened technologies
                               appear most suitable for the site. Technologies can be combined to form
                               the overall corrective measures alternatives. The alternatives developed
                               should represent a workable number of options that each appear to
                               adequately address all site problems and corrective action objectives.
                               Each alternative may consist of an individual technology or a combination
                               of technologies. The Permittee shall document the reasons for excluding
                               technologies.

                               When a new technology is proposed or similar waste streams have not
                               routinely been treated or disposed of using the technology, the Permittee
                               shall conduct laboratory and/or bench-scale studies to determine the
                               applicability to facility conditions.  The Permittee shall analyze the
                               technologies, based on literature review, vendor contracts, and past
                               experience to determine the testing requirements.

1)   The Permittee shall develop a testing plan identifying the type(s) and goal(s) of the study(ies), the level of effort needed, and the
     procedures to be used for data management and interpretation.


                                          2)        Upon completion of testing, the Permittee shall evaluate the
                                                    testing results to assess the technology or technologies with

                                                                 IV-44
                                                 Lafarge Building Materials, Inc.
                                                    EPA ID #OKD064558703


                   respect to the site-specific questions identified in the test
                   plan.

            3)     The Permittee shall prepare a report summarizing the
                   testing program and its results, both positive and negative.

d.   Evaluation of Corrective Measures Alternative(s)

     The Permittee shall evaluate each corrective measures alternative
     developed in Permit Condition VI.V.4.c. The evaluation shall be based on
     technical, environmental, human health and institutional concerns. The
     Permittee shall also develop cost estimates for each corrective measure.

            1)     Technical, Environmental, Human Health, and Institutional
                   Concerns

                   The Permittee shall provide a description of each corrective
                   measures alternative which includes but is not limited to the
                   following: preliminary process flow sheets; preliminary sizing
                   and type of construction for buildings and structures; and
                   rough quantities of utilities required. The Permittee shall
                   evaluate each alternative in the four following areas:

                   Technical

                          The Permittee shall evaluate each corrective
                          measure alternative based on performance,
                          reliability, implementability and safety.

                   The Permittee shall evaluate performance based on the
                         effectiveness and useful life of the corrective
                         measure:

                          Effectiveness shall be evaluated in terms of the
                                  ability to perform intended functions such as
                                  containment, diversion, removal, destruction,
                                  or treatment. The effectiveness of each
                                  corrective measure shall be determined either
                                  through design specifications or by
                                  performance evaluation. Any specific waste
                                  or site characteristics which could potentially
                                  impede effectiveness shall be considered. The
                                  evaluation should also consider the
                                  effectiveness      of     combinations      of
                                  technologies.


                               IV-45
                              Lafarge Building Materials, Inc.
                                 EPA ID #OKD064558703


       Useful life is defined as the length of time the level of
               effectiveness can be maintained.            Each
               corrective measure shall be evaluated in
               terms of the projected service lives of its
               component        technologies.         Resource
               availability in the future life of the
               technology, as well as appropriateness of the
               technologies, must be considered in
               estimating the useful life of the project.

The Permittee shall provide information on the reliability of
       each corrective measure including operation and
       maintenance requirements and demonstrated
       reliability:

       Operation and maintenance requirements include
              the frequency and complexity of operation
              and maintenance. Technologies requiring
              frequent or complex operation and
              maintenance activities should be regarded as
              less reliable than technologies requiring little
              or      straightforward     operation      and
              maintenance. The availability of labor and
              materials to meet these requirements shall
              also be considered.

       Demonstrated and expected reliability is a way of
            measuring risk and effect of failure. The
            Permittee     should     evaluate    whether
            technologies have been used effectively under
            analogous      conditions;    whether     the
            combination of technologies have been used
            together effectively; whether failure of any
            one technology has an immediate impact on
            receptors; and whether the corrective
            measure has the flexibility to deal with
            uncontrollable changes at the site.

The Permittee shall describe the implementability of each
      corrective measure including relative ease of
      installation (constructibility) and total time required
      to achieve a given level of response:


         IV-46
                                      Lafarge Building Materials, Inc.
                                         EPA ID #OKD064558703


                Constructibility is determined by conditions both
                       internal and external to facility conditions
                       and includes such items as location of
                       underground utilities, depth to water table,
                       heterogeneity of subsurface materials, and
                       location of facility (i.e., remote location vs.
                       congested urban area). The Permittee shall
                       evaluate what measures can be taken to
                       facilitate construction under site specific
                       conditions. External factors which affect
                       implementation include the need for special
                       permits      or    agreements,        equipment
                       availability, and the location of suitable
                       off-site treatment or disposal facilities.

                Time has two components to be addressed: the time
                      it takes to implement a corrective measure
                      and the time it takes to see beneficial results.
                      Beneficial results are defined as the reduction
                      of contaminants to acceptable levels as
                      established in the corrective measures
                      objectives.

      The Permittee shall evaluate each corrective measures
            alternative with regard to safety. This evaluation
            shall include threats to the safety of nearby
            communities and environments as well as those to
            workers during implementation. Factors to consider
            include fire, explosion, and exposure to hazardous
            substances.

Environmental

      The Permittee shall perform an Environmental Assessment
      for each alternative. The assessment shall focus on facility
      conditions and pathways of contamination actually
      addressed by each alternative.         The Environmental
      Assessment for each alternative will include at a minimum,
      an evaluation of the short- and long-term beneficial and
      adverse effects of the response alternative, evaluation of
      any adverse effects on environmentally sensitive areas, and
      an analysis of measures to mitigate adverse impacts.

Human Health


                 IV-47
                                      Lafarge Building Materials, Inc.
                                         EPA ID #OKD064558703


        The Permittee shall assess each alternative in terms of the
        extent to which it mitigates short- and long-term potential
        exposure to any residual contamination and protects human
        health both during and after implementation of the corrective
        measure. The assessment will describe the levels and
        characterizations of contaminants on-site, potential
        exposure routes, and potentially affected populations. Each
        alternative will be evaluated to determine the level of
        exposure to contaminants and the reduction over time. For
        management of mitigation measures, the relative reduction
        of impact will be determined by comparing residual levels of
        each alternative with existing criteria, standards, or
        regulations acceptable to the ODEQ.

Institutional

        The Permittee shall assess relevant institutional needs for
        each alternative. Specifically, the effects of Federal, State,
        and Local environmental and public health standards,
        regulations, guidance, advisories, ordinances, or community
        relations on the design, operation, and timing of each
        alternative shall be considered.




                 IV-48
                                             Lafarge Building Materials, Inc.
                                                EPA ID #OKD064558703



2)   Cost Estimate

     The Permittee shall develop an estimate of the cost of each
     corrective measures alternative and for each phase or segment of
     the alternative. The cost estimate shall include capital, and
     operation and maintenance costs.

     a)    Capital costs consist of direct and indirect costs.

           Direct capital costs include:

                     Construction costs: Cost of materials, labor (including
                            fringe benefits and worker's compensation),
                            and equipment required to install the
                            corrective measures alternative;

                     Equipment costs: Costs of treatment, containment,
                           disposal and/or servicing of equipment used
                           to implement the action;

                     Land and site development costs:         Expenses
                          associated with purchase of land and
                          development of existing property; and

                     Building and services costs: Costs of process and
                            non-process buildings, utility connections,
                            purchased services, and disposal costs.

           Indirect capital costs include:

                     Engineering expenses: Costs of administration,
                            design, construction, supervision, drafting,
                            and testing of corrective measures
                            alternatives;

                     Legal     fees and license or permit costs:
                              Administrative and technical costs necessary
                              to obtain licenses and permits for installation
                              and operation;

                     Start-up and shakedown costs: Costs incurred during
                            corrective measure start-up; and



                      IV-49
                                  Lafarge Building Materials, Inc.
                                     EPA ID #OKD064558703


            Contingency allowances: Funds to cover costs
                   resulting from unforeseen circumstances such
                   as adverse weather conditions, strikes, and
                   inadequate facility characterization.


b)   Operation and maintenance costs are post-construction
     costs necessary to ensure continued effectiveness of a
     corrective measure. The Permittee shall consider the
     following operation and maintenance cost components:



     i.     Operating labor costs: Wages, salaries, training,
            overhead, and fringe benefits associated with the
            labor needed for post-construction operation;



     ii.    Maintenance materials and labor costs: Costs for
            labor, parts, and other resources required for routine
            maintenance of facilities and equipment;

     Auxiliary materials and energy: Costs of such items as
             chemicals and electricity for treatment plant
             operations, water and sewer service, and fuel;

     Purchased services: Sampling costs, laboratory fees, and
           professional fees which can be predicted;

     Disposal and treatment: Costs of transporting, treating, and
            disposing of waste materials, such as treatment
            plant residues, generated during operation;

     Administrative costs: Costs associated with administration
           of corrective measures operation and maintenance
           not included under other categories;

     Insurance, taxes, and licensing costs: Costs of such items as
            liability and accident insurance; real estate taxes on
            purchased land or rights-of-way; licensing fees for
            certain technologies; and permit renewal and
            reporting costs;


              IV-50
                                                 Lafarge Building Materials, Inc.
                                                    EPA ID #OKD064558703


                   Maintenance reserve and contingency funds: Annual
                         payments into escrow funds to cover costs of
                         anticipated replacement or rebuilding of equipment,
                         and any large unanticipated operation and
                         maintenance costs; and

                   Other costs: Items that do not fit any of the above
                         categories.


e.   Selection of Corrective Measures Alternative(s)

     The Permittee shall select a corrective measures alternative using
     technical, human health, and environmental criteria. At a minimum, the
     following criteria shall be used to select the final corrective measure or
     measures.

     1)     Technical

            a)     Performance. Corrective measure or measures which are
                   most effective at performing their intended functions and
                   maintaining performance over extended periods of time will
                   be given preference;

            b)     Reliability. Corrective measure or measures which do not
                   require frequent or complex operation and maintenance
                   activities and have proven effective under conditions similar
                   to those anticipated will be given preference;

            c)     Implementability. Corrective measure or measures which
                   can be constructed and operated to reduce levels of
                   contamination to attain or exceed applicable standards in
                   the shortest period of time will be preferred; and

            d)     Safety. Corrective measure or measures which pose the
                   least threat to the safety of nearby residents and
                   environments as well as workers during implementation will
                   be preferred.

     2)     Human Health

            The corrective measure or measures must comply with existing
            EPA criteria, standards, or regulations for the protection of human
            health. Corrective measures which provide the minimum level of
            exposure to contaminants and the maximum reduction in exposure
            with time are preferred.



                            IV-51
                                                    Lafarge Building Materials, Inc.
                                                       EPA ID #OKD064558703



      3)     Environmental

      The corrective measure or measures imposing the least adverse impact or
      greatest improvement on the environment over the shortest period of time
      will be preferred.

5.    Task VI:       CMS Final Report and Summary

The Permittee shall prepare a CMS Final Report and Summary presenting the
results of the CMS and recommending a corrective action program. The Permittee
may also submit a Partial CMS Final Report(s) for particular CMS activities or
milestones. The Report shall at a minimum include:

a.    A summary of all the corrective measures alternatives originally identified,
      and the screening rationale employed. The results of development of each
      alternative shall be described, and the evaluation of those developed shall
      be presented in detail. The report will describe the rationale for selection of
      a corrective measures alternative, including performance expectations,
      preliminary design criteria and rationale, general operation and
      maintenance requirements, and long-term monitoring requirements. The
      report shall include summary tables which allow the alternative or
      alternatives to be easily understood. Trade-offs among health risks,
      environmental effects, and other pertinent factors shall be highlighted.

b.    A proposed corrective action program that will attain compliance with
      concentration level objectives, control sources of releases, meet
      acceptable waste management requirements, and protect human health
      and the environment.

c.    Design and implementation precautions, including special technical
      problems, additional engineering data required, permits and regulatory
      requirements, access, easements, and right-of-way, health and safety
      requirements, and community relations activities.

d.    Cost estimates and schedules including capital cost estimate, operation
      and maintenance cost estimate, and project schedule (design,
      construction, operation).

e.    A schedule for corrective measure (remedy) implementation.




                               IV-52
Table 1:       RFI/CMS SUBMISSION SUMMARY

Below is an example summary of the planned reporting requirements pursuant to this Permit,
which may be required by the ODEQ for new corrective action activities whose schedule has not
already been established:

Actions                                          Due Date (examples)
Progress reports on all activities               Quarterly; no later than ninety (90) calendar days
                                                 after effective date of Permit
RFI Workplan                                     One hundred twenty (120) calendar days after
                                                 the effective date of the Permit if required
Revised RFI Workplan                             As determined by ODEQ, not less than thirty (30)
                                                 calendar days of receipt of NOD
RFI Report and Summary                           Sixty (60) calendar days after completion of RFI
Revised RFI Report and Summary                   As determined by ODEQ, not less than thirty (30)
                                                 calendar days of receipt of NOD
Notification of newly identified SWMUs           Thirty (30) calendar days after discovery
Notification of newly discovered releases        Fifteen (15) calendar days after discovery
Interim Measures Plan                            As determined by ODEQ
Revised Interim Measure Plan                     As determined by ODEQ
CMS Plan (If required)                           Forty five (45) calendar days after notification of
                                                 requirement to perform CMS
Revised CMS Plan (If required)                   As determined by ODEQ, not less than thirty (30)
                                                 calendar days of receipt of NOD
CMS Final Report and Summary (If required)       Ninety (90) calendar days after completion of
                                                 CMS
Revised CMS Final Report (If required)           As determined by the ODEQ, not less than (30)
                                                 calendar days after receipt of NOD
CMS Implementation Completion Report or Sixty (60) days after completion of corrective
Partial Completion Report(s)                     measures (excluding monitoring) or completion
                                                 of particular corrective/remedial measures or
                                                 milestones.
Demonstration of Financial Assurance at Facility One hundred and twenty (120) calendar days
                                                 after permit modification to implement corrective
                                                 measures unless Permittee is utilizing an annual
                                                 Financial Test or Corporate Guarantee as
                                                 demonstration of financial responsibility.
 Attachment 1
Waste Analysis Plan
Lafarge Building Materials, Inc.          Tulsa, OK        U.S. EPA ID No. OKD064558703




                               WASTE ANALYSIS PLAN
                                        Revision 2

                                        April 2010




Rev. 2, April 2010                   Waste Analysis Plan                       Page C-i
Lafarge Building Materials, Inc.                             Tulsa, OK                           U.S. EPA ID No. OKD064558703



                                                 Waste Analysis Plan

                                                   Table of Contents

C.1    WASTE ANALYSIS PLAN PURPOSE AND SCOPE..................................................... 1
C.2    INTRODUCTION .............................................................................................................. 2
C.3    DESCRIPTION OF PROCESS STREAMS....................................................................... 3
  C.3.1    Fuel Quality Waste Description.................................................................................. 3
  C.3.2    Cement Kiln Dust and Refractory Brick..................................................................... 5
C.4    PURPOSE OF SAMPLING AND ANALYSIS ................................................................. 7
  C.4.1    Residue Classification and Refractory Brick Status Determination ........................... 7
C.5    SAMPLING PROCEDURES AND FREQUENCIES ....................................................... 8
  C.5.1    Cement Kiln Dust ....................................................................................................... 8
  C.5.2    Used Refractory Brick ................................................................................................ 9
C.6    SAMPLE ANALYSIS ...................................................................................................... 11



                                                      List of Tables
Table C-1           Typical FQW Analysis (Organic Constituents)
Table C-2           Typical FQW Analysis (Non-Organic Constituents)
Table C-3           Sampling Methods
Table C-4           Analytical Parameters, Methods, and Rationale



                                                 List of Attachments
Attachment C-1 CKD Sampling and Analysis Plan




Rev. 2, April 2010                                    Waste Analysis Plan                                                 Page C-ii
Lafarge Building Materials, Inc.            Tulsa, OK Plant                     EPA ID #OKD064558703




                                          SECTION C
                                   WASTE ANALYSIS PLAN

C.1        WASTE ANALYSIS PLAN PURPOSE AND SCOPE

The purpose and scope of the Waste Analysis Plan (WAP) is to describe the procedures,
sampling and analysis requirements, and rationale that will be followed at the Lafarge facility to
ensure adequate information is available to identify and manage Resource Conservation and
Recovery Act (RCRA) hazardous waste safely. This WAP has been prepared in accordance with
the requirements of 40 CFR 264.13. It provides a description of the process streams and
addresses the sampling and analysis associated with those waste activities related to FQW,
cement kiln dust (CKD), and refractory brick disposal.




Revision 2, April 2010               Section C – Waste Analysis Plan                         Page C-1
Lafarge Building Materials, Inc.              Tulsa, OK Plant                       EPA ID #OKD064558703




C.2        INTRODUCTION

Lafarge owns and operates a portland cement plant in Tulsa, Oklahoma. The plant is owned and
operated by Lafarge Building Materials, Inc. Systech Environmental Corporation (Systech)
owns and operates a waste management facility co-located on the Lafarge cement plant site for
the receiving, blending, storage, and transfer to the cement kilns of fuel quality waste (FQW).
Both companies are indirect wholly owned subsidies of Lafarge North America. Together, the
FQW blending facility and the cement plant are operated as a resource recovery site. The
cement plant manufactures portland cement from limestone, clay, sand, and other materials using
two dry-process rotary kilns. The kilns may obtain up to 100% of the thermal energy required in
the cement manufacturing process through the combustion of FQW.                  The FQW replaces
traditional fossil fuels - coal, coke, and natural gas - used to provide the heat energy for the kilns.
The management of FQW at the Lafarge facility is regulated under the RCRA and the Oklahoma
Hazardous Waste Regulations, Oklahoma Administrative Code (OAC 252 et. al.).                       The
combustion of the FQW in the Lafarge cement kilns is regulated by the United States
Environmental Protection Agency (USEPA), 40 CFR Part 63, subpart EEE, Hazardous Waste
Combustor - Maximum Achievable Control Technology (MACT) regulations.




Revision 0, June 2009                  Section C – Waste Analysis Plan                           Page C-2
Lafarge Building Materials, Inc.                  Tulsa, OK Plant                  EPA ID #OKD064558703




C.3        DESCRIPTION OF PROCESS STREAMS

The feed streams associated with cement manufacturing include FQW, nonhazardous fuels, raw
materials, raw material substitutes, and recycled CKD. These feed streams produce the clinker
product and CKD (which may be recycled, handled as a product, or placed in a landfill as a
waste).       Air emissions associated with the burning of fuels and production of cement are
regulated under 40 CFR 63 Subparts EEE and LLL. Consequently, only the FQW, CKD
removed from the process, and spent refractory brick processes are described in this section.

           C.3.1 Fuel Quality Waste Description

           FQW at the Lafarge facility is considered to be “pumpable.” FQW is received and then
           blended with other FQW in the two FQW storage tanks owned and operated by Systech.
           Tanks allow for blending and transfer of FQW to maintain a relatively consistent FQW
           feed quality to the kilns.

           Liquid FQW is essentially a mixture of waste solvents from various industries such as
           paints, inks, plastics, oils, petrochemicals, pharmaceuticals, and coatings industries.
           Liquid FQW consists of organic liquids such as alcohols, paint thinners, acetone, oils,
           etc., with small amounts of dissolved and/or fine solid particles from the processes
           generating the wastes.

           Typical organic substances that may be present at some level from time to time in the
           FQW include alcohols, glycols, glycol ethers, ethers, aldehydes, polyols, ketones, esters,
           hydrocarbon degreasers, petroleum oils and derivatives, vegetable oils and derivatives,
           chlorinated organic liquids, and polymers/copolymers/oligomers/resin fragments
           including epoxies, phenolics, polyesters, acrylics, urethanes, vinyls, polyethylenes,
           polypropylenes, and styrenes.

           Tables C-1 and C-2 present the typical organic and non-organic constituent composition
           of FQW.




Revision 0, June 2009                      Section C – Waste Analysis Plan                      Page C-3
Lafarge Building Materials, Inc.                     Tulsa, OK Plant                          EPA ID #OKD064558703




                            Table C-1. Typical FQW Analysis (Organic Constituents)1

                                                                                            Average
                                   Compound                                CAS Number        wt%
           C4+ Aliphatics                                                       N/A          28.13
           C9-C10 alkylbenzenes (as n-propyl benzene)                           N/A           6.25
           Acetone                                                           67-64-1          2.60
           Toluene                                                          108-88-3          2.23
           2-Propanol                                                        67-63-0         2.06
           Xylenes                                                          1330-20-7         1.37
           MEK                                                                78-93-3        1.15
           Methanol                                                          67-56-1          0.82
           Styrene                                                          100-42-5          0.80
           Butyl Acetate                                                     123-86-4         0.80
           Methyl Amyl Ketone                                               110-12-3         0.76
           Ethanol                                                           64-17-5         0.65
           Hexane                                                            110-54-3         0.63
           N-Methyl-2-Pyrrolidone (pyrrillidone)                             872-50-4         0.56
           Butyl Cellosolve                                                 111-76-2         0.51
           1-Methoxy-3-Acetoxy-Propane (Glycol Ether)                        108-65-6         0.42
           Ethyl Acetate                                                     141-78-6         0.36
           MIBK                                                              108-10-1        0.36
           Tetrahydrofuran                                                   109-99-9         0.33
           Isopropyl Acetate (2-Propylacetate)                               108-21-4         0.33
           Ethylbenzene                                                      100-41-4         0.32
           n-Propyl Acetate                                                  109-60-4         0.19
           Acetonitrile                                                        75-5-8        0.17
           Benzene                                                            71-4-2          0.15
           Tetrachloroethylene                                               127-18-4         0.13
           Cyclohexanone (as cyclohexanol)                                   108-93-0         0.12
           Nitrobenzene                                                       98-95-3         0.12
           Methylene Chloride                                                 75-9-2          0.10
           Diacetone Alcohol                                                123-42-2         0.09
           n-Propanol (1-Propanol)                                           71-23-8         0.09
           Methyl Acetate                                                     79-20-9         0.07
           t-Butyl Methyl Ether                                              115-10-6         0.06
           Ethyl Ether                                                        60-29-7         0.06
           n-Butanol                                                         71-36-3         0.05
           Butanoic Acid Butyl Ester                                         109-21-7         0.00
           Insoluble solids                                                     N/A          27.86
           Total Moisture                                                       N/A          19.55
           1
            Organic data as presented in the Lafarge Fredonia 2003 Initial Comprehensive Performance Test (ICPT)
           Plan.




Revision 0, June 2009                         Section C – Waste Analysis Plan                              Page C-4
Lafarge Building Materials, Inc.                         Tulsa, OK Plant                             EPA ID #OKD064558703




                            Table C-2. Typical FQW Analysis (Non-Organic Constituents)1

                                    Parameter                                       HWF
                        Chlorine (%)                                                 1.1
                        Arsenic (ppm)                                                24.5
                        Beryllium (ppm)                                               1.5
                        Cadmium (ppm)                                                10.5
                        Chromium (ppm)                                              146.6
                        Lead (ppm)                                                  231.6
                        Mercury (ppm)                                                2.2
                        1
                        Metals data is the average of Lafarge Fredonia calendar year 2005 analyses


           All FQW fired in the industrial furnace comes from only one source, the on-site Systech
           fuel processing operations.               The single supplier, Systech, has prepared a Fuel
           Qualification Form for the FQW received by Lafarge from the on-site Systech operations.
           The qualification form is updated as necessary if Lafarge is notified or has reason to
           believe the FQW has changed. Each transfer from the Systech tanks to the industrial
           furnace is reviewed to demonstrate that the FQW meets the transfer requirements as
           defined in the Feedstream Analysis Plan (FAP) developed in compliance with the
           Hazardous Waste Combustor MACT (40 CFR 63 Subpart EEE). The heat content
           (determined by mathematically calculating the results of test methods based on ASTM
           D240 and/or ASTM D5468) of each transfer is used as a fingerprint test to ensure that the
           waste is as expected and is reviewed to ensure that the FQW meets the minimum energy
           recovery requirements of the industrial furnace.

           C.3.2 Cement Kiln Dust and Refractory Brick

           Process by-products consist of particulate matter removed from the stack emissions and
           spent refractory brick. The particulate matter is usually referred to as cement kiln dust
           (CKD). The CKD is captured by the air pollution control devices dedicated to each kiln
           and collected in hoppers below each unit. CKD must be sampled and analyzed in order
           to demonstrate compliance with 40 CFR 266.112(b).

           Used refractory brick is generated periodically by the removal of this material from the
           kilns during maintenance. Used kiln brick is not a listed hazardous waste, does not
           contain high chromium materials, and does not contain hazardous constituents above the

Revision2, April 2010                             Section C – Waste Analysis Plan                                 Page C-5
Lafarge Building Materials, Inc.                 Tulsa, OK Plant              EPA ID #OKD064558703



           characteristic regulatory levels. The used brick is tested to confirm the absence of
           hazardous characteristics prior to reuse or disposal.




Revision2, April 2010                     Section C – Waste Analysis Plan                  Page C-6
Lafarge Building Materials, Inc.                Tulsa, OK Plant                     EPA ID #OKD064558703




C.4        PURPOSE OF SAMPLING AND ANALYSIS

           C.4.1 Residue Classification and Refractory Brick Status Determination

           Under 40 CFR 266.112(b), it is necessary to demonstrate that burning hazardous waste in
           a cement kiln does not affect process residues. Sampling and analyses are performed to
           demonstrate that the residue does not contain toxic compounds at levels above specified
           health-based limits that could reasonably be attributable to burning or processing
           hazardous waste. This sampling and analysis is referred to as the Bevill exclusion test.

           CKD will retain the Bevill exemption as long as it can be demonstrated that the character
           of the residue is not affected by the burning of hazardous waste. For the purposes of
           waste classification, Lafarge has established a plan for determining whether CKD retains
           the exemption or must be managed as a hazardous waste, using the F039 list for organics
           and Toxic Characteristic Leaching Procedure (TCLP) list for metals.           This plan is
           provided as Attachment C-1 of the Waste Analysis Plan.

           Lafarge will also sample the used refractory brick for metals to determine its status as a
           characteristic waste. After analysis, Lafarge will handle the material according to its
           designation (see Section C.5.2).




Revision2, April 2010                    Section C – Waste Analysis Plan                         Page C-7
Lafarge Building Materials, Inc.                      Tulsa, OK Plant                                EPA ID #OKD064558703




C.5         SAMPLING PROCEDURES AND FREQUENCIES

40 CFR 266.102(b)(2) requires owners and operators to conduct sampling and analysis as
necessary to ensure that the hazardous waste, other fuels, and industrial furnace feedstocks fired
into the industrial furnace are within the physical and composition limits specified in the permit.
The Feedstream Analysis Plan (FAP), required by the HWC MACT, details the sampling and
analysis of the feed streams to assure compliance with the limitation specified in the permit.

This section explains the sampling procedures that Lafarge employs when sampling CKD and
refractory brick. To collect a sample that is representative of the process stream, the sample
must be collected and handled by means that will preserve its original physical form and
composition, as well as prevent contamination or changes in concentration of the parameters to
be analyzed. Table C-3 provides a list of sampling methods and sampling frequency to be used
for each stream.

                                                  Table C-3
                                               Sampling Methods

                                                                                                               Field
       Feed              Sampling Site    Frequency           Method              Type      Container1       Duplicate
      Stream                                                                                                 Frequency
CKD                 CKD screw            Daily sample          S-004              Grab         P,G            1 per 10
                                                                                                              samples
Used Kiln           Brick pile           Each batch           ”whole”           Composite       P             1 per 10
Brick                                                          brick                                          samples
1
    Plastic (P) or Glass (G)

            C.5.1 Cement Kiln Dust

            CKD samples will be collected as close to the air pollution control device as possible in
            order to minimize the possibility of contamination due to ambient conditions. The
            sampling point for each unit will be at the screw conveyor prior to the pneumatic pump.

            Lafarge samples the CKD (composited from both kilns) on a daily basis when CKD is
            being removed from the system (either as product or waste). The samples will be




Revision 2, April 2010                        Section C – Waste Analysis Plan                                     Page C-8
Lafarge Building Materials, Inc.                       Tulsa, OK Plant                    EPA ID #OKD064558703



           analyzed at the sampling interval specified in the CKD Sampling and Analysis plan,
           Attachment C-1.

           If the TCLP analysis confirms that any constituent is present in the CKD at levels which
           exceed the regulatory limits given at 40 CFR 266, Appendix VII, the CKD will be sent to
           a Subtitle C landfill.

           Sampling and analysis frequency for F039 organics and dioxin/furans in the CKD will be
           conducted at least once per year based upon experience at the Lafarge Fredonia, Kansas,
           facility. During the Fredonia 1995 and 2003 Trial Burns, Lafarge conducted sampling
           and analysis of CKD for F039 listed organics during minimum combustion zone
           temperatures. Under these conditions, 100% fuel substitution with FQW was practiced,
           and principle organic hazardous constituents (POHCs) selected on the basis of maximum
           thermal stability were being spiked in the waste fuel feed stream. These kiln conditions
           favor incomplete combustion and are most likely to result in contamination of the CKD
           by toxic organics; however, all of the CKD samples indicated concentrations below the
           F039 limits specified for non-wastewater Land Disposal Restrictions (40 CFR 268.40).

           C.5.2 Used Refractory Brick

           Lafarge has established the following procedures for sampling used refractory brick.

           •            Used brick will be piled on a concrete surface with rainwater runoff protection.
           •            One sample will be taken from each quadrant of the pile.
           •            The samples will be crushed and mixed to form a single composite sample to
                        represent the entire pile.
           •            The sample will be analyzed at Systech, or an off-site lab, for TCLP metals.
           •
           •            If the sample exceeds the regulatory level for any TCLP metal, it will be
                        considered hazardous.
           •            If the brick is hazardous, it will be sent off-site for proper treatment or disposal
                        within 90 days of determination that it is a regulated hazardous waste.
           •            If the brick is non-hazardous, it will be reused as a raw material ingredient in the


Revision 0, June 2009                           Section C – Waste Analysis Plan                        Page C-9
Lafarge Building Materials, Inc.                     Tulsa, OK Plant                      EPA ID #OKD064558703



                        manufacture of cement.
           •            Non-hazardous used brick will be recycled within than one year.




Revision 0, June 2009                         Section C – Waste Analysis Plan                         Page C-10
Lafarge Building Materials, Inc.                                Tulsa, OK Plant                                      EPA ID #OKD064558703




C.6        SAMPLE ANALYSIS

The samples described in Section C.5 will be prepared and analyzed according to the methods
described below:

Systech is under contractual agreement with Lafarge to perform the total metal analysis on the
refractory brick. The analyses may be performed in either the on-site or Fredonia Systech
laboratories, in the Systech corporate laboratories, or in other contracted laboratories. All CKD-
related analyses are performed following Methods 6020A, 7470A, 8260B, 8082, 8270C, 8082S,
8260S, 8270S, or 8290, as appropriate from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, SW-846, Third Edition.                                     Table C-4 describes the methods of
preparation and analysis for each parameter, as well as a description of the reason for the
analysis.

                                                    Table C-4
                                   Analytical Parameters, Methods, and Rationale

         Parameter                 Preparation1                    Analysis                             Reason for Analysis
    Volatile Organics                SW-846                      Method 8260                 CKD Exemption Determination
    Semi-volatiles                                               Method 8270                 CKD Exemption Determination
    Pesticides & PCB’s                                       Method 8081, 8082               CKD Exemption Determination
    Misc. VOC’s &                                          Methods 8015 & 8151               CKD Exemption Determination
    Herbicides
    TCLP Metals                                           Methods 1311, 6010 and             CKD Exemption Determination
                                                          7000-series (as needed)
    Dioxins/Furans                                               Method 8280                 CKD Exemption Determination
    F039 Organics                                                                            CKD Exemption Determination
    TCLP Metals                      SW-846                      Method 1311                 Refractory Brick Hazard Classification

1
 One or more of the methods are used in a modified, amended, revised, or updated form in accordance with the following quotations from the
Federal Register, February 8, 1990, pages 4440-4445, EPA Proposed Rules - Preamble to SW-846 3rd edition.
     •"This notice, or the subsequent final rule, should not be constructed to require the use of SW-846, Third Edition methods except where
     specifically prescribed by regulation."
     •"Except for those situations where the RCRA regulations specify use of a particular method, it is appropriate for the chemist to use
     judgement, tempered by experience, in selecting an appropriate set of methods from SW-846 or the scientific literature for preparing and
     analyzing a given sample."
     • "Implicit in the preceding argument is the fact that SW-846 was designed largely for use in showing that a waste does not contain certain
     hazardous constituents or characteristics. In that regard, many SW-846 sample preparation methods are designed around trace analysis
     rather than the percent level determinations often required for concentrated wastes. These methods, however, might be suitable for percent
     level determination analysis when appropriately modified by the analyst."




Revision 0, June 2009                                  Section C – Waste Analysis Plan                                               Page C-11
Lafarge Building Materials, Inc.                 Tulsa, OK Plant            EPA ID #OKD064558703




                                             Attachment C-1

                                   CKD SAMPLING AND ANALYSIS PLAN




Revision 0, June 2009                     Section C – Waste Analysis Plan               Page C-12
                         LAFARGE CEMENT KILN DUST
                        SAMPLING AND ANALYSIS PLAN




                                          Prepared for:

                                  Lafarge Midwest, Inc.
                                11130 Sunrise Valley Drive
                                  Reston, Virginia 22090



                                           Prepared by:

                                    Radian Corporation
                                   2455 Horsepen Road
                                  Herndon, Virginia 22071




                                      March 1993
                             Revised March 2006 by Lafarge
                              Revised June 2009 by Lafarge




Revision 0, June 2009       Attachment C-1 – CKD Sampling and Analysis Plan   Page Att. C-1-1
1.0       INTRODUCTION

This document defines the sampling and analysis protocol to be followed to ensure quality data
for the characterization of cement kiln dust (CKD) generated by Lafarge. CKD sampling and
analyses will be performed to meet the requirements regarding regulation of residues as outlined
in 40 CFR 266.112. All sampling and analysis will be performed in accordance with procedures
specified in EPA's Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-
846, 3rd Edition.

Lafarge may modify this document to accommodate changes in regulations or to provide new or
additional information.

2.0       ORGANIZATIONAL RESPONSIBILITY

Lafarge will have overall responsibility for implementing the sampling activities discussed in
this document. These activities include providing and training sampling personnel, scheduling
sample collection events, periodically reviewing field sampling procedures to ensure that they
are being conducted properly, and adhering to appropriate health and safety requirements. The
Environmental Manager will serve as the primary point of contact and control concerning
sampling activities at the plant.

Lafarge is responsible for providing sufficient quantities of CKD to the laboratory for use as
field/trip blanks.

Lafarge may delegate any or all of these sampling activities at its discretion.

The laboratory selected by Lafarge will have overall responsibility for implementing the
analytical activities discussed in this document. These activities include training analytical
personnel in the requirements of CKD sample preparation and analysis, ensuring that all analyses
are conducted in a timely fashion according to specified SW-846 protocols and adhering to any
special analytical techniques and QA/QC procedures (e.g., CKD trip blank) required by the
nature of the CKD matrix. The laboratory will have experience in preparing and analyzing CKD
matrices. The laboratory Client Services Coordinator or his/her designee will serve as the
primary point of contact and control concerning analytical activities at the laboratory.


Revision 0, June 2009           Attachment C-1 – CKD Sampling and Analysis Plan            Page Att. C-1-2
The laboratory may not subcontract any analytical work without the prior express written
consent of Lafarge. If work is subcontracted, the original laboratory will be responsible for
overseeing subcontractor operations.

The laboratory is responsible for supplying and preparing sampling kits as specified in Section
4.3 and sample containers as specified in Section 4.4, and then shipping them to Lafarge as
needed. Preparation includes any necessary equipment pre-cleaning that must be performed to
meet specified protocols.

3.0                     DATA QUALITY OBJECTIVES

Data quality objectives (DQOs) are guidelines for certain characteristics of data that indicate the
usefulness or reliability of the data. The DQOs for the Lafarge CKD sampling and analysis
episodes are specified in terms of accuracy, precision, comparability, completeness,
representativeness, and practical quantitation limits (PQLs). The procedures prescribed in this
document are intended to ensure that the specified DQOs for Lafarge CKD sampling and
analysis are achieved and valid data are obtained.

In any instance where a DQO is not achieved during a sampling and analysis episode, the
Lafarge Environmental Manager will be notified at once.                        The Environmental Manager is
responsible for ensuring that any necessary corrective action is taken as soon as practicable after
notification.

          3.1           Accuracy

          Accuracy is a measure of how closely a measured value agrees with the true value of a
          parameter. Accuracy will be evaluated using matrix spike and surrogate recoveries to
          determine the extent of matrix interference, and field/trip/lab blank analysis to determine
          the extent of any sample contamination.

          The DQO for matrix spike and surrogate recoveries is the recovery range specified in
          each applicable method in SW-846 or the acceptable recovery range specified by a
          laboratory performing the analysis.




Revision 0, June 2009              Attachment C-1 – CKD Sampling and Analysis Plan                Page Att. C-1-3
          Bias determined from the matrix spike recovery information will be used to correct
          measured analyte values when the average recovery is less than the minimum acceptable
          recovery range specified; bias corrections using the average recovery will be performed
          as specified in SW-846. No bias correction will be performed when the method used
          self-corrects for bias (e.g., isotope dilution), or when the matrix spike recovery is greater
          than or equal to the minimum of the acceptable recovery range specified in SW-846. The
          DQO for field/trip/lab blanks is an analyte concentration below the sample detection limit
          for all analytes of concern. If analytes are detected in blanks, corresponding sample
          concentrations for those analytes will be evaluated to determine if the sample
          concentrations are attributable to contamination according to criteria specified in
          SW-846. Affected samples will be noted.

          3.2           Precision

          Precision is a measure of the agreement among individual measurements of the same
          parameter performed under similar conditions.                        It indicates the extent of inherent
          variability in sampling and analysis procedures. Analytical precision will be evaluated
          using matrix spike/matrix spike duplicate (MS/MSD) pairs.

          The DQO for relative percent difference (RPD) between results of duplicate pair analyses
          for target organic analytes is 50% or less; for target inorganic analytes, the DQO for RPD
          is 30% or less. If a DQO for precision is not met, the impact on data quality will be
          evaluated. Where indicated, the more conservative of the matrix spike duplicate pair
          analyses, i.e., the one leading to higher analyte sample concentrations, will be used in lieu
          of the average recovery for any data reduction. In some instances, re-analysis may be
          warranted.

          3.3           Comparability

          Comparability is a measure of the degree of confidence with which one data set can be
          compared to another. The DQO for comparability will be ensured by using the same
          sampling and analysis procedures for each sampling episode. Analytical data will be




Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan                 Page Att. C-1-4
          reported in the same manner and using the same units for each test for all samples of the
          same fraction.

          3.4           Completeness

          Completeness is a measure of the amount of valid data that is collected from a sampling
          and analysis episode compared to the amount of data that was desired to be produced.
          Completeness may not always be achieved due to mishaps in sampling and sample
          shipping, analytical difficulties, etc.

          The DQO for completeness for each sampling episode is 100%. If completeness for any
          sampling and analysis episode is less than 100%, the circumstances must be documented,
          and the impact on data quality must be evaluated. Supplemental sampling and analysis
          may be required if deemed appropriate.

          3.5           Representativeness

          Representativeness is a measure of the degree to which the analytical results represent the
          population from which the sample was obtained. The DQO for representativeness will be
          ensured by following standard sampling and analysis techniques prescribed in SW-846
          and in this document.

          3.6           Practical Quantitation Limits (PQLs)

          The PQLs for target metal analytes using the standard SW-846 methods specified in
          Section 5.2 of this Attachment will be less than or equal to the TCLP Extract
          Concentration Limits for those metals, as specified in 40 CFR Part 266, Appendix VII.

          The PQLs for target organic analytes using the standard SW-846 methods specified in
          Section 5.2 of this Attachment will be less than or equal to the PQLs as listed in the
          methods for this type of matrix.               In cases where the method-specified PQL is not
          attainable due to sample matrix interferences, any data generated in those instances will
          be flagged accordingly.




Revision 0, June 2009                  Attachment C-1 – CKD Sampling and Analysis Plan       Page Att. C-1-5
4.0       SAMPLING PROCEDURES

The sampling procedures outlined below assume that the full set of sample fractions will be
collected during the same sampling and analysis episode. If less than the full set of sample
fractions for various different analyses is collected during a sampling episode, the procedures
will be modified accordingly to accommodate only the specific sample fractions necessary for
each particular sampling episode.

The prescribed sampling procedures may also require modification based on plant-specific
circumstances.            The Lafarge Environmental Manager must give prior approval before any
modifications to sampling procedures can be implemented.

All personnel involved in any aspect of sampling will be adequately trained to perform their
specific duties. In addition, they will be familiar with and abide by all relevant health and safety
requirements, including the proper use of any necessary personal protective equipment (PPE).

          4.1           General Precautions

          CKD is a powerful adsorbent. It may adsorb volatile organic compounds (VOCs) that are
          present in surrounding air to the extent that VOCs are detected when CKD samples are
          analyzed, producing a "false positive" result. Since VOCs can be generated in various
          ways (from vehicles, machinery, paints, solvents, adhesives, etc.) and can occur virtually
          anywhere, utmost caution will be observed when collecting VOC fractions of CKD
          samples. Empty or filled VOC sample containers will not be stored near waste-derived
          fuel-burning operations, vehicle exhausts, or painting, spraying, waxing, or other
          chemical operations, etc., to the extent practicable. Samples will not be collected if
          conditions persist around the sampling location that are conducive to the presence of
          VOCs (e.g., presence of gasoline engines, etc.). The Environmental Manager or his
          designee will be responsible to ensure that conditions around the sampling location are
          conducive to collecting a sample.




Revision 0, June 2009                 Attachment C-1 – CKD Sampling and Analysis Plan    Page Att. C-1-6
          4.2           Sample Fractions

          Four sample fractions will be retrieved from one grab sample collected at each sampling
          location at the Lafarge plant in the following order:

          1.            VOCs;
          2.            Semivolatiles, including Pesticides and PCBs;
          3.            Polychlorinated dibenzo-p-dioxins/dibenzofurans (Dioxins/Furans) (this fraction
                        may be discontinued following the initial sampling episode for Dioxins/Furans at
                        each site after analytical results are evaluated); and
          4.            Metals.

          4.3           Sampling Conditions

          CKD will be sampled only during normal waste-burning operations. The sampled CKD
          will be representative of CKD generated during steady-state operating conditions.
          Sampling personnel will confirm steady-state operation with the current Shift Kiln
          Burner Operator.

          4.4           Sampling Locations

          According to 40 CFR 266.112(b), to demonstrate that burning hazardous waste in a
          cement kiln does not affect waste-derived residue, i.e., CKD, the residue must not contain
          toxic compounds (above specified health-based limits) that could reasonably be
          attributable to burning or processing the hazardous waste. Therefore, samples collected
          during each sampling episode at the plant will represent recently generated CKD to
          minimize any environmental contamination that is not attributable to burning or
          processing hazardous waste. As such, CKD samples will be taken as close to the Air
          Pollution Control Device (APCD) waste dust outlets as practicable. The sampling point
          is at the screw conveyor prior to the pneumatic pump.

          4.5           Sampling Frequency

          Metals.         Lafarge will sample for TCLP metals in the CKD at a frequency to be
          determined through the evaluation of historical results. A sampling interval adequate to

Revision 0, June 2009                    Attachment C-1 – CKD Sampling and Analysis Plan     Page Att. C-1-7
          provide a 95% confidence level that the limits will not be exceeded will be statistically
          derived, and these calculations, as well as the proposed sampling interval, will be
          submitted to the Agency before the current sampling interval is modified. A minimum
          sampling frequency of once per quarter will be maintained.

          Non-Metals. Lafarge will sample CKD for non-metal constituents during the worst-case
          operating conditions (minimum combustion chamber temperature maximum hazardous
          waste feed rate) during the Trial Burn. If none of the technology-based Land Disposal
          Restriction limits for waste code F039 non-wastewaters are exceeded in these samples,
          Lafarge will sample for non-metals in the CKD at least annually.

5.0       ANALYTICAL PROCEDURES

          5.1           General Precautions

          CKD is a powerful adsorbent. It may adsorb volatile organic compounds (VOCs) that are
          present in surrounding air to the extent that VOCs are detected when CKD samples are
          analyzed, producing a "false positive" result. Since VOCs can be generated in various
          ways (from vehicles, machinery, paints, solvents, adhesives, etc.) and can occur virtually
          anywhere, utmost caution will be observed when preparing or analyzing VOC fractions
          of CKD samples. VOC sample containers will not be stored near vehicle exhausts, or
          near painting, spraying, waxing, or other chemical operations, etc., to the extent
          practicable.

          5.2           Analytical Methods

          The samples from each sampling location will be analyzed for VOCs using SW-846
          Method 8260, for Semivolatiles using Method 8270, Pesticides and PCBs using Method
          8081, Dioxins/Furans using Method 8280, for TCLP Metals using Methods 1311, 6010,
          and 7000-series methods (as needed), and for miscellaneous VOCs and Herbicides using
          Methods 8015 and 8151, respectively. This method list may be condensed, expanded, or
          otherwise substituted by the laboratory as long as the methods selected adequately
          analyze         all   target   analytes.         All     applicable       laboratory   calibration,   quality
          assurance/quality control (QA/QC), and auditing procedures will be followed.

Revision 0, June 2009                    Attachment C-1 – CKD Sampling and Analysis Plan                   Page Att. C-1-8
          5.3           Target Analyte List

          The regulations at 40 CFR 266.112(b) allow the owner or operator of a cement kiln to
          choose either of two criteria to demonstrate that the burning of FQW does not
          significantly affect the resulting CKD. Lafarge has chosen to comply with the criteria
          contained in 40 CFR 266.112(b)(2), which compares the concentration of nonmetal and
          metal constituents of concern in the waste-derived CKD with health-based limits. As
          described below, Lafarge may use the criteria contained in 40 CFR 266.112(b)(1) as a
          secondary criteria to confirm results prior to making a final determination. The specific
          requirements used for the primary method described in 40 CFR 266.112(b)(2) are:

          •             The concentration of nonmetal constituents of concern (i.e., toxic constituents
                        from Appendix VIII, 40 CFR 261 that could be reasonably attributed to the
                        hazardous waste and the Products of Incomplete Combustion listed in 40 CFR
                        266 Appendix VII) in the hazardous waste-derived CKD generally must not
                        exceed the limits specified in 40 CFR 268.40 for waste code F039 (non-waste
                        waters), "Treatment Standards for Hazardous Wastes". Constituents of concern
                        not in the F039 list do not have specified concentrations. There are special
                        considerations for problems with limits of detection that exceed the
                        concentrations specified in the F039 list as explained at § 266.112(b)(2).

                        Table 1 in Appendix A contains the list and comparison limits of nonmetal
                        constituents of concern that are used to determine compliance with 40 CFR
                        266.112(b). This list has been developed from the following lists:

                           •   The Products of Incomplete Combustion (PICs), which are listed in 40
                               CFR, Part 266, Appendix VII;
                           •   The toxic constituents from 40 CFR Part 261 Appendix VIII, that
                               reasonably could be attributed to the WDF (reasonably expected analytes,
                               or REAs); and
                           •   The chemicals that have specified non-wastewater limits as listed in the
                               F039 entry in 40 CFR 268.40.



Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan          Page Att. C-1-9
                        The determination of which REAs to include on the list is based on the list of
                        waste codes which the facility is approved to receive that are included within the
                        40 CFR 261 Appendix VIII. If an REA or a PIC is listed in the non-wastewater
                        limits in the F039 entry at 40 CFR 268.40, then it was included in the list in Table
                        1. This list is not expected to be modified since it represents significantly more
                        compounds than have been identified in the many years of WDF quarterly
                        sampling at other Lafarge facilities. The lack of presence of these compounds
                        from the CKD residues demonstrates the effectiveness of the high destruction
                        removal efficiency and the inherent capabilities of the pyroprocessing system.

          •             Table 2 of Appendix A contains the list and comparison limits of metal
                        constituents of concern that are used to determine compliance with 40 CFR
                        266.112(b). This list includes the twelve BIF residue metals (i.e., antimony,
                        arsenic, barium, beryllium, cadmium, chromium, lead, mercury, nickel, selenium,
                        silver and thallium) contained in Appendix VII, 40 CFR 266.

          •             The CKD must be sampled and analyzed as often as necessary to determine
                        whether the CKD generated during each 24-hour period has concentrations of
                        constituents of concern in excess of those referenced in the two preceding
                        paragraphs.

          The target analyte list was developed by compiling all 40 CFR Part 261, Appendix VIII
          Hazardous Constituents that could reasonably attributed to the hazardous waste (waste
          code included in the Part A) and all 40 CFR Part 266, Appendix VII Nonmetal Residue
          Concentration Limits, and then reducing that compilation to include only those
          constituents that can be analyzed by SW-846 methods according to 40 CFR Part 264,
          Appendix IX. The laboratory will analyze all listed target analytes that it is capable of
          analyzing; the laboratory will provide Lafarge with an exact list of any compounds on the
          target analyte list that it is not capable of analyzing. Matrix and analytical spikes will be
          performed using representative target analytes.




Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan         Page Att. C-1-10
          5.4           SW-846 Method Modification

          In instances where SW-846 methods require modification for analysis of CKD samples
          with analyte detection limits at or below analyte health-based limits, the laboratory will
          verify that the modification is valid, and will document the procedures and data used to
          make the validity determination. No method modification can be made without the prior
          express written consent of Lafarge.




Revision 0, June 2009                Attachment C-1 – CKD Sampling and Analysis Plan    Page Att. C-1-11
                                      Appendix A
                          TARGET ANALYTE LISTS




Revision 0, June 2009   Attachment C-1 – CKD Sampling and Analysis Plan   Page Att. C-1-12
                                  Table 1 – Non-Metals Target Analyte List
                                                                       Chemical
                              Common name                                               Conc. Mg/kg
                                                                      abstracts No.
            p-Nitroaniline                                              100-01-6            28
            p-Nitrophenol                                               100-02-7            29
            cis-1,3-Dichloropropene (as part of 1,3-
                                                                      10061-01-5            18
            Dichloropropene)
            trans-1,3-Dichloropropene (as part of 1,3-
                                                                      10061-02-6            18
            Dichloropropene)
            N-Nitrosopiperidine                                         100-75-4            35
            4,4'-Methylenebis(2-chloroaniline)                          101-14-4            30
            4-Bromophenyl phenyl ether                                  101-55-3            15
            Heptachlor epoxide                                         1024-57-3           0.066
            2,4-Dimethylphenol                                          105-67-9            14
            p-Cresol (as part of Cresols or Cresylic Acid)              106-44-5            5.6
            p-Dichlorobenzene                                           106-46-7            6
            p-Chloroaniline                                             106-47-8            16
            Ethylene dibromide                                          106-93-4            15
            3-Chloropropene (Allyl chloride)                            107-05-1            30
            Ethylene dichloride                                         107-06-2             6
            Acrylonitrile                                               107-13-1            84
            Methyl isobutyl ketone                                      108–10–1            33
            m-Cresol (as part of Cresols or Cresylic Acid)              108-39-4            5.6
            Toluene                                                     108-88-3            10
            Chlorobenzene                                               108-90-7             6
            Phenol                                                      108-95-2            6.2
            Pyridine                                                    110-86-1            16
            Dichloroethyl ether [ Bis(2-chloroethyl) ether]             111-44-4            6
            Dichloromethoxy ethane [
                                                                        111-91-1            7.2
            Bis(chloromethylether)]
            Diethylhexyl phthalate [Bis(2-ethylhexyl)
                                                                        117-81-7            28
            phthalate]
            Di-n-octyl phthalate                                        117–84–0            28
            Hexachlorobenzene                                           118-74-1            10
            Isosafrole                                                  120-58-1            2.6
            2,4-Dichlorophenol                                          120-83-2            14
            2,4-Dinitrotoluene                                          121-14-2            140
            1,4-Diethyleneoxide                                         123-91-1            170


Revision 0, June 2009                 Attachment C-1 – CKD Sampling and Analysis Plan                 Page Att. C-1-13
                                   Table 1 – Non-Metals Target Analyte List
                                                                         Chemical
                             Common name                                                  Conc. Mg/kg
                                                                        abstracts No.
            Methacrylonitrile                                             126-98-7            84
            Tetrachloroethylene                                           127-18-4            6
            Dimethyl phthalate                                            131-11-3            28
            Xylene                                                      1330–20–7             30
            Polychlorinated biphenyls                                    1336-36-3            10
            Ethyl acetate                                                 141–78–6            33
            Kepone                                                        143-50-0           0.13
            1,2-Dichloroethylene                                          156-60-5            30
            Hexachloropropene                                            1888-71-7            30
            Indeno[1,2,3-cd]pyrene                                        193-39-5            3.4
            Fluoranthene                                                  206-44-0            3.4
            Chrysene                                                      218-01-9            3.4
            Pronamide                                                   23950-58-5            1.5
            Methyl parathion                                              298-00-0            4.6
            Phorate                                                       298-02-2            4.6
            Disulfoton                                                    298-04-4            6.2
            Aldrin                                                        309-00-2           0.066
            Isodrin                                                       465-73-6           0.066
            DDT                                                             50-29-3          0.087
            Benzo[a]pyrene                                                  50-32-8           3.4
            2,4-Dinitrophenol                                               51-28-5          160
            Famphur                                                         52-85-7           15
            4,6-Dinitro-o-cresol                                          534-52-1            160
            Dibenz[a,h]anthracene                                           53-70-3           8.2
            2-Acetylaminefluarone                                           53-96-3           140
            m-Dichlorobenzene                                             541-73-1             6
            N-Nitrosodiethylamine                                           55-18-5           28
            Carbon tetrachloride                                            56-23-5            6
            Parathion                                                       56-38-2           4.6
            3-Methylcholanthrene                                            56-49-5           15
            Benz[a]anthracene                                               56-55-3           3.4
            Chlordane                                                       57-74-9          0.26
            Lindane                                                         58-89-9          0.066



Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan                 Page Att. C-1-14
                                 Table 1 – Non-Metals Target Analyte List
                                                                         Chemical
                               Common name                                                Conc. Mg/kg
                                                                        abstracts No.
            2,3,4,6-Tetrachlorophenol                                       58-90-2           7.4
            p-Chloro-m-cresol                                               59-50-7           14
            Ethyl ether                                                    60–29–7            160
            Dieldrin                                                        60-57-1          0.13
            2,6-Dinitrotoluene                                            606-20-2            28
            Pentachlorobenzene                                            608-93-5            10
            Phenacetin                                                      62-44-2           16
            Aniline                                                         62-53-3           14
            1,1,1,2-Tetrachloroethane                                     630-20-6             6
            Acetone                                                        67–64–1           160
            Chloroform                                                      67-66-3           6
            Hexachloroethane                                                67-72-1           30
            n-Butyl alcohol                                                71–36–3            2.6
            Benzene                                                         71-43-2           10
            1,1,1-Trichloroethane                                           71-55-6           6
            Endrin                                                          72-20-8          0.13
            Methoxychlor                                                    72-43-5          0.18
            DDD                                                             72-54-8          0.087
            Methyl bromide                                                  74-83-9           15
            Methyl chloride                                                 74-87-3           30
            Methyl iodide                                                   74-88-4           65
            Methylene bromide                                               74-95-3           15
            Vinyl chloride                                                  75-01-4           6
            Methylene chloride                                              75-09-2           30
            Bromoform                                                       75-25-2           15
            Ethylidene dichloride                                           75-34-3            6
            1,1-Dichloroethylene                                            75-35-4            6
            Trichlorofluoromethane                                          75-69-4           30
            Dichlorodifluoromethane                                         75-71-8           7.2
            Heptachlor                                                      76-44-8          0.066
            Hexachlorocyclopentadiene                                       77-47-4           2.4
            Isobutyl alcohol                                                78-83-1           170
            Propylene dichloride                                            78-87-5           18



Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan                 Page Att. C-1-15
                                  Table 1 – Non-Metals Target Analyte List
                                                                         Chemical
                             Common name                                                  Conc. Mg/kg
                                                                        abstracts No.
            Methyl ethyl ketone (MEK)                                       78-93-3           36
            1,1,2-Trichloroethane                                           79-00-5           6
            Trichloroethylene                                               79-01-6            6
            1,1,2,2-Tetrachloroethane                                       79-34-5            6
            Toxaphene                                                    8001-35-2            2.6
            Methyl methacrylate                                             80-62-6           160
            Pentachloronitrobenzene (PCNB)                                  82-68-8           4.8
            Diethyl phthalate                                               84-66-2           28
            Dibutyl phthalate                                               84-74-2           28
            2,6-Dichlorophenol                                              87-65-0           14
            Hexachlorobutadiene                                             87-68-3           5.6
            Pentachlorophenol                                               87-86-5           7.4
            2,4,6-Trichlorophenol                                           88-06-2           7.4
            Dinoseb                                                         88-85-7           2.5
            Naphthalene                                                     91-20-3           5.6
            beta-Chloronaphthalene                                          91-58-7           5.6
            Methapyrilene                                                   91-80-5           1.5
            N-Nitrosodi-n-butylamine                                      924-16-3            17
            N-Nitrosopyrrolidine                                          930-55-2            35
            Safrole                                                         94-59-7           22
            2,4-D                                                           94-75-7           10
            o-Cresol (as part of Cresols or Cresylic Acid)                  95-48-7           5.6
            o-Dichlorobenzene                                               95-50-1            6
            o-Chlorophenol                                                  95-57-8           5.7
            1,2,4,5-Tetrachlorobenzene                                      95-94-3           14
            2,4,5-Trichlorophenol                                           95-95-4           7.4
            1,2-Dibromo-3-chloropropane                                     96-12-8           15
            Ethyl methacrylate                                              97-63-2           160
            Acetophenone                                                    98-86-2           9.7
            Nitrobenzene                                                    98-95-3           14
            5-Nitro-o-toluidine                                             99-55-8           28
            Hexachlorodibenzo-p-dioxins (HxCDD)                                              0.001




Revision 0, June 2009                   Attachment C-1 – CKD Sampling and Analysis Plan                 Page Att. C-1-16
                                    Table 2 –Metals Target Analyte List

                                                                         Concentration limit
                        Compound                 CAS No.
                                                                              (mg/L)
                        Antimony                 7440-36-0                        1
                        Arsenic                  7440-38-2                       5
                        Barium                   7440-39-3                      100
                        Beryllium                7440-41-7                     0.007
                        Cadmium                  7440-43-9                        1
                        Chromium                 7440-47-3                        5
                        Lead                     7439-92-1                       5
                        Mercury                  7439-97-6                      0.2
                        Nickel                   7440-02-0                       70
                        Selenium                 7782-49-2                       1
                        Silver                   7440-22-4                       5
                        Thallium                 7440-28-0                       7




Revision 0, June 2009                Attachment C-1 – CKD Sampling and Analysis Plan           Page Att. C-1-17
 Attachment 2
Procedures to Prevent
      Hazards
Lafarge Building Materials, Inc.             Tulsa, OK             U.S. EPA ID No. OKD064558703




            PROCEDURES TO PREVENT HAZARDS
                                           Revision 2

                                           April 2010




Rev. 2, April 2010                 Procedures to Prevent Hazards                       Page F-i
Lafarge Building Materials, Inc.                                 Tulsa, OK                              U.S. EPA ID No. OKD064558703



                                          Procedures to Prevent Hazards

                                                      Table of Contents

F.1    Security Plan ....................................................................................................................... 1
F.2    Inspection Plan ................................................................................................................... 2
F.3    Preparedness and Prevention .............................................................................................. 3
  F.3.1     Emergency Equipment................................................................................................ 3
    F.3.1.1 Internal Communication and Alarm System........................................................... 3
    F.3.1.2 External Communication System ........................................................................... 4
    F.3.1.3 Emergency Equipment............................................................................................ 4
    F.3.1.4 Water for Fire Control ............................................................................................ 6
  F.3.2     Equipment Testing and Maintenance.......................................................................... 6
  F.3.3     Access to Communication or Alarm System .............................................................. 6
  F.3.4     Required Aisle Space.................................................................................................. 6
  F.3.5     Arrangements with Local Authorities......................................................................... 7
  F.3.6     Waiver of Preparedness and Prevention Requirements .............................................. 7
F.4    Preventative Procedures, Structures, and Equipment ......................................................... 8
  F.4.1     Loading/Unloading Operations................................................................................... 8
  F.4.2     Run-on/Run-off........................................................................................................... 8
  F.4.3     Water Supplies ............................................................................................................ 9
  F.4.4     Equipment Failure and Power Outages....................................................................... 9
  F.4.5     Personal Protective Equipment ................................................................................... 9
  F.4.6     Releases to the Atmosphere ........................................................................................ 9
F.5    Prevention of Reaction or Ignition.................................................................................... 11
  F.5.1     Precautions for Handling Ignitable Wastes............................................................... 11
  F.5.2     Identification of Waste Characteristics..................................................................... 11



                                                     List of Attachments
Att. F-1                Security Plan
Att. F-2                Inspection Plan




Rev. 2, April 2010                                  Procedures to Prevent Hazards                                                  Page F-ii
Lafarge Building Materials, Inc.                   Tulsa, OK              U.S. EPA ID No. OKD064558703



                                                SECTION F

                                   PROCEDURES TO PREVENT HAZARDS

The information presented in this section is submitted in accordance with the requirements of 40
CFR 264.14, 264.15, 264.30 through 264.37, 266.102, 270.14, and O.A.C.252:205-3-2(f).

F.1      SECURITY PLAN

         In accordance with 40 CFR 264.14 and 270.14(b)(4), and OAC 252:205-3-2(f), the
         Lafarge Tulsa plant has developed a security plan to prevent the unknowing entry, and
         minimize the possibility for the unauthorized entry, of persons or livestock onto the
         active portion of the facility.        A copy of this plan and how Lafarge meets the
         requirements of these regulations is included in Attachment F-1.




Rev. 2, April 2010                        Procedures to Prevent Hazards                       Page F-1
Lafarge Building Materials, Inc.             Tulsa, OK               U.S. EPA ID No. OKD064558703



F.2      INSPECTION PLAN

A written inspection plan has been developed for the timely detection of equipment malfunctions
or deterioration, operator errors, and waste discharges at the Lafarge plant to meet the
requirements of 40 FCR 264.15 and 264.14(b)(5). A copy of this plan is included in Attachment
F-2.




Rev. 2, April 2010                  Procedures to Prevent Hazards                        Page F-2
Lafarge Building Materials, Inc.                     Tulsa, OK               U.S. EPA ID No. OKD064558703



F.3      PREPAREDNESS AND PREVENTION

This facility is designed, constructed, maintained, and operated to minimize the possibility of a
fire, explosion or any unplanned release of hazardous waste or hazardous waste constituents to
air, soil, or surface water that could threaten human health or the environment. Should an
unavoidable incident occur, personnel are trained to respond to emergencies and to minimize
associated risks.

To comply with 40 CFR Part 264, Subpart C, the plant has:

         •           Designed and equipped the plant for maximum safety;
         •           Prepared emergency response plans; and
         •           Made arrangements with local authorities for emergency response.

         F.3.1 Emergency Equipment

         The following equipment is required at the Lafarge Tulsa plant to effectively respond to
         emergencies:

              •         Internal alarms and communications devices to provide immediate emergency
                        instruction to facility personnel;
              •         External communications equipment to summon outside assistance;
              •         Fire-fighting equipment;
              •         Spill control and decontamination equipment; and
              •         Adequate spill clean-up equipment.

                     F.3.1.1       Internal Communication and Alarm System

                     Plant personnel can alert others to the existence of a possible emergency by voice
                     contact, by telephone, by two-way radio, or by activating the plant-wide alarm
                     system. Telephones are located throughout the plant and can be used as necessary
                     for emergency communications. Two telephones, that are available at all times,
                     are located in the Control Room. The Control Room is located near the hot ends
                     of the kilns where fuels are introduced and is manned at all times when the kiln is


Rev. 2, April 2010                          Procedures to Prevent Hazards                        Page F-3
Lafarge Building Materials, Inc.                     Tulsa, OK                   U.S. EPA ID No. OKD064558703



                     in operation. Closed circuit television between the Control Room and the kilns
                     allows visible access to the hot ends of the kilns. Both kilns are controlled and
                     monitored from the Control Room.                   The Control Room Operator can
                     communicate with Lafarge or Systech via these two telephones.

                     All on-site Emergency Coordinators (Shift Supervisor/Leadman) carry portable
                     radios at all times when on duty. Radios are also available in the front office and
                     various managers’ offices that are available during normal working hours. A
                     radio with two frequencies (Lafarge and Systech) is also available at all times in
                     the Control Room.

                     The internal telephone system includes a plant-wide paging capability, intercoms,
                     and an emergency alarm system. Personnel can use the telephone system to
                     activate the alarm system if necessary. The alarm signal is a continuous blast on a
                     warning siren that is clearly audible throughout the plant.

                     F.3.1.2        External Communication System

                     The internal telephone system also provides access to external telephone networks
                     needed to summon emergency response teams. The telephones located in the
                     Control Room have a separate plant line and both access an outside line. Because
                     the Control Room is manned at all times and both kilns are controlled and
                     monitored from the Control Room, the Control Room telephones will serve as
                     main conduits for external communication.              Emergency contact telephone
                     numbers are posted at the Control Room telephones.

                     F.3.1.3        Emergency Equipment

                     The emergency equipment has been selected to provide an adequate amount of
                     equipment for those employees directly involved in responding to an emergency;
                     all other employees would evacuate the immediate response area and report to the
                     rally point.




Rev. 2, April 2010                          Procedures to Prevent Hazards                            Page F-4
Lafarge Building Materials, Inc.                      Tulsa, OK               U.S. EPA ID No. OKD064558703



                     Fire Control Equipment

                     Several systems are in place to prevent fires from occurring and to minimize them
                     if they do occur.      First, operating personnel monitor the areas to eliminate
                     combustible material that could contribute to a fire. Therefore, there is virtually
                     nothing present on the kiln floors that is combustible except the fuel, which is
                     contained within a pipe. Second, at least one (1) 120-pound dry chemical fire
                     extinguisher is available in the plant's kiln area to control any fires. Personnel
                     would use this equipment to immediately extinguish any fire that did start. Third,
                     Lafarge controls the pump that supplies FQW to the kiln. In the unlikely event
                     that an accident did occur or a fire did start, Lafarge would stop the pump to
                     prevent additional waste fuel from being transferred to the kiln area. The operator
                     located in the Control Room has total control over the FQW feed pumps located
                     at Systech. The operator not only controls the FQW flow rate, he also can enable
                     and disable the operation of the pumps. Systech cannot start a pump unless it has
                     been enabled by Lafarge. Systech also has no control over the pumping rate of
                     the pumps. In addition, all of the automatic waste feed cutoffs (AWFCOs) are
                     interconnected with not only the AWFCO valve, but also with the FQW pumps.
                     If an AWFCO occurs, the pump is also automatically shut off, and cannot be
                     restarted until Lafarge enables the pump, and Systech manually re-starts the
                     pump. Automatic pump shut-offs are triggered by various safety parameters
                     within the requirements of the HWC MACT compliance. For example, a high
                     fuel line pressure or a high pump pressure will turn off the FQW feed pumps.

                     In the highly unlikely event that there is a sustained fire, there is adequate water
                     available to control the fire.

                     Spill Control Equipment

                     Solvent absorbent booms and absorbents stored in drums or buckets can be used
                     to contain and clean up spills. The boom systems range in length from four to ten
                     feet and can be linked together to form containment dikes or to absorb spills.



Rev. 2, April 2010                           Procedures to Prevent Hazards                        Page F-5
Lafarge Building Materials, Inc.                     Tulsa, OK                U.S. EPA ID No. OKD064558703



                     Other equipment such as shovels, brooms, and containers are readily available on
                     site. Heavy equipment is available upon request within the cement plant.

                     Decontamination equipment

                     Equipment and clothing that cannot be decontaminated is sealed in containers and
                     subsequently transported to an appropriate facility for disposal. Equipment and
                     clothing that can be cleaned will be placed in containers until the cleaning and
                     decontamination can be accomplished. A pressure washer, cleaner, clean mineral
                     spirits solvent, and soap and water are available.

                     F.3.1.4       Water for Fire Control

                     The primary water supply for fire control is an 8-inch city water main.

         F.3.2 Equipment Testing and Maintenance

         All emergency communications equipment, alarm systems, and fire protection, spill
         control, and decontamination equipment is inspected according to the inspection schedule
         included in Attachment F-2.

         F.3.3 Access to Communication or Alarm System

         Lafarge operations personnel involved in kiln operations and fuel delivery carry portable
         radios when working outside the office/laboratory complex providing them immediate
         access to emergency communications equipment. The internal alarm system can be
         activated by the control. Room operator. Telephones throughout the plant and kiln
         control room are manned 24 hours per day.

         F.3.4 Required Aisle Space

         Aisle space is maintained in the plant's kiln area to allow unobstructed movement of
         personnel, fire response equipment, spill control equipment, and decontamination
         equipment.




Rev. 2, April 2010                          Procedures to Prevent Hazards                         Page F-6
Lafarge Building Materials, Inc.                    Tulsa, OK                    U.S. EPA ID No. OKD064558703



         F.3.5 Arrangements with Local Authorities

         The Lafarge plant has made arrangements with local authorities as described in the
         Contingency Plan in Section G. including the Sheriff's Department, the Fire Department,
         the Hospital, and Ambulance Service, to provide emergency services during a fire,
         explosion, or major release of hazardous waste. The primary or alternate Emergency
         Coordinator, or his/her designee, can contact the local authorities by telephone to request
         emergency services. These groups have been briefed on the following information:

                     •       Layout of the plant;
                     •       Properties of hazardous wastes handled at the plant and associated
                             hazards;
                     •       Places where personnel would normally be working;
                     •       Entrances to and roads within the plant area; and
                     •       Evacuation routes.

         All local authorities who enter into an agreement with the Lafarge plant receive a copy of
         the plant's Contingency Plan and any updates or modifications to the Plan as they become
         available. Lafarge will maintain copies of the agreements or refusal to enter into an
         agreement in the facility operating record.

         F.3.6 Waiver of Preparedness and Prevention Requirements

         The Lafarge plant does not request a waiver of preparedness and prevention
         requirements.




Rev. 2, April 2010                         Procedures to Prevent Hazards                             Page F-7
Lafarge Building Materials, Inc.                Tulsa, OK                U.S. EPA ID No. OKD064558703



F.4      PREVENTATIVE PROCEDURES, STRUCTURES, AND EQUIPMENT

The following sections provide information on preventative procedures, structures, and
equipment at the Lafarge plant.

         F.4.1 Loading/Unloading Operations

         Loading/unloading operations from trucks are carried out at the Systech storage facility.
         The liquid FQW used at the Lafarge Tulsa plant is piped directly from the storage tanks
         owned and operated by Systech to the plant’s kilns. All unloading procedures take place
         while the hazardous waste is still in Systech's custody and are covered under Systech's
         permit.

         F.4.2 Run-on/Run-off

         No permitted storage of hazardous wastes occurs on-site at the Lafarge plant, minimizing
         the potential for leaks and resulting runoff. Samples of hazardous waste may be stored
         for short periods of time within buildings where spills may be readily contained.

         The kiln hoods are within roofed areas. If a spill occurs at the kiln, rainwater can not
         come in contact with the spill.

         The FQW transfer piping between storage at Systech and the kilns meets the
         requirements of 40 CFR 264.193(f)(1) and (2) by being inspected daily for leaks and all
         flanges, joints, and connections are welded. If leaks are found, repairs are initiated to
         minimize the amount of spilled material.

         Because of these precautions, Lafarge does not anticipate any leaks or spills on the
         Lafarge site that could not be immediately controlled through the procedures specified in
         the emergency response plan (Section G of this document). Following the steps outlined
         in the emergency response plan should ensure that no wastes come into contact with plant
         runoff.




Rev. 2, April 2010                     Procedures to Prevent Hazards                         Page F-8
Lafarge Building Materials, Inc.                Tulsa, OK               U.S. EPA ID No. OKD064558703



         F.4.3 Water Supplies

         As stated above, precautions are in place to prevent the runoff of hazardous waste in the
         unlikely event a spill occurs. Because potential runoff of hazardous waste is controlled,
         the possible contamination of surface water from a spill is minimized. There is little
         chance of rainwater contacting the hazardous waste, and if it does, it will be collected
         before it can reach the environment.

         There are no drinking water wells within ¼ mile from the plant boundary. Groundwater
         is not generally used for drinking water supplies.

         F.4.4 Equipment Failure and Power Outages

         The kilns at the Lafarge Tulsa plant have auxiliary power supplied by a diesel-powered
         generator to maintain rotation of the kilns at all times. The AWFCO system engages in
         the event of a power failure or emergency shut-down of the induced draft fans or
         baghouse.

         F.4.5 Personal Protective Equipment

         FQW managed at the Lafarge plant kilns is hard-piped directly into the kilns, thus
         limiting exposure of plant personnel to this waste. Personnel receive training according
         to RCRA/MSHA guidelines that includes information on how to minimize exposure to
         hazardous waste. Lafarge personnel do not handle hazardous waste fuel. All sampling,
         testing, blending, and storage is performed by trained personnel at Systech.          If a
         hazardous waste spill occurs, Lafarge personnel immediately notify Systech and Systech
         provides trained personnel to clean up the spill, as specified in the written agreement
         between Lafarge and Systech. Lafarge has personal protective equipment available (see
         list in Attachment F-2) for short-term exposures in emergency situations, but Lafarge
         personnel do not routinely undertake activities that would allow exposure.

         F.4.6 Releases to the Atmosphere

         Baghouses are used to control particulate emissions to the atmosphere from the kilns to
         within the emission standards specified by the HWC MACT Rule. Operating parameter

Rev. 2, April 2010                     Procedures to Prevent Hazards                        Page F-9
Lafarge Building Materials, Inc.              Tulsa, OK               U.S. EPA ID No. OKD064558703



         limits for hazardous waste burning modes of operation as established during the
         comprehensive performance testing required by HWC MACT are included in Lafarge’s
         Title V Operating Permit.

         The kilns operate under negative pressure, thereby preventing fugitive emissions.
         Hazardous waste is transferred by sealed piping under a leak detection and repair
         program to minimize releases. No open containers of hazardous waste are used. All
         liquid storage tanks maintained by Systech are sealed and vented to the kiln to destroy
         any vapors.




Rev. 2, April 2010                   Procedures to Prevent Hazards                       Page F-10
Lafarge Building Materials, Inc.                   Tulsa, OK              U.S. EPA ID No. OKD064558703



F.5      PREVENTION OF REACTION OR IGNITION

All FQW is hard-piped to the kiln areas and are physically separated and protected from sources
of ignition or reaction, including but not limited to: open flames, smoking, cutting, welding, hot
surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition, and
radiant heat. There is not a possibility of ignition under normal circumstances.

"NO SMOKING" signs are posted on the kiln floors in the area where the ignitable waste valves,
meters, and connections are located. "NO UNAUTHORIZED PERSONNEL" signs (or signs
conveying a similar message) are also posted in the kiln area.

         F.5.1 Precautions for Handling Ignitable Wastes

         The Lafarge plant neither handles nor mixes any hazardous waste-derived fuels. The
         co-located Systech storage facility premixes the liquid FQW and delivers it directly to the
         Lafarge plant kilns through hard pipes.

         Compatibility testing, achieved by mixing delivery vehicle samples with storage tank
         samples, is performed by Systech to ensure that wastes can be mixed in the tank systems
         without undesirable results.

         F.5.2 Identification of Waste Characteristics

         All hazardous wastes are assumed to be ignitable. Waste handling processes are designed
         accordingly. No incompatible, corrosive, or reactive hazardous wastes are accepted at
         the Lafarge plant. While Lafarge is responsible for the compliance with the state and
         federal regulations regarding the burning of hazardous waste, Systech conducts the
         identification and approval of all wastes used at the plant in accordance with a written
         agreement.         Lafarge will not burn wastes that exhibit the RCRA characteristic of
         reactivity or corrosivity. Nor will Lafarge burn waste that contains insufficient energy to
         make a positive contribution to the manufacturing process.




Rev. 2, April 2010                        Procedures to Prevent Hazards                      Page F-11
Lafarge Building Materials, Inc.       Tulsa, OK      U.S. EPA ID No. OKD064558703




                                    Attachment F-1

                                   SECURITY PLAN




Rev. 2, April 2010                    Security Plan                  Page Att. F-1-1
Lafarge Building Materials, Inc.                  Tulsa, OK               U.S. EPA ID No. OKD064558703



1.        Security Plan

In accordance with 40 CFR 264.14 and 270.14(b)(4), and OAC 252:205-3-2(f), the Lafarge
Tulsa plant has developed a security plan to prevent the unknowing entry, and minimize the
possibility for the unauthorized entry, of persons or livestock onto the active portion of the
facility.    Plant personnel are on site 24 hours per day and use hand-held radios, portable
telephones, and the plant's internal telephone system to provide an immediate means of
communication if a breach of security occurs. Visitor access to the plant is controlled by
requiring all visitors to register at the main office or control room and to be escorted by a plant
employee at all times. Systech personnel employed by the on-site Systech operation are not
considered to be visitors.         Certain vendors and contractors that are routinely onsite or for
extended periods of time may not be escorted but will have received introductory safety training
to familiarize them with the locations and hazards associated with the FQW to ensure they are
not unduly exposed. Plant employees are instructed to stop and question unescorted visitors
about their presence. Remote areas of the plant have perimeter fencing to prevent unauthorized
access.

          1.1        24-Hour Surveillance System

          A surveillance system is used to continuously monitor the kiln floors and FQW controls
          on the burn floors. Television monitors are manned 24 hours a day, seven days a week,
          from a central control room. The active area of the Lafarge kilns is relatively small,
          aiding in surveillance of the area.

          In addition, a Kiln Burner Operator is on duty at all times in the Lafarge Control Room
          when the kiln is operating.           The Kiln Burner Operator, along with the Shift
          Supervisor/Leadman, is responsible for ensuring that no unauthorized personnel are in the
          area.

          1.2        Warning Signs

          Signs bearing the legend "DANGER--UNAUTHORIZED PERSONNEL KEEP OUT" or
          similar language are posted at entrances to the Lafarge facility and at access stairways to



Rev. 2, April 2010                               Security Plan                           Page Att. F-1-2
Lafarge Building Materials, Inc.                  Tulsa, OK             U.S. EPA ID No. OKD064558703



         the kiln floor area. These signs are legible from a distance of at least 25 feet and are
         visible from all angles of approach to the kiln floors.

         1.3         Fencing and Access Control

         The Lafarge facility is surrounded by a fence to prevent the unknowing entry, and
         minimize the unauthorized entry, of personnel or livestock onto the active portion of the
         facility. The main gate is closed and provided with access control during overnights and
         weekends and all other gates are closed and locked during those times.

         1.4         Waiver

         The Lafarge Tulsa plant does not request a waiver from security requirements under 40
         CFR 264.14(a).




Rev. 2, April 2010                            Security Plan                            Page Att. F-1-3
Lafarge Building Materials, Inc.        Tulsa, OK       U.S. EPA ID No. OKD064558703




                                    Attachment F-2
                                   INSPECTION PLAN




Rev. 2, April 2010                    Inspection Plan                  Page Att. F-2-1
Lafarge Building Materials, Inc.                     Tulsa, OK                       EPA ID #OKD064558703




1.         Inspection Plan

A written inspection schedule has been developed for the timely detection of equipment
malfunctions or deterioration, operator errors, and waste discharges at the Lafarge plant to meet
the requirements of 40 FCR 264.15 and 264.14(b)(5).

The schedule provides for the routine inspection of, as applicable:

           •          Monitoring equipment;
           •          Safety and emergency equipment;
           •          Security devices; and
           •          Operating and structural equipment.

The inspection schedule is kept at the plant and is designed to ensure that there are no incidents
or releases that could potentially threaten or harm human health or the environment. Table F-1
shows the inspection schedule for hazardous waste management units at the Lafarge Tulsa plant.

Lafarge ensures that records of inspections are entered in the plant's inspection logs and
operating record.             Inspection logs for the type of equipment indicated above contain the
following information:

           •          Date and time of the inspection;
           •          Name of the inspector;
           •          Items to be inspected;
           •          Notation of the observations made; and
           •          Date and nature of any repairs made or remedial actions undertaken.

The inspection records are maintained at the facility for at least three years from the date of
inspection.

If inspections reveal that non-emergency maintenance is needed, it is completed as soon as
possible to preclude further damage and to reduce the need for emergency repairs. If a hazard is
imminent or has already occurred, remedial action is initiated immediately.




Rev. 2, April 2010                                Inspection Plan                           Page Att. F-2-2
Lafarge Building Materials, Inc.                  Tulsa, OK                          EPA ID #OKD064558703



In the event of an emergency involving the release of hazardous wastes to the environment,
efforts are directed toward containing the hazard, removing it, and subsequently decontaminating
the affected area.

The frequency of the various inspections depends on the anticipated rate of deterioration in each
system and the probability of an incident if the deterioration or operator error goes undetected
between inspections. For example, areas in which spills may occur are inspected daily, when in
use. Inspection frequencies may be altered in the future based on the plant's actual operating
experience with the kilns. Plant personnel remedy any problems found during an inspection,
documenting the date and resolution. Problems with equipment covered by the leak detection
and repair program are corrected as stipulated in the program.              Management review and
oversight is maintained to ensure problems are corrected.

Inspections are conducted by Lafarge employees, or may be conducted by Systech employees.

           1.1        Safety and Emergency Equipment

           Safety and emergency equipment at the Lafarge plant is inspected per the scheduled
           specified in Table F-1. Inspections of this equipment are also performed following an
           emergency event that requires its use. Timely execution of these inspections ensures the
           health and safety of employees and the protection of the environment should an
           emergency occur.

           1.2        Security Devices

           Security devices (i.e., closed-circuit TVs) at the Lafarge Tulsa plant are inspected daily to
           ensure they are functional.

           1.3        Operating and Structural Equipment

           The portions of the operating and structural equipment at the Lafarge plant that are
           inspected include all hazardous waste conveyance equipment. This equipment consists of
           pipes, flanges, and valves.




Rev. 2, April 2010                             Inspection Plan                             Page Att. F-2-3
Lafarge Building Materials, Inc.                 Tulsa, OK                         EPA ID #OKD064558703



           For aboveground segments of piping that supply hazardous waste fuel to the kilns, daily
           inspections are conducted unless the system has secondary containment (i.e., the piping
           used to contain hazardous waste has been replaced as double-walled piping). Fittings and
           valves are monitored according to 40 CFR Part 264, Subpart BB, the leak detection and
           repair program (LDAR), which is discussed in Section L-2.

           The inspection schedule for operating and structural equipment is included in Table F-1.




Rev. 2, April 2010                            Inspection Plan                            Page Att. F-2-4
Lafarge Building Materials, Inc.                              Tulsa, OK                           EPA ID #OKD064558703




                                             Table F-1 - Inspection Schedule

    Type of                           Item                                      Type                  Frequency
   Equipment

 Safety and            Protective clothing (coated full-      Adequate supply, no deterioration   Weekly/after use
 Emergency             body coveralls, gloves, and
 Equipment             boots)
                       Emergency shower and eyewash           Functional, leaks                   Weekly
                       First aid equipment and supplies       Adequate supply                     After use
                       Telephone system                       Proper function                     Weekly
                       Fire extinguishers                     Need for recharging, adequate       Monthly (per
                                                              supply                              MSHA)
                       Emergency alarm                        Proper function                     Weekly
                       Face shields                           Adequate supply                     Weekly
                       Half-face respirators                  Adequate supply                     Weekly
                       Organic vapor monitor                  Functional, calibrated              Available at
                                                                                                  Systech
                       Empty 55-gallon drums                  Adequate supply                     Available at
                                                                                                  Systech
                       Hand-held radios                       Functional                          Weekly
                       Warning signs                          Legibility                          Weekly
 Operating and         Pipes, braided hose                    Leaks                               Daily
 Structural
 Equipment                                                    Loss of thickness                   Annually

                       Valves                                 Leaks, deterioration                Daily
                       Fittings                               Leaks, deterioration                Daily
 Security              CCTV – Systech and Kiln                Functional                          Daily
 Devices




Rev. 2, April 2010                                         Inspection Plan                                Page Att. F-2-5
Attachment 3
Personnel Training
Lafarge Building Materials, Inc.         Tulsa, OK     U.S. EPA ID No. OKD064558703




                                       Section H

                                   TRAINING PLAN
                                       Revision 2

                                       April 2010




Rev. 2, April 2010                     Training Plan                       Page H-i
Lafarge Building Materials, Inc.                               Tulsa, OK                              U.S. EPA ID No. OKD064558703



                                                         Training Plan

                                                     Table of Contents

H.1    PURPOSE AND SCOPE.................................................................................................... 1
  H.1.1     Facility Operations Covered by this Plan ................................................................... 2
H.2    Job Title and Descriptions .................................................................................................. 3
H.3    Training Content, Frequency, and Techniques ................................................................... 4
  H.3.1     Initial Training Period................................................................................................. 4
  H.3.2     On-the- Job Training................................................................................................... 4
  H.3.3     Continuing Training - Annual Review ....................................................................... 4
H.4    Training Director ................................................................................................................ 6
H.5    Relevance of Training to Job Position ................................................................................ 7
H.6    Training for Emergency Response...................................................................................... 8
H.7    Implementation of Training Program ................................................................................. 9


                                            ATTACHMENTS
Att. H-1             Lafarge Training Program Outline
Att. H-2             Training Requirements




Rev. 2, April 2010                                           Training Plan                                                     Page H-ii
Lafarge Building Materials, Inc.                                    Tulsa, OK                               U.S. EPA ID No. OKD064558703



                                                               SECTION H

                                                    PERSONNEL TRAINING

H.1        PURPOSE AND SCOPE

In accordance with 40 CFR 264.16, 40 CFR 270.14(b)(14), and O.A.C. 252:205-3-2(f), Lafarge
has developed introductory and continuing training programs including classroom and on-the-job
instruction that teaches employees to perform their duties in a way that ensures the facility’s
compliance with all requirements. All employees undergo general RCRA training to identify,
evaluate, and control safety and health hazards and to provide emergency response procedures
for plant personnel to follow in emergency situations. Additionally, employees involved in the
sampling of CKD undergo specific on-the-job training as required. No other categories of
Lafarge employees are required to undergo any specific RCRA training as they either do not
handle Fuel Quality Waste (FQW) 1 or the training requirements related to their job have been
superceded by training required by the HWC MACT regulations.

This section outlines the initial and continuing training Lafarge employees receive.                                                         Both
classroom instruction and on-the-job training (OJT) are used to train personnel in hazard
recognition, job content and responsibilities, engineering safety controls, the use of personal
protective equipment, emergency response procedures, medical surveillance policy, recognition
of symptoms of illness, and sources of medical assistance. These training components provide
personnel with a level of training directly related to their level of responsibility and their specific
job functions.

An outline of the contents of the classroom training sessions is presented in Attachment H-1.




1
  The handling of hazardous waste is limited to Systech personnel, therefore Systech coordinates appropriate training for their staff, as outlined
in the Systech Part B application.



Rev. 2, April 2010                                               Training Plan                                                          Page H-1
Lafarge Building Materials, Inc.               Tulsa, OK                 U.S. EPA ID No. OKD064558703



         H.1.1 Facility Operations Covered by this Plan

         Lafarge is located in Rogers County, Oklahoma, northeast of the City of Tulsa. The plant
         consists of a quarry operation, crushing system, two raw mill, two cement kilns, two
         finish mill systems, and cement storage silos.

         The Lafarge Tulsa plant receives hazardous liquid waste-derived fuels from Systech
         Environmental Corporation (Systech), also known as fuel quality waste (FQW). The
         FQW is used directly in the plant’s cement manufacturing process.            All fuels are
         compatible with the process of cement manufacturing. The equipment used to contain
         and convey this hazardous material is regulated by the RCRA hazardous waste
         regulations.

         This permit application is for Lafarge to thermally treat FQW for energy recovery.
         Lafarge is not a permitted hazardous waste storage facility. The Lafarge facility is also a
         Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste. Training
         associated with the management of FQW prior to thermal treatment is regulated by 40
         CFR 264.16(b). This regulation requires initial and annual refresher training for persons
         who manage FQW streams. Relevant personnel in this plant would include certain
         inspectors, those who obtain samples, and those who are involved in the generation of
         hazardous waste. (Training is recommended but not required for CESQG generators who
         do not store hazardous waste.)




Rev. 0, June 2009                            Training Plan                                  Page H-2
Lafarge Building Materials, Inc.              Tulsa, OK                  U.S. EPA ID No. OKD064558703



H.2      JOB TITLE AND DESCRIPTIONS

The job title, job description, and name of each employee filling positions related to FQW
management are kept on file at the facility. Job descriptions include educational and other
necessary qualifications as well as the assigned duties for each position.




Rev. 0, June 2009                           Training Plan                                   Page H-3
Lafarge Building Materials, Inc.                Tulsa, OK                U.S. EPA ID No. OKD064558703



H.3      TRAINING CONTENT, FREQUENCY, AND TECHNIQUES

This section and Attachment H-2, Training Requirements, describe the training employees
receive.

         H.3.1 Initial Training Period

         All newly hired, transferred, or cross-training personnel receive instruction and OJT
         relating specifically to their assigned duties within six months of their assignment to the
         waste management positions.

         The initial training consists of 24 to 40 hours of instruction using a variety of methods
         and presentation materials to describe the waste-derived fuel program, discussions of
         material safety data, information on the characteristics and handling of waste materials,
         and safe work practices. OJT continues after the initial training is completed. Employees
         are not permitted to work unsupervised with FQW until they have completed sufficient
         training to ensure that they can safely perform assigned duties in compliance with the
         applicable hazardous waste management requirements.

         H.3.2 On-the- Job Training

         The mastery of specific skills or procedures is accomplished through supervised OJT
         activities. Supervisory personnel observe and evaluate the performance and competence
         of the trainees over the course of their training.

         H.3.3 Continuing Training - Annual Review

         After the first year and during a twelve-month period, facility personnel attend
         approximately eight hours of training. This program includes an abbreviated review of
         the introductory training outline (see Attachment H-1 or a subset of the topics), coupled
         with a detailed review of emergency response procedures contained in the Contingency
         Plan. It may also contain information relating to health and safety as required by the
         Mine Safety and Health Administration (MSHA). Emphasis is placed on discussions of
         how any changes in wastes, equipment, operations, procedures, or regulations affect the
         Contingency Plan and emergency response activities. Additionally, question and answer


Rev. 0, June 2009                             Training Plan                                 Page H-4
Lafarge Building Materials, Inc.               Tulsa, OK                 U.S. EPA ID No. OKD064558703



         opportunities allow for discussion of any operational concerns, difficulties, malfunctions,
         or incidents that have occurred in the past year.




Rev. 0, June 2009                            Training Plan                                  Page H-5
Lafarge Building Materials, Inc.             Tulsa, OK                  U.S. EPA ID No. OKD064558703



H.4      TRAINING DIRECTOR

The Lafarge Plant Manager or their designee coordinates training activities for facility personnel.
The Plant Manager and experienced personnel coordinating OJT activities are trained in
hazardous waste management procedures.




Rev. 0, June 2009                          Training Plan                                   Page H-6
Lafarge Building Materials, Inc.           Tulsa, OK                 U.S. EPA ID No. OKD064558703



H.5      RELEVANCE OF TRAINING TO JOB POSITION

The entire training program prepares personnel to manage the wastes received safely and
efficiently. In addition, OJT provides more intensive training and experience in daily waste
handling operations related to each employee's particular duties. Attachment H-2 identifies the
type of OJT each position requires and the RCRA training that employees attend.




Rev. 0, June 2009                        Training Plan                                  Page H-7
Lafarge Building Materials, Inc.                 Tulsa, OK                U.S. EPA ID No. OKD064558703



H.6      TRAINING FOR EMERGENCY RESPONSE

Facility personnel receive training in implementing the Contingency Plan, both during initial
training and during the annual review. They are familiar with emergency procedures, equipment,
and systems and will be able to respond promptly and safely should the need arise.

The training program includes the following safety-related items:

         •          Procedures for using, inspecting, and awareness of facility emergency and
                    monitoring equipment
         •          Key parameters for automatic waste feed cut-off systems.
         •          Communications and alarm systems
         •          Response to fires and explosions
         •          Shutdown of operations




Rev. 0, June 2009                              Training Plan                                 Page H-8
Lafarge Building Materials, Inc.                   Tulsa, OK                  U.S. EPA ID No. OKD064558703



H.7      IMPLEMENTATION OF TRAINING PROGRAM

Certain records relating to the training of FQW facility personnel are maintained at the facility.
These records indicate that facility personnel have successfully completed training within six
months of their employment or assignment to the facility or transfer to a new position which
includes involvement with FQW within the facility. Employees do not work in unsupervised
positions involving FQW until they have completed the training requirements.

The following items are maintained at the facility as part of the Operating Record.

         •          Job title for each position at the facility relating to FQW management, and the
                    name of the employee(s) filling each position.
         •          Written job descriptions for each position, including the requisite skill, education,
                    qualifications and duties of the employees assigned to each position.
         •          Written description of the training.
         •          Records that document the appropriate training or job experience described above
                    has been given to and completed by the facility personnel.

Training records on current personnel are kept for three years following closure of the facility.
Training records on former employees are kept for at least three years from the date the
employee last worked at the facility. Training documents for employees that are transferred to
another Lafarge facility are transferred with that employee




Rev. 0, June 2009                                Training Plan                                   Page H-9
Lafarge Building Materials, Inc.                Tulsa, OK             U.S. EPA ID No. OKD064558703



                                           Attachment H-1

                                   Lafarge Training Program Outline

1)       Hazard recognition,
         a) Hazard characteristics
            i) Ignitability
            ii) Corrosivity
            iii) Reactivity
            iv) Toxicity
         b) What Is Fuel Quality Waste (FQW)?
            i) Basic Characteristics of FQW
                 (1)      Vapors
                 (2)      Ignitability
            ii) Hazards Associated with FQW
                 (1)      Fire/Explosion
                 (2)      Health Effects
2)       Emergency response procedures,
         a) Types of potential emergencies
            i) Spill
            ii) Fire
            iii) Tornado
         b) Contingency Plan
            i) Response to incidents
            ii) Communications or alarm systems
            iii) Initial actions to fires or explosions
            iv) Initial actions to spills
            v) FQW operations shutdown
            vi) Notifications
            vii) Follow-up
         c) Emergency evacuation procedures
         d) Using, inspecting, and replacing facility emergency equipment
3)       Waste minimization/pollution prevention.
         a) Types of site-generated wastes
         b) Methods to reduce waste generation
4)       Sampling waste streams;
         a) Description of waste streams
            i) Cement kiln dust
            ii) Used refractory brick
         b) Sampling procedures
         c) Sample preparation and shipping;
5)       Hazardous waste management requirements for CESQ generators (laboratory).
         a) Manifesting
         b) Packaging, labeling, marking, placarding
         c) Accumulation time – satellite accumulation
         d) Recordkeeping and reporting



Rev. 2, April 2010                            Training Plan                        Page Att. H-1-1
Lafarge Building Materials, Inc.                   Tulsa, OK                   U.S. EPA ID No. OKD064558703



                                               Attachment H-2

                                     TRAINING REQUIREMENTS


                Position             Initial      Annual       Sampling   Inspections      Annual
                                   Classroom     refresher       OJT         OJT         emergency
                                                                                          response
                                                                                            drill
        Shift                         X             X             X           X              X
        Supervisor/Leadman
        Control Room Operator         X             X
        Laboratory technician         X             X             X           X
        Regulatory Manager            X             X             X           X              X
        Site Manager                  X             X                         X              X




Rev. 0, June 2009                                Training Plan                              Page Att. H-2-1
Attachment 4
Hazardous Waste
Contingency Plan
Lafarge Building Materials, Inc.           Tulsa, OK       U.S. EPA ID No. OKD064558703




                                   CONTINGENCY PLAN
                                          Revision 2

                                         April 2010




Rev. 2, April 2010                      Contingency Plan                       Page G-i
Lafarge Building Materials, Inc.                                  Tulsa, OK                              U.S. EPA ID No. OKD064558703



                                                       Contingency Plan

                                                       Table of Contents

G.1    RESPONSE LEVEL........................................................................................................... 4
G.2    INITIAL ACTIONS............................................................................................................ 5
  G.2.1    Spill ............................................................................................................................. 5
  G.2.2    Fire .............................................................................................................................. 5
  G.2.3    Tornado ....................................................................................................................... 5
  G.2.4    Medical Emergency .................................................................................................... 6
G.3    NOTIFICATION ................................................................................................................ 7
  G.3.1    Internal ........................................................................................................................ 7
  G.3.2    External ....................................................................................................................... 7
    G.3.2.1 Notification of National Response Center (NRC) .................................................. 8
    G.3.2.2 Written Notification to ODEQ Director ................................................................. 8
    G.3.2.3 Notification of the Local Emergency Planning Committee.................................... 9
  G.3.3    Identification ............................................................................................................... 9
  G.3.4    Assessment................................................................................................................ 10
G.4    FOLLOW-UP ................................................................................................................... 12
  G.4.1    Control and Containment.......................................................................................... 12
  G.4.2    Remediation .............................................................................................................. 12
  G.4.3    Termination and Follow-Up Actions ........................................................................ 13


                                                               FIGURES
Fig. G-1              Response Process
Fig. G-2              Typical Spill Response

                                                  TABLES
Table G-1             Emergency Coordinator (EC) Notification List
Table G-2             Spill Quantity and Appropriate Response
Table G-3             Emergency Contacts

                                           ATTACHMENTS
Att. G-1              Emergency Response Operations
Att. G-2              Emergency Response Resources
Att. G-3              Plot Plan
Att. G-4              Example of Agreement for Emergency Assistance




Rev. 2, April 2010                                           Contingency Plan                                                       Page G-ii
Lafarge Building Materials, Inc.              Tulsa, OK                   U.S. EPA ID No. OKD064558703



                                           SECTION G

                                     CONTINGENCY PLAN

As required by 40 CFR 264.51, 270.14(b)(7), and O.A.C. 252-205-3-2(f), Lafarge has developed
a Contingency Plan designed to minimize hazards to human health and the environment from
fires, explosions, and any unplanned sudden or non-sudden release of hazardous waste or
hazardous waste constituents to air, soil, or surface water. The Contingency Plan meets the
requirements of 40 CFR 264 Subpart D and serves as a mechanism to ensure that the response
management teams at Lafarge are adequately prepared to address a worst-case situation. As
such, the Lafarge Contingency Plan details procedures for mobilizing personnel and mitigation
assets. The resulting response is designed to minimize life threatening situations and damage to
natural resources.

This Contingency Plan will be implemented in conjunction with the co-located Systech fuel
blending facility, which is located within the Lafarge plant property.           As such, activities
identified in the Plan may be implemented by either Lafarge or Systech personnel.

This chapter outlines the initial response actions necessary to protect the safety of Lafarge
personnel, the environment, and plant facilities during a hazardous waste discharge or other
situation. The objective of the Contingency Plan is to provide field operators and responders
with procedures for initial response to hazardous waste spills and other emergencies, to make
initial notification of key personnel, and to activate the facility’s Contingency Plan.

This Contingency Plan is divided into sections that correspond to each stage of the initial
response process for emergencies. Each section identifies the key personnel responsible for
executing specific tasks. Figure G-1 summarizes the response process and serves as a map for
this Contingency Plan.

The Lafarge facility receives fuel quality waste (FQW) from the on-site Systech facility to be
used as a supplementary fuel in the cement manufacturing process. Lafarge does not operate any
storage units. The hazardous waste management system consists of piping from the Systech
facility to the kilns.




Rev. 2, April 2010                         Contingency Plan                                  Page G-1
Lafarge Building Materials, Inc.                  Tulsa, OK                       U.S. EPA ID No. OKD064558703



The facility was designed and is operated to prevent spills, fires, or explosions. Personnel are
thoroughly trained to act immediately should it ever become necessary to implement the
Contingency Plan. The Contingency Plan is designed to minimize hazards to human health and
the environment from fires, explosions, or release of hazardous wastes or hazardous waste
constituents to the air, soil, or surface water. This Plan would be implemented if any of these
occurs.

Attachment G-3 is a Plot Plan of the Lafarge and Systech facility.

                                        Figure G-1: Response Process




                        Discovery                              Initial Actions (G.2)




                  Coordinator Actions                          Activate Internal Facility Alarm (G.3.1)
                                                               Activate Contingency Plan (G.3.1)




                                                              Notification (G.3.2)
            Response Management Systems                       Identification (G.3.3)
                                                              Assessment (G.3.4)
                                                              Control & Containment (G.4.1)
                                                              Remediation (G.4.2)


                    Communications                            Coordinator Write-up (G.4.3)
                                                              Required Reports




Rev. 2, April 2010                             Contingency Plan                                           Page G-2
Lafarge Building Materials, Inc.               Tulsa, OK                U.S. EPA ID No. OKD064558703



                     Table G-1       Emergency Coordinator (EC) Notification List
     On-Site                                      Shift Supervisor/Leadman
                       Position/Title,
     EC                                           918-437-3902 or ext. 250
                       Work Phone
                                                  918-388-1150 (direct dial)
                                                  One Shift Foreman will be on-site at all
                       Address                    times. The Shift Foremen who are not on-
                                                  site have no EC responsibilities.
                       24 Hour Emergency Phone 918-388-1150
     Primary           Name                       Steve Jeffrey
     EC                Position/Title             Production Manager
                                                  25956 South Brandon Terrace
                       Address
                                                  Claremore, OK 74019
                       Cell Phone                 918-688-3276
     Alternate         Name                       Hans Schrama
     EC                Position/Title             Operations Manager
                                                  13901 E 90th St N
                       Address
                                                  Owasso, OK 74055-4399
                       Cell Number                918-704-6354




Rev. 2, April 2010                          Contingency Plan                               Page G-3
Lafarge Building Materials, Inc.                   Tulsa, OK                   U.S. EPA ID No. OKD064558703



G.1      RESPONSE LEVEL

The appropriate level of response for a particular incident largely depends on both the
professional judgment of the primary or alternate EC and the regulatory reporting requirements.
The factors that affect the level of response necessary for a specific incident include:

    •         Type of waste handling system and the necessity of suspending operations or
              diverting waste fuels during an emergency;
    •         Potential for fires, explosions, or releases to spread to other areas of the plant;
    •         Immediate health and safety effect of the incident on plant personnel; and
    •         Potential hazards to the outside environment and public health.

More detailed information on specific components and functions of the response management
system is provided in Attachment G-1.

                                   Figure G-2      Typical Spill Response


                                          Activate Contingency
                                                   Plan




                                            Notify Appropriate         Assess Spill Size and
        Contain/Stop Flow
                                         Personnel and Agencies              Threat


                    Land Impact
                                                                        Estimate Equipment
                                                                       and Personnel Needs
                                                       Water Impact


         Containment and
                                         Containment Strategies        Is Assistance Needed?
            Recovery




                                         Cleanup and Disposal




                                         Evaluation and Review




Rev. 2, April 2010                              Contingency Plan                                    Page G-4
Lafarge Building Materials, Inc.                     Tulsa, OK                    U.S. EPA ID No. OKD064558703



G.2      INITIAL ACTIONS

         G.2.1 Spill

         Upon discovery of a discharge, or imminent discharge, of hazardous waste, the
         discoverer shall immediately follow the steps outlined below.

                   1.        DO NOT enter a hazardous area without proper personal protective
                             equipment: respirator, gloves, rubber boots, goggles.           Follow Lafarge
                             confined space procedures.
                   2.        Stop flow by closing valves or shutting off pumps.
                   3.        If spill is FQW, stop all transfer activity to the kiln area.
                   4.        Shut off all ignition sources in the area, including, but not limited to,
                             electrical equipment, automobiles, cigarettes, and welding equipment.
                   5.        Contact the EC that is on-site.

         G.2.2 Fire

         Upon discovery of a fire, the discoverer shall immediately follow the steps outlined
         below.

                   1.        Contact the EC that is on site (in the order listed on Table G-1). If the
                             Primary EC is not on site, contact the Alternate EC.
                   2.        Activate local emergency response.
                   3.        DO NOT enter any area that would jeopardize your safety.
                   4.        Contain fire with hand-held extinguisher if the fire is manageable and does
                             not present a threat to safety.

         G.2.3 Tornado

         Upon the issuance of a tornado warning for the plant location, the discoverer shall
         immediately follow the steps outlined below.

                   1.        Contact your immediate supervisor promptly so that he/she may contact
                             all other employees using established communications systems.


Rev. 2, April 2010                               Contingency Plan                                    Page G-5
Lafarge Building Materials, Inc.                      Tulsa, OK                 U.S. EPA ID No. OKD064558703



                   2.        The Control Room Operator will activate the emergency siren.
                   3.        Go directly to a shelter which is the nearest identified tornado shelter and
                             away from windows or open areas. If at all possible, do not shelter alone.
                   4.        Upon notification that the danger has passed, proceed to the primary rally
                             point for a headcount.

         G.2.4 Medical Emergency

         Upon discovery of a medical emergency, the discoverer shall immediately follow the
         steps outlined below.

                   1.        Assess the situation. If the accident scene is safe to enter, provide first aid
                             to the best of your ability to the victim. If the accident scene is not safe,
                             proceed to step 2.
                   2.        Contact the designated first responder. Inform him of the nature of the
                             emergency and location and state of the victim.
                   3.        Contact the on-site EC. If the on-site EC is not available, contact the
                             Primary or Alternate EC. Inform them of the nature of the emergency,
                             and if emergency services are required.
                   4.        If the accident scene is safe, stay with the victim.          Make them as
                             comfortable as possible until help arrives.




Rev. 2, April 2010                                Contingency Plan                                 Page G-6
Lafarge Building Materials, Inc.                     Tulsa, OK                  U.S. EPA ID No. OKD064558703



G.3      NOTIFICATION

         G.3.1 Internal

         At the time a fire or release, which is not readily containable, or if a tornado warning is
         issued, the internal facility alarm is activated as instructed by an onsite, primary or
         alternate EC. The responding EC will implement the Contingency Plan and notify
         appropriate emergency response agencies, as needed. A list of emergency contacts is
         listed in Table G-3.

         The Emergency Coordinator is responsible for implementing the Contingency Plan. The
         Emergency Coordinator or designated alternates are available to facility personnel at all
         times. They will be on the facility premises or on call and therefore available to respond
         to an emergency by reaching the facility within a short period of time. The Emergency
         Coordinator, who is responsible for coordinating all emergency response measures, is
         familiar with:

                   •         All aspects of the facility's Contingency Plan.
                   •         All operations and activities at the facility.
                   •         The location and characteristics of waste handled.
                   •         The location of all records within the facility.
                   •         The facility layout.

         The emphasis on immediate response to emergency conditions requires that the
         Emergency Coordinator be free to use his or her judgment in an emergency situation.
         Therefore, the Primary Emergency Coordinator and alternates have the authority to
         commit the resources needed to carry out the Contingency Plan.

         G.3.2 External

         All reportable spills >1 gallon are recorded in the Operating Record. Copies of these
         records are maintained by the Environmental Manager. The Emergency Coordinator or
         alternate is responsible for determining if a spill must be reported to federal, state, or
         local agencies.           Any spill reaching the surface waters outside Lafarge property is


Rev. 2, April 2010                               Contingency Plan                                  Page G-7
Lafarge Building Materials, Inc.                   Tulsa, OK                  U.S. EPA ID No. OKD064558703



         reportable. The EC or alternate is also responsible for notifying the appropriate agencies
         if needed. Information to be included in the notification is addressed in Section G.3.3.

                   G.3.2.1         Notification of National Response Center (NRC)

                   Spills of hazardous substances, which exceed the Reportable Quantity (RQ) for
                   that substance, must be immediately reported to the NRC. Any quantity of oil or
                   fuel that reaches surface waters must be reported to the NRC. The information to
                   be provided to the NRC by telephone is included in Section G.3.3.

                   G.3.2.2         Written Notification to ODEQ Director

                             The Environmental Manager is responsible for preparing spill reports for
                             the regulatory agencies. All releases reported to the NRC will also be
                             reported to the Oklahoma Department of Environmental Quality (ODEQ)
                             by telephone. In addition, any spill of oil or fuel that exceeds 25 gallons
                             should also be immediately reported to ODEQ.

                         Table G-2        Spill Quantity and Appropriate Response
                Size                            Response                           Notify
                          Cleanup and Report (if not
 > 1 pound to environment
                          immediately contained and ODEQ
 (offsite)
                          cleaned up)
 <1 gal onsite            Cleanup                    Not required
 >1 gal and <25 gal. on
                                      Cleanup                         Environmental Manager
 site
 >25 gal                              Cleanup                         ODEQ
 Anything to surface water            Contain and Cleanup             NRC, ODEQ
 >1000 gal to surface
                                      Contain                         NRC, ODEQ,
 water
 >RQ on-site                          Cleanup                         NRC, ODEQ
 >RQ leaving site                     Cleanup                         NRC, ODEQ, LEPC




Rev. 2, April 2010                              Contingency Plan                                 Page G-8
Lafarge Building Materials, Inc.                     Tulsa, OK                   U.S. EPA ID No. OKD064558703



                                      Table G-3       Emergency Contacts
                                                 Address
                                               (if written                      Type of       Reporting
      Branch                   Agency                                Phone #
                                              notification is                   Report        Deadline
                                                required)
 FIRE                    Catoosa Fire                            911           Telephone As Needed
                         Department
 HAZMAT                  Tulsa Fire                              911           Telephone As needed
                         Department
 POLICE                  Catoosa Police                          911           Telephone As Needed
                         Department
 HOSPITAL                Southcrest          8801 S. 101st       918-294-      Telephone As Needed
                         Hospital            East Ave.           4000
                                             Tulsa, OK
                                             74133
 AMBULANCE Pafford                                               911           Telephone As Needed
           Ambulance
 LEPC      Rogers County                     219 S.              918-341-      Telephone Immediately
           Emergency                         Missouri, Rm.       2060
           Management                        B113,
           Agency                            Claremore,
                                             OK 74017
                         Tulsa Area          411 S.              918-596-      Telephone Immediately
                         Emergency           Frankfort           7361
                         Management          Ave., Tulsa
                         Agency              OK, 74103
 STATE/                  Oklahoma Dept.      707 N               800-522-      Telephone Immediately
 FEDERAL                 of Env. Quality     Robinson            0206
                         (ODEQ)              Oklahoma
                                                                               Written      15 days
                                             City, OK
                                             73102
                         National                                800-424-      Telephone Immediately
                         Response Center                         8802

                   G.3.2.3         Notification of the Local Emergency Planning Committee

                   The Local Emergency Planning Committee (LEPC) contact for the area is the
                   Rogers County and Tulsa County Emergency Management Agency. The LEPC
                   will be notified when any other agency is notified of a spill that leaves the site.

         G.3.3 Identification

         The responding EC will identify the following characteristics of any released material:


Rev. 2, April 2010                                Contingency Plan                                    Page G-9
Lafarge Building Materials, Inc.                    Tulsa, OK                  U.S. EPA ID No. OKD064558703



                   •         Identification;
                   •         Exact Source;
                   •         Amount; and
                   •         Impacted area.

         This may be accomplished by visual observation of materials, review of facility records
         or manifests, or, if necessary, by chemical analysis.

         G.3.4 Assessment

         During an emergency, the responding EC will assess the following possible hazards to
         human health or the environment:

                   •         Direct and indirect effects of any materials released;
                   •         Effects of gases generated;
                   •         Effects of hazardous surface runoff from fire control materials;
                   •         Effects of chemicals used to control the emergency; and
                   •         Potential for surface water contamination.
                   •         Will this emergency threaten human health or the environment outside the
                             facility?

         If the responding EC determines that a significant quantity of hazardous waste has been
         released, or that an emergency will threaten human health or the environment, the
         responding EC, or his designee, will immediately activate the plant evacuation alarm and
         notify local authorities by calling the emergency 911 number.

         By calling 911, the Fire Department and the Police Department will be aware of the
         situation. If necessary, the responding EC, or the police or fire department, will notify
         the Hospital and Ambulance Service.

         If a reportable quantity of waste has been released, the primary EC will also notify the
         National Response Center as well as other appropriate agencies and authorities.

         The EC will include the following information in the notification:



Rev. 2, April 2010                              Contingency Plan                                 Page G-10
Lafarge Building Materials, Inc.                      Tulsa, OK                 U.S. EPA ID No. OKD064558703



                   •         Name, address, and telephone number of the plant owner or operator;
                   •         Name, address, and telephone number of the plant;
                   •         Date, time, and type of incident (e.g., fire, explosion);
                   •         Name and quantity of material(s) involved;
                   •         Location of the spill;
                   •         Surface on which the oil spilled;
                   •         Amount of time before the spill will flow into a storm sewer inlet or other
                             drainage pathway;
                   •         Cause of the spill;
                   •         Extent of damages and injuries, if any;
                   •         Assessment of actual or potential hazards to human health or the
                             environment, if applicable;
                   •         Actions taken to mitigate the spill;
                   •         If an evacuation will be required, and;
                   •         Estimated quantity and disposition of any recovered materials.




Rev. 2, April 2010                                 Contingency Plan                               Page G-11
Lafarge Building Materials, Inc.                   Tulsa, OK                  U.S. EPA ID No. OKD064558703



G.4      FOLLOW-UP

         G.4.1 Control and Containment

         During an emergency, the responding EC must take all reasonable measures necessary to
         ensure that fires, explosions, and releases do not occur, recur, or spread to other areas at
         the plant. These measures may include, where applicable, shutting off the flow of
         liquids, shutting down the flow of fuel into the kilns, and shutdown of the kilns. The EC
         will also monitor for leaks, pressure buildup, or other potential problems when the fuel
         flows and kilns are shut down.

         G.4.2 Remediation

         The following specific procedures will be initiated following an emergency:

                   •         Immediately after an emergency, the Primary EC will make arrangements
                             for treatment, storage, or disposal of recovered wastes, contaminated soil,
                             contaminated groundwater, contaminated surface water, or any other
                             contaminated materials.    Materials that result from a release, fire, or
                             explosion at the kiln area will be analyzed and if the materials meet fuel
                             requirements will be reintroduced into the kiln system.           Materials
                             determined to be hazardous waste, and not meeting fuel requirements, will
                             be sent to an appropriate off-site treatment or disposal facility. If the
                             system is damaged, the waste will be containerized and either stored at
                             Systech until repairs are made or sent to an appropriate off-site treatment
                             or disposal facility. The Emergency Coordinator will ensure that no waste
                             that may be incompatible with the released material is treated, stored or
                             disposed of until clean-up procedures are completed.

                   •         The Primary EC will ensure that cleanup procedures are completed and
                             that emergency equipment is clean and fit for use before resuming
                             operations in an affected area. Contaminated equipment will be rinsed
                             with clean solvent or pressure water where necessary.        Any resulting
                             contaminated solvent will be retained in a catch bucket or container and


Rev. 2, April 2010                             Contingency Plan                                 Page G-12
Lafarge Building Materials, Inc.                     Tulsa, OK                    U.S. EPA ID No. OKD064558703



                             transferred into the fuel storage tanks. Small quantities of water used to
                             clean contaminated equipment will be managed similarly.

                   •         The Primary EC will investigate the cause of the emergency and will take
                             steps to prevent the recurrence of such incidents.

         G.4.3 Termination and Follow-Up Actions

         If a release to the environment occurs in an amount greater than 1 pound the Primary EC
         will notify the ODEQ, in compliance with 40 CFR 264.196(d), within 24 hours of
         detection. The Primary EC will also ensure that any waste that may be incompatible with
         the released materials is not treated, stored, or disposed of until cleanup procedures are
         completed; and that all emergency equipment listed in the Contingency Plan is
         decontaminated and fit for its intended use before operations can resume in affected areas
         of the plant.

         The EC will note in the plant’s operating record the time, date, and details of any incident
         that requires the implementation of the Contingency Plan.                 Within 15 days of the
         incident, the Primary EC will submit a report to ODEQ, and the LEPC. The report will
         contain the following information:

                   •         Name, address, and telephone number of the plant owner or operator;
                   •         Name, address, and telephone number of the plant;
                   •         Date, time, and type of incident (e.g., fire, explosion);
                   •         Name and quantity of material involved;
                   •         Extent of injuries, if any;
                   •         Assessment of actual or potential hazards to human health or the
                             environment, if applicable; and
                   •         Estimated quantity and disposition of any recovered materials.

         The Contingency Plan will be reviewed and amended, if necessary, whenever:

                   •         The facility permit is revised.
                   •         The plan fails in an emergency.


Rev. 2, April 2010                               Contingency Plan                                   Page G-13
Lafarge Building Materials, Inc.                   Tulsa, OK                  U.S. EPA ID No. OKD064558703



                   •         Changes occur in the facility's design, construction, operation,
                             maintenance, or other circumstances which materially increase the
                             potential for fires, explosions, or releases of hazardous waste or hazardous
                             waste constituents, or changes occur in the response necessary in any
                             emergency.
                   •         The list of Emergency Coordinators changes.
                   •         The list of emergency equipment changes significantly.




Rev. 2, April 2010                              Contingency Plan                                Page G-14
Lafarge Building Materials, Inc.                        Tulsa, OK                        U.S. EPA ID No. OKD064558703



                  Attachment G-1             EMERGENCY RESPONSE OPERATIONS

Spill Response

                                                    INITIAL RESPONSE
            DO NOT enter a hazardous area without proper personal protective equipment:
            respirator, gloves, rubber boots, goggles, and monitoring equipment as appropriate.
            Stop waste flow by closing valves or shutting off pumps.
            Stop all transfer activity to the kiln area.
            Shut off all ignition sources in the area including, but not limited to:
            electrical equipment, automobiles, cigarettes, and welding equipment.
            Contact the EC that is on site, who will contact the primary or secondary EC. If an RQ is exceeded or
            the spill threatens to spread outside the plant, immediately notify the NRC.


                                            DUTIES OF RESPONDING EC
            Attempt to determine the source of spill without risking personal safety.
            Identify the material spilled and determine the hazards involved in terms of the potential for fire,
            hazardous gas release, corrosion, explosion, or water pollution. If it is a reportable spill, notify
            appropriate agencies.
            Evacuate all endangered or unnecessary personnel. In case of the release of toxic or flammable gases,
            determine if off-site evacuation is advisable. Remove nearby wastes that may be incompatible with the
            spilled material.
            Investigate the spill and check analytical records and inventory data. Evaluate the hazard potential and
            assign trained personnel to clean up the spill.


                                           SPILL RESPONSE PROCEDURES
            Contain the spill as much as possible while attempting to stop the spill.
            If flammable material, rope off the spill area a minimum of 50 feet away from spill.
            To contain the spill:
            With absorbent booms or CKD:
                  1) Use booms in tandem (one placed a few inches behind the other) or CKD dikes to help control
                      the flow of material.
                  2) Oil sorbent booms should be used on any water that could possibly be contaminated; they will
                      serve as backups for materials that might get by the tandem sorbent booms
            With absorbent:
                  1) Pour absorbent from bags or barrels to form a dike.
                  2) Barrels can be turned on their sides and rolled to create a dike.
                  3) Use front-end loader buckets of absorbent or CKD for major spills.
            After the spill is contained, recover as much FQW liquid as possible and return to the FQW tanks; treat
            the remaining spill with neutralizing agents to decrease the risk of fire, corrosion, explosion, or other
            hazards. Apply non-reactive sorbent materials.
            If contamination of the area occurs, depending on instructions from the regulatory agencies, excavate
            the area and isolate removed materials from rainfall and runoff in a container or containment area.
            After the material has been characterized, develop a disposal plan. A plan may include, but not be
            limited to: blending with other materials and using as a fuel in the hot end of the kiln, or off-site
            disposal.
            Use on-site monitoring to determine safety of the area.
            Make any temporary repairs.
            Complete a written description of the event.
            The Primary EC will report the spill, if necessary.




Rev. 0, June 2009                                  Contingency Plan                                      Page Att. G-1-1
Lafarge Building Materials, Inc.                        Tulsa, OK                        U.S. EPA ID No. OKD064558703



Fire or Explosion Response

                                                 INITIAL RESPONSE
            Contact the EC that is on site, who will contact the primary or secondary EC.
            EC will notify Fire Department and send an employee to the front gate for escort.
            DO NOT enter any area that would jeopardize your safety.
            Contain fire with hand-held extinguisher if the fire is manageable and does not present a threat to
            safety.


                                            DUTIES OF RESPONDING EC
            Determine what material is on fire by location, kiln, inventory, or log.
            Determine if the staff is endangered by the fire or if the fire could spread to other wastes or kilns.
            Define the limits of the fire, estimate the potential dangers with respect to other materials in the
            immediate vicinity, and call the local Fire Department if needed.
            Evacuate all endangered personnel to the designated rally points. In case of a release of toxic gases
            or a potential for explosion, determine if off-site evacuation is necessary.
            Determine the best and safest approach to handling the fire, taking into consideration not only the
            type of fire, but also the direction of the flame, spread, wind direction, potential dangers and any
            physical limitations.


                                        FIRE RESPONSE PROCEDURES
            The EC will help Fire Department personnel decide if the fire should be left to burn or should be
            extinguished.
            Use only as much water as necessary, to minimize the amount of water that may become
            contaminated.
            Allow only emergency vehicles into the plant during the emergency.
            Contain any spilled material or contaminated water by using absorbent or absorbent booms
            Collect all contaminated absorbent for disposal
            Make any temporary repairs.
            Complete a written description of events.
            Begin equipment and area decontamination and replacement
            The Primary EC will report the fire, if necessary.


                      FIRE RECURRENCE AND SPREAD PREVENTION PROCEDURES
            To reduce the possibility of sparking or heat generation that may result in a fire or explosion, shut
            down all mechanical equipment. Turn off all equipment not required for emergency response and
            close all pipelines feeding the kilns, if it can be done without hazard to personnel.
            After system shutdown is accomplished, monitor gauges and indicators for evidence of system
            changes. If changes develop, take steps to immediately identify and remedy the condition.
            Periodically inspect the affected areas for leaks, including, but not limited to, drops, sprays, pooling
            of liquids, or wet areas. Examine piping for evidence of failure, including cracks, ruptures, or
            abnormal distortion.
            The Primary EC will ensure that no material that may be incompatible with the released material is
            treated, stored, or disposed until cleanup procedures are complete.




Rev. 0, June 2009                                  Contingency Plan                                      Page Att. G-1-2
Lafarge Building Materials, Inc.                       Tulsa, OK                        U.S. EPA ID No. OKD064558703



Emergency Evacuation Procedures

                                         DUTIES OF RESPONDING EC
            The responding EC is responsible for implementing the evacuation and will notify personnel if an
            evacuation is necessary.
            Employees and visitors will be directed to the proper exit and to the assigned safe areas.


                                           EVACUATION PROCEDURES
            The EC will assess the conditions and order an evacuation or any other action that is required.
            The EC will notify personnel if an evacuation is necessary by sounding the emergency alarm (a
            continuous blast on a siren or by providing instructions to evacuate using the radio/telephone
            system).
            When an evacuation is announced, work will be stopped. Personnel should go to the nearest exit.
            All employees should leave the plant and report to the designated rally points. Employees should
            not run or linger in entranceways or driveways and should congregate in the designated rally points.
            The plant Administrative Assistant will bring the guest log and Shift Supervisor/Leadman will bring
            the contractor sign-in sheet to the rally point and account for all plant guests.
            All employees will be accounted for by their immediate supervisors.
            The Primary EC will notify personnel when it is safe to re-enter the facility. Re-entry will not be
            permitted until the Primary EC declares that it is safe to do so and issues an all-clear signal.


                                                   RALLY POINTS
            Employee Parking Lot - Primary
            Scale House – Alternate
            Quarry Y-Intersection - Rally point for personnel working in the quarry or crusher so they do not have
            to travel through the plant.


                                   EMERGENCY EVACUATION PRECAUTIONS
            Keep calm, think and avoid panic and confusion. WALK to the nearest exit.
            Know all exit locations; be sure that you know the quickest way out of the building.
            Do not lock office doors when evacuating the building.
            Do not delay evacuation for any reason.
            Do not assist in fire control unless you are properly trained and qualified.
            Stay clear of the plant and DO NOT interfere with emergency operations.




Rev. 0, June 2009                                  Contingency Plan                                    Page Att. G-1-3
Lafarge Building Materials, Inc.                       Tulsa, OK                        U.S. EPA ID No. OKD064558703



Tornado Procedures

                                         DUTIES OF RESPONDING EC
            The responding EC is responsible for sounding the tornado alarm and will notify personnel if shelter
            is necessary.
            Employees and visitors will be directed to the proper shelter and to the assigned safe areas.


                                             SHELTER PROCEDURES
            The EC will assess the conditions and order personnel to seek shelter or any other action that is
            required.
            The EC will notify personnel if shelter is necessary by sounding the emergency alarm (a continuous
            blast on a siren or by providing instructions to seek shelter using the radio/telephone system).
            When an alarm is sounded, work will be stopped. Personnel should go to the nearest shelter.
            All employees should report to a designated tornado shelter. Employees should not run or linger in
            entranceways or driveways and should congregate in the designated shelters. Do not shelter alone if
            possible.
            The Primary EC will notify personnel when it is safe to leave shelter and proceed to the rally point.
            Departure from shelter will not be permitted until the Primary EC declares that it is safe to do so.
            Once the Primary EC announces an “all-clear” over the radio/telephone system, personnel should
            proceed to the designated rally point.
            The Administrative Assistant will bring the guest log and Shift Supervisor/Leadman will bring the
            contractor sign-in sheet and account for all plant guests.
            All employees will be accounted for by their immediate supervisors.


                                                   RALLY POINTS
            Employee Parking Lot - Primary
            Scale House – Alternate
            Quarry Y-Intersection - Rally point for personnel working in the quarry or crusher so they do not have
            to travel through the plant.


                                                SHELTER PRECAUTIONS
            Keep calm, think and avoid panic and confusion. WALK to the nearest shelter.
            Know all shelter locations; be sure that you know the quickest way to shelter.
            Do not lock office doors when seeking shelter.
            Do not delay taking shelter for any reason.
            Go below ground if possible.
            Stay away from any opening.
            After the all-clear is given, stay clear of the plant and DO NOT interfere with emergency operations.


                                         SEVERE WEATHER SHELTERS
            Main Office – North hallway by breakroom
            Console – console basement
            Cooler Building – Tunnel to console
            Quarry – Basement of gyratory
            Blending – Interstice at manlift elevator
            Garage – Parts room
            Packhouse – Silo interstices
            Mill Building – Basement of load center
            Coal – Drag and hopper tunnel



Rev. 0, June 2009                                  Contingency Plan                                     Page Att. G-1-4
Lafarge Building Materials, Inc.                     Tulsa, OK                       U.S. EPA ID No. OKD064558703



Procedures for Recovery of Personnel

                                           DUTIES OF RESPONDING EC
            The responding EC is responsible for polling supervisors and determining which, if any, personnel
            are not accounted for.
            If EMS is requested, EC will send an employee to the front gate for escort.
            EC will ensure plant is safe for personnel to conduct search and rescue operations.
            EC will arrange needed personnel in groups of four to conduct search and rescue.


                                    SEARCH AND RESCUE PROCEDURES
            Groups of four will comb assigned areas for personnel.
            Found employees should be reported over the radio.
            Search groups should not move injured employees except in case of immediate danger.
            Search groups will stay with injured employees until emergency personnel have arrived on-scene.




Rev. 0, June 2009                                Contingency Plan                                   Page Att. G-1-5
Lafarge Building Materials, Inc.           Tulsa, OK                 U.S. EPA ID No. OKD064558703



                  Attachment G-2   EMERGENCY RESPONSE RESOURCES

       Emergency Equipment                       Location           Outline of Capabilities
                                Internal Communication Systems
 Portable radios                         Facility-wide office,   Internal communication
                                         personnel, kiln area
 FQW emergency shutdown switch           Kiln control room       Shut off primary feed pumps
                                                                 to kiln
 Telephone (intercom)                    Lab, office, facility-  Internal communication,
                                         wide                    plant-wide public address,
                                                                 emergency alarm
 Emergency alarm                         Plant-wide, kiln area   Plant-wide, audible fire
                                                                 alarm
                               External Communications Systems
 Telephones                              Office, lab, kiln area, Call outside for emergency
                                         EC                      assistance
                                    Fire Extinguishing System
 Extinguishers: 20-lb ABC                Plant-wide              For use on Type A, B, or C
                                                                 fires
                                     Spill Control Equipment
 Absorbent                               Kiln area               Contain, absorb, and clean
                                                                 up spills from off-loading
                                                                 pads, container building
 Solvent Absorbent Booms                 Truck Offloading Area   Absorb spills
 Organic vapor monitor                   Systech                 Exposure monitoring
 Empty containers                        Systech                 Receptacle for leaking or
                                                                 damaged containers and for
                                                                 spilled materials
                                   Other Emergency Equipment
 First aid supplies: bandages, gauze Lab, control room, lunch Immediate first aid for minor
 bandages, tape, butterfly bandages, room, main office           injuries
 antibacterial ointments, splints,
 aspirin, eyewash, local/topical
 anesthetics
 Emergency eyewash, fountain and         Lab, kiln floor area    Immediate treatment for
 drench showerhead                                               personnel in case of contact
                                                                 with hazardous waste
 Protective clothing and equipment: Locker room, lab, kiln       Protect personnel from
 hard hats, protective eyewear,          area                    possible hazards
 rubber and neoprene boots,
 impervious gloves, face shields,
 protective eyeglasses, half-face
 dust/chemical cartridge respirators,
 chemical cartridges
 Clean solvent                           Available from Systech Rinse contaminated
                                         for Systech use         equipment

Rev. 0, June 2009                       Contingency Plan                          Page Att. G-2-1
Lafarge Building Materials, Inc.      Tulsa, OK       U.S. EPA ID No. OKD064558703




                                   Attachment G-3

                                    PLOT PLAN




Rev. 0, June 2009                  Contingency Plan                Page Att. G-3-1
Lafarge Building Materials, Inc.          Tulsa, OK       U.S. EPA ID No. OKD064558703




                                      Attachment G-4

                                       EXAMPLE OF
                           AGREEMENT FOR EMERGENCY ASSISTANCE




Rev. 2, April 2010                     Contingency Plan                Page Att. G-4-1
Lafarge Building Materials, Inc.               Tulsa, OK                 U.S. EPA ID No. OKD064558703



                           AGREEMENT FOR EMERGENCY ASSISTANCE
                          BY AND BETWEEN LAFARGE TULSA FACILITY
                                    AND _______________

This agreement has been prepared to make arrangements for emergency services to be provided
by the ___________________ in the event of emergencies that may result from fires, explosions,
or a major release at:

         Lafarge Building Materials, Inc.
         2609 N. 145th East Avenue
         Tulsa, Oklahoma 74116
         918-437-3902

Any request for emergency assistance will be issued by telephone by the primary emergency
coordinator, the on-site coordinators, or their designee. Lafarge will have someone at the plant
entrance to give specific directions to the incident. One of the emergency coordinators will be at
the scene to brief you on the assistance required.

The materials primarily being handled at the Tulsa facility are organic compounds which have
been used as industrial solvents, coats, etc., that have been blended into Fuel Quality Waste
(FQW). Heavy metals will be present within the FQW. A Material Safety Data Sheet for typical
waste fuel is enclosed for your use. If an emergency arises, the specific compounds involved
will be immediately identified by consulting material inventory and analytical records at the
Systech facility which is located within the Lafarge Tulsa facility. A copy of the Lafarge
Contingency Plan, which describes emergency response procedures, identifies the type and
location of emergency equipment and sets forth emergency assistance requirements, is enclosed
with this agreement.

The _________________ agrees to provide emergency assistance to the Lafarge Tulsa facility, at
their request, if an incident occurs which requires facilities, equipment or expertise not available
at the facility.


_____________________________________________________________________________


Lafarge Tulsa:                                          _______________:

By:      ______________________________                 By:    ______________________________

Date: ______________________________                    Date: ______________________________




Rev. 2, April 2010                          Contingency Plan                          Page Att. G-4-2
Attachment 5
 Closure Plan
Lafarge Building Materials, Inc.      Tulsa, Oklahoma   U.S. EPA ID No. OKD064558703




                                       Section I

                      CLOSURE PLAN AND FINANCIAL
                                   REQUIREMENTS
                                       Revision 2
                                       April 2010




Revision 2, April 2010                  Closure Plan                         Page I-i
Lafarge Building Materials, Inc.                                Tulsa, Oklahoma                                 U.S. EPA ID No. OKD064558703




                          CLOSURE PLAN AND FINANCIAL REQUIREMENTS

                                                        Table of Contents

I.1                   Introduction............................................................................................................. 1
I.2                   General Closure Issues............................................................................................ 2
   I.2.1              Closure Performance Standard ............................................................................... 2
   I.2.2              Amendment to Closure Plan ................................................................................... 2
   I.2.3              Partial Closure......................................................................................................... 2
   I.2.4              Location and Retention of Closure Plan ................................................................. 3
   I.2.5              Notification of Partial/Final Closure....................................................................... 3
   I.2.6              Schedule for Closure............................................................................................... 3
      I.2.6.1         Time Allowed for Closure ...................................................................................... 3
      I.2.6.2         Extension for Closure Time .................................................................................... 4
   I.2.7              Closure Procedures Summary................................................................................. 4
      I.2.7.1         Disposal or Decontamination of Ancillary Equipment, Structures, and
                      Components ............................................................................................................ 4
       I.2.7.2        Pyroprocessing System ........................................................................................... 5
I.3                   Closure Procedure Details for Pyroprocessing System and Lafarge-Owned Feed
                      System..................................................................................................................... 7
   I.3.1              Description of Regulated Units............................................................................... 7
   I.3.2              Anticipated Closure Date........................................................................................ 7
   I.3.3              Notification of Final Closure .................................................................................. 8
   I.3.4              Closure Schedule .................................................................................................... 8
   I.3.5              Disposal of Maximum Inventory of Hazardous Liquid Waste-Derived Fuel......... 9
   I.3.6              Closure Procedures ............................................................................................... 10
      I.3.6.1         Cement Kilns, Kiln Combustion Components, and Air Pollution Control System
                      Closure .................................................................................................................. 10
      I.3.6.2         Ancillary Equipment Closure ............................................................................... 11
I.4                   Closure Standards ................................................................................................. 13
   I.4.1              Cement Kiln, Kiln Combustion Components, and Air Pollution Control System
                      Closure Standards ................................................................................................. 13
   I.4.2              Ancillary Equipment Closure Standards............................................................... 14
I.5                   Closure Cost Estimate........................................................................................... 16
I.6                   Financial Assurance Mechanism for Closure and Liability.................................. 17


                                            ATTACHMENTS
Att. I-1              Closure Sampling and Analysis Plan
Att. I-2              Closure Cost Estimate
Att. I-3              Financial Assurance Documents




Revision 2, April 2010                                             Closure Plan                                                          Page I-ii
Lafarge Building Materials, Inc.                    Tulsa, Oklahoma              U.S. EPA ID No. OKD064558703




I.1                     INTRODUCTION

The information in this section is submitted in accordance with 40 CFR 270.14(b)(13). The
purpose of this Closure Plan is to ensure that the Lafarge Tulsa kilns will be closed pursuant to
40 CFR 264.111 through 264.115, 266.102, and OAC 252:205-3-2(f). This section includes:
           •            Closure plan description;
           •            Closure cost estimate;
           •            Financial assurance mechanism for closure; and,
           •            Liability coverage mechanism for sudden accidental occurrences.

A Post-Closure Plan is not required since the waste management activities at the plant do not
include the land disposal of hazardous waste. The kiln, Fuel Quality Waste (FQW) feed piping
owned by Lafarge, and all ancillary equipment will be decontaminated, and all decontamination
residues will be removed from the premises. Therefore, no waste inventory will remain at the
plant following closure that would require post-closure maintenance.

Lafarge will keep a copy of the Closure Plan as part of the Operating Record at the facility until
the certificate of final closure has been accepted by the Oklahoma Department of Environmental
Quality (ODEQ).




Revision 0, June 2009                                 Closure Plan                                   Page I-1
Lafarge Building Materials, Inc.               Tulsa, Oklahoma                  U.S. EPA ID No. OKD064558703




I.2                     GENERAL CLOSURE ISSUES

           I.2.1        Closure Performance Standard

           40 CFR 264.111 and OAC 252:205-3-2(f) require that closure of the facility be
           performed in a manner that minimizes the need for further maintenance and controls,
           minimizes or eliminates threats to human health and the environment, and minimizes or
           eliminates the post-closure escape of hazardous waste and hazardous-waste constituents
           to the environment.

           The Closure Plan proposed by Lafarge achieves those objectives.             FQW, including
           decontamination residues, either will be treated thermally in the pyroprocessing system or
           will be transported off-site to a permitted or interim status treatment, storage, or disposal
           (TSD) facility. The equipment and plant areas associated with the management of FQW
           will be decontaminated to the levels specified in the Closure Plan, if appropriate,
           removed and disposed of off-site at a permitted or interim status TSD facility, or metal
           components will be recycled as scrap.

           I.2.2        Amendment to Closure Plan

           In accordance with 40 CFR 264.112(c), Lafarge will submit a written notification or
           request for a permit modification to ODEQ to obtain authorization to amend the Closure
           Plan if: 1) changes in the operating plans or facility design affect the Plan; 2) the year of
           expected closure changes, if applicable; or 3) modifications to the Plan become necessary
           because of unexpected events during partial or final closure activities.

           I.2.3        Partial Closure

           Lafarge does not anticipate the need to conduct partial closure of the pyroprocessing
           system; but, for a variety of reasons, partial closure of one or more hazardous waste
           management units (i.e., kilns) within the facility may occur. In the event that partial
           closure is implemented for a kiln, the same closure procedures outlined for final closure
           will be implemented during partial closure.




Revision 0, June 2009                            Closure Plan                                       Page I-2
Lafarge Building Materials, Inc.                    Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




           I.2.4        Location and Retention of Closure Plan

           A copy of this Closure Plan and subsequent amendments will be maintained in the
           Operating Record at the facility until Completion of Closure Certifications have been
           submitted to and accepted by ODEQ.

           I.2.5        Notification of Partial/Final Closure

           Lafarge will notify ODEQ in writing at least 45 days before partial/final closure activities
           are expected to begin. If the facility permit is terminated or the facility is ordered closed
           by judicial decree or a final order under RCRA §3008, closure notification is not
           required.

           I.2.6        Schedule for Closure

                        I.2.6.1 Time Allowed for Closure

                        Lafarge anticipates completing closure activities within 180 days of receipt of the
                        final volume of waste materials from Systech. All waste materials burned in the
                        Lafarge Tulsa kilns are provided by the onsite Systech facility under its RCRA
                        permit.

                        If the Systech facility is to be closed simultaneously with the Lafarge Tulsa kilns,
                        the closure of the Systech facility will occur according to the Closure Plan in the
                        Systech permit.    The Systech Closure Plan includes the FQW tanks, truck
                        unloading area, and feed piping owned by Systech.            Table I-1 shows an
                        anticipated schedule for closure of the pyroprocessing system and the Lafarge-
                        owned waste materials feed systems.

                        The projected schedule of closure activities for full closure of the Lafarge Tulsa
                        plant is presented in Table I-1. This schedule complies with the time limitations
                        of 40 CFR 264.113(b) and OAC 252:205-3-2(f) by anticipating full closure within
                        180 days of receipt of the final volume of FQW.




Revision 0, June 2009                                 Closure Plan                                      Page I-3
Lafarge Building Materials, Inc.                     Tulsa, Oklahoma               U.S. EPA ID No. OKD064558703




                        I.2.6.2 Extension for Closure Time

                        Lafarge does not anticipate that closure activities will take more than 180 days to
                        complete. If unforeseen circumstances result in a delay of the closure schedule,
                        Lafarge will request a schedule extension from ODEQ in accordance with 40 CFR
                        264.113(b)(2) and OAC 252:205-3-2(f).

           I.2.7        Closure Procedures Summary

           Section I.3 describes the closure procedures Lafarge will implement to close the kilns,
           ancillary equipment, and Lafarge-owned waste feed system components.

                        I.2.7.1 Disposal or Decontamination of Ancillary Equipment, Structures, and
                                   Components

                        The Closure Plan addresses disposal and decontamination activities in accordance
                        with 40 CFR 264.114 and OAC 252:205-3-2(f). Decontamination procedures,
                        generally, are as follows.

                        Equipment is triple-rinsed using detergents or solvents capable of removing FQW
                        constituents.    Alternatively, steam cleaning, high-pressure water sprays,
                        degreasing detergents, or other appropriate cleaning technology may be used to
                        clean and decontaminate equipment. Where appropriate, equipment is dismantled
                        or disassembled prior to such cleaning.

                        Effective decontamination will be determined by testing rinsates for specified
                        constituents of concern using the applicable procedures contained in the then-
                        current edition of Test Methods for Evaluating Solid Waste, Physical/Chemical
                        Methods, (SW-846). The constituents of concern are those constituents contained
                        in 40 CFR Part 261, Appendix VIII that have ever been contained in FQW placed
                        in the equipment or area to be decontaminated. These constituents of concern are
                        identified by the waste codes listed on the Uniform Hazardous Waste Manifests
                        for FQW received at the facility. Decontamination is considered complete when




Revision 0, June 2009                                  Closure Plan                                    Page I-4
Lafarge Building Materials, Inc.                       Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703



                        the concentration of constituents of concern is at or below a level prescribed by
                        Lafarge and approved by ODEQ and described in Section I.4.

                        In addition to these options, Lafarge may also elect to remove residuals, rinse
                        metal components, and recycle this material as scrap metal.

                        Two FQW feed lines to the kiln and one return line on Lafarge property will be
                        cut off after decontamination, placed in a roll-off, and shipped off-site as scrap
                        metal.

                        Rinsates and cleaning supplies will be managed as hazardous waste and disposed
                        of by burning for energy recovery in the on-site pyroprocessing system, if
                        appropriate. Otherwise, these wastes will be transferred off-site to a permitted or
                        interim status TSD facility.

                        Decontamination supplies, such as disposable personal protective equipment,
                        brooms, mops, squeegees, rags, etc., will be managed as hazardous waste and
                        disposed of by thermal treatment in the on-site pyroprocessing system, if
                        appropriate, or disposed of off-site at a permitted or interim status TSD facility.

                        Non-expendable equipment used during cleaning and decontamination is
                        decontaminated by triple-rinsing using detergents or solvents capable of removing
                        FQW constituents.

                        Since disposal and decontamination activities will result in Lafarge becoming a
                        generator of hazardous waste, such waste will be handled in accordance with the
                        requirements of 40 CFR Part 262 and OAC 252:205-3-2(d).

                        I.2.7.2 Pyroprocessing System

                        The components of the pyroprocessing system that will be decontaminated
                        include the equipment that may come into direct contact with FQW or FQW
                        residues. The components include the following.

                           •       The rotary kilns and kilns’ multi-channel burner pipes.


Revision 0, June 2009                                    Closure Plan                                      Page I-5
Lafarge Building Materials, Inc.                      Tulsa, Oklahoma               U.S. EPA ID No. OKD064558703




                           •       The cement kiln dust (CKD)-handling system used to transport CKD from
                                   the baghouses. This system will only be addressed in the event that CKD
                                   is ever determined to be hazardous per 40 CFR 266.112 and OAC
                                   252:205-3-2(h).




Revision 0, June 2009                                   Closure Plan                                    Page I-6
Lafarge Building Materials, Inc.                       Tulsa, Oklahoma                U.S. EPA ID No. OKD064558703




I.3                     CLOSURE PROCEDURE DETAILS FOR PYROPROCESSING SYSTEM
                        AND LAFARGE-OWNED FEED SYSTEM

This Closure Plan has been prepared in accordance with 40 CFR 264.111, 40 CFR 264.112, and
OAC 252:205-3-2(f) for the pyroprocessing system that burns FQW at the Lafarge Cement Plant
located in Tulsa, Oklahoma.

           I.3.1        Description of Regulated Units

           This Closure Plan describes how Lafarge intends to close the plant’s pyroprocessing
           system that burns FQW and the associated Lafarge-owned ancillary equipment and
           components, i.e., feed systems. For the purpose of this Closure Plan, the regulated units
           are defined as follows.

                        Pyroprocessing System

                           •       The rotary kilns, the kilns’ multi-channel burner pipes, and associated
                                   ancillary equipment that may come into direct contact with FQW or FQW
                                   residues.
                           •       The CKD handling system used to transport CKD from the baghouses to
                                   the CKD holding silos. This system will only be addressed in the event
                                   that CKD is ever determined to be hazardous per 40 CFR 266.112 and
                                   OAC 252:205-3-2(h).

                        Lafarge-Owned Feed System

                           •       The Lafarge-owned feed system consisting of piping, fittings, instruments,
                                   and valves.

           I.3.2        Anticipated Closure Date

           Final closure of the pyroprocessing system is not expected to occur before the year 2035.




Revision 0, June 2009                                    Closure Plan                                     Page I-7
Lafarge Building Materials, Inc.                  Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




           I.3.3        Notification of Final Closure

           Lafarge will notify ODEQ in writing at least 45 days before the date on which final
           closure of the pyroprocessing system is expected to begin. Closure is expected to be
           completed no later than 180 days after initiation of closure.

           I.3.4        Closure Schedule

           Lafarge will begin closure within 30 days of the date on which the known final volume of
           FQW is received for use in the pyroprocessing system. However, if there is a reasonable
           possibility that the kiln will receive additional FQW, the closure will begin within a year
           after the date on which the kiln received the most recent volume of FQW. At least 45
           days before beginning the final/partial closure, Lafarge will submit a notice in writing to
           ODEQ stating the date closure is expected to begin. Lafarge intends to complete closure
           of the units within 180 days of the start of closure. The schedule of closure activities is
           shown in Table I-1.

           Within 60 days of completion of closure activities, Lafarge will submit certification to
           ODEQ that the unit has been closed according to the approved Closure Plan.

           If closure cannot be accomplished within 180 days or if the Certificate of Closure cannot
           be prepared within the 60-day time period, Lafarge will submit to ODEQ a written
           request for an extension of the deadline. The request for an extension will be submitted
           at least 30 days before the expiration of the 180- or 60-day period.

           Lafarge will submit to ODEQ a written request for a permit modification, including a
           copy of the amended Closure Plan, for approval no later than 60 days after unexpected
           events or at least 60 days before proposed changes in facility design or operation that
           affect the Closure Plan. If an unexpected event occurs during the closure period, Lafarge
           will request from ODEQ a permit modification no later than 30 days after the unexpected
           event.




Revision 0, June 2009                               Closure Plan                                      Page I-8
Lafarge Building Materials, Inc.                       Tulsa, Oklahoma                U.S. EPA ID No. OKD064558703




                                   Table I-1: Projected Schedule of Closure Activities

                                                                                   Completion Date
                                          Closure Activity                          From Closure
                                                                                     Start Date
           1.           Removal of FQW from Lafarge-owned portion of the
                                                                                         Day 30
                        feed lines and return line
           2.           Decontamination of cement kilns                                  Day 60
           3.           Decontamination of ancillary equipment                           Day 90
           4.           Disposal of decontamination residuals and rinses                 Day 120
           5.           Completion of closure                                            Day 180
           6.           Submission of certification to ODEQ                              Day 240


           I.3.5        Disposal of Maximum Inventory of Hazardous Liquid Waste-Derived Fuel

           FQW burned in the Lafarge Tulsa kilns is provided by Systech under its RCRA permit.
           At closure, Lafarge will receive no additional FQW from Systech so that no bulk
           inventory of FQW will remain on Lafarge property. The disposal of the maximum
           inventory of FQW is limited to the volume of waste remaining in the Lafarge feed and
           return piping. However, as the worst-case scenario, FQW can remain in the two feed
           lines to the kiln and one return line. The amount of FQW in these lines on Lafarge
           property is calculated as follows:

           Amount of FQW:
                        = (2 feed lines x 750 ft/line + 1 return line x 750 ft/line) x π[3/(12x2)]2
                        = 2,250 ft x 0.049 ft2
                        = 110.45 ft3
                        = 826 gallons

           Hazardous wastes, including rinsates and decontamination residues, will be treated on-
           site in the pyroprocessing system or will be transported to an off-site permitted or interim
           status TSD facility.




Revision 0, June 2009                                    Closure Plan                                     Page I-9
Lafarge Building Materials, Inc.                        Tulsa, Oklahoma                  U.S. EPA ID No. OKD064558703




           I.3.6        Closure Procedures

                        I.3.6.1 Cement Kilns, Kiln Combustion Components, and Air Pollution
                                   Control System Closure

                        Standard kiln combustion components closure activities associated with the
                        kiln(s) combustion components shall consist of the following procedures:

                           •       Disconnect and dismantle burner control system, nozzles, flow meters,
                                   valves, feed and return lines, and other appurtenant equipment.
                           •       Use a high-pressure wash with detergent to clean any residues contained
                                   in the components.
                           •       Inspect kiln components for visual cleanliness. Clean again if necessary.
                                   Visual cleanliness will be an adequate closure criterion for ancillary
                                   equipment prior to recycling as scrap metal.
                           •       If Lafarge elects to reuse these components or to dispose of the items as
                                   other than hazardous waste, collect a final rinse water sample and analyze
                                   the sample, using methods outlined in Attachment I-1, to check for the
                                   presence of hazardous waste constituents.             The kiln combustion
                                   components will be considered clean closed when analytical results on the
                                   final rinse water sample indicate that levels of constituents are below the
                                   closure criteria presented in Section I.4.
                           •       Contaminated cleaning solutions, rinse waters, and other residues resulting
                                   from cleaning activities will be collected in appropriate containers. The
                                   contaminated materials will be pyroprocessed in the cement kiln, if
                                   applicable, or sent off-site for proper treatment and disposal.

                        Standard kiln and air pollution control system cleaning activities shall consist of
                        the following procedures:

                           •       Allow kiln to burn normally for 24 hours on non-hazardous fuel (e.g., fuel
                                   oil, petroleum coke, natural gas, coal, or other fuel).




Revision 0, June 2009                                     Closure Plan                                      Page I-10
Lafarge Building Materials, Inc.                        Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




                           •       During “burn out” period, collect and analyze samples of CKD at the main
                                   discharge point of each associated baghouse every 6 hours.
                           •       Analyze the CKD samples, using methods outlined in Attachment I-1, to
                                   check for the presence of hazardous waste constituents. The kiln and the
                                   associated air pollution control components will be considered clean
                                   closed when analytical results of the CKD indicate that levels of
                                   constituents are below the closure criteria presented in Section I.4.

                        I.3.6.2 Ancillary Equipment Closure

                        Routine operational replacement of Lafarge-owned ancillary equipment, such as
                        piping, valves, hoses, and fittings, etc., may require removal and partial closure
                        during the life of the facility. This section addresses the “partial closure” of these
                        items during the normal, routine operations of the facility, prior to reuse, recycle
                        for scrap metal recovery, or disposal as a hazardous waste.

                        Standard cleaning activities associated with ancillary equipment replacement
                        include the following procedures:

                           •       Isolate and remove all liquid from the equipment. A vacuum pump may
                                   be used, if necessary. Transfer the liquid contents to a tank/container that
                                   is in hazardous waste service for further processing and/or proper disposal.
                           •       Remove any solids/slurry that may have settled out, using a vacuum pump
                                   if necessary. Transfer the solids/slurry contents into a tank/container that
                                   is in hazardous waste service for further processing and/or proper disposal.
                           •       Clean the parts and/or equipment using parts washers; recirculation of
                                   virgin or recycled solvents such as alcohols, ketones, aliphatic
                                   hydrocarbons, etc.; and/or high-pressure wash with detergent solution and
                                   other methods to remove visible signs of contamination.
                           •       Inspect the equipment for visual cleanliness. Repeat the above steps if
                                   necessary. Visual cleanliness will be the adequate closure criteria for
                                   ancillary equipment prior to recycling as scrap metal.



Revision 0, June 2009                                     Closure Plan                                     Page I-11
Lafarge Building Materials, Inc.                        Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




                           •       If Lafarge elects to reuse this equipment, collect a final rinse water sample
                                   and analyze the rinse water, using methods outlined in Attachment I-1, to
                                   check for the presence of hazardous waste constituents. The equipment
                                   will be certified as clean closed when analytical results of the final rinse
                                   water indicate that levels of constituents are below the closure criteria
                                   presented in Section I.4.
                           •       Equipment that meets the clean closure criteria will be removed from
                                   service. Equipment that does not meet the criteria will have the cleaning
                                   steps repeated until they meet the requirements or the item will be
                                   disposed at an off-site facility as hazardous waste, or it will be shipped
                                   off-site as scrap metal.

                        Cleaning solutions, rinse waters, and other liquids resulting from cleaning
                        activities will be collected and may be fuel blended, if appropriate, or sent off-site
                        for proper treatment or disposal. Following cleaning and decontamination, the
                        parts and/or equipment will be available for reuse, recycle for scrap metal
                        recovery, or disposed of as non-hazardous waste.




Revision 0, June 2009                                     Closure Plan                                     Page I-12
Lafarge Building Materials, Inc.                     Tulsa, Oklahoma                  U.S. EPA ID No. OKD064558703




I.4                     CLOSURE STANDARDS

           I.4.1        Cement Kiln, Kiln Combustion Components, and Air Pollution Control
                        System Closure Standards

           In order to verify that the kiln and its associated combustion and air pollution control
           components have been properly decontaminated, the kiln and its associated combustion
           and air pollution control components shall be considered clean closed when sampling
           verifies the following.

                  •     Kiln and Air Pollution Control Equipment - CKD samples exhibit metals
                        concentrations below Toxicity Characteristic Leaching Potential (TCLP)
                        hazardous waste levels.
                  •     Kiln Combustion Components - Final rinsate samples exhibit constituent
                        concentrations below practical quantitation limits (PQLs) or below two standard
                        deviations of an average (three sample minimum) background constituent
                        concentration of the rinse water used during the final rinse activities.

           Final rinse samples from the kiln combustion components will be collected and analyzed
           for total metals, volatile organics, and semi-volatile organics as presented in Attachment
           I-1.       To achieve the clean closure standard for the combustion components, the
           components will be emptied of all hazardous wastes (i.e., liquids and solids).
           Subsequently, the combustion components will be cleaned and rinsed adequately to
           achieve the clean closure standard. Rinsate generated during kiln combustion component
           cleaning will be managed as a hazardous waste, with the exception of final rinsates that
           meet the clean closure standard. Rinsate material not demonstrated to meet the clean
           closure standard will be pyroprocessed in the cement kiln or transported off-site for
           proper disposal.




Revision 0, June 2009                                  Closure Plan                                      Page I-13
Lafarge Building Materials, Inc.                    Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703



           Following the final kiln combustion component rinsing, the following options, dependent
           upon rinsate analysis, may be exercised.

                •       If the final rinsate meets the clean closure standard, no end use restrictions shall
                        be placed on decontaminated combustion components and closure of the
                        combustion components will be deemed final.
                •       Combustion components that cannot meet the clean closure standard will be
                        recycled as scrap metal.

           Alternately, units may be scrapped for metal recovery without performing rinsate
           analyses after visible signs of contamination have been removed from them.

           CKD samples will be collected from the discharge of the air pollution control devices and
           analyzed for TCLP metals as described in Attachment I-1. To achieve the clean closure
           standard for the kiln and air pollution control components, the kiln will be burned
           normally for 24 hours on non-hazardous fuel (e.g., fuel oil, petroleum coke, natural gas,
           coal, or other fuel).

           During this “burn out” period, four samples of CKD will be collected at the discharge of
           the baghouses and analyzed at 6-hour intervals. The kiln and the associated air pollution
           control components will be considered clean closed when the CKD samples exhibit
           metals concentrations below TCLP hazardous waste levels.

           I.4.2        Ancillary Equipment Closure Standards

           In order to verify that ancillary equipment has been properly decontaminated, the
           ancillary equipment shall be considered clean closed when the sampling verifies that the
           final rinsate sample exhibits constituent concentrations below PQLs or below two
           standard deviations of an average (three sample minimum) background constituent
           concentration of the rinse water used during final rinse activities.

           Final rinsate samples will be collected and analyzed for total metals, volatile organics,
           and semi-volatile organics, as presented in Attachment I-1. To achieve the clean closure
           standard, the ancillary equipment will be initially emptied of all hazardous wastes (i.e.,


Revision 0, June 2009                                 Closure Plan                                     Page I-14
Lafarge Building Materials, Inc.                    Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703



           liquids and solids). Subsequently, the ancillary equipment will be cleaned and rinsed
           adequately to achieve the clean closure standard. Rinsates generated during equipment
           cleaning will be managed as a hazardous waste, with the exception of final rinsates that
           meet the clean closure standard. Rinsate material not demonstrated to meet clean closure
           standards will be pyroprocessed in the cement kiln or transported off-site for proper
           disposal.

           Following final ancillary equipment rinsing, the following options, dependent upon
           rinsate analysis, may be exercised.

                •       If the final rinsate meets the clean closure standard, no and use restrictions shall
                        be placed on decontaminated process equipment and closure of the ancillary
                        equipment unit will be deemed final.
                •       Ancillary equipment that cannot meet the clean closure standard will be recycled
                        as scrap metal.

           Alternately, units may be scrapped for metal recovery without performing rinsate
           analyses after visible signs of contamination have been removed from them.




Revision 0, June 2009                                 Closure Plan                                     Page I-15
Lafarge Building Materials, Inc.                 Tulsa, Oklahoma               U.S. EPA ID No. OKD064558703




I.5                   CLOSURE COST ESTIMATE

An estimate of the closure cost for the pyroprocessing system and associated Lafarge-owned
feed system components for the Lafarge Tulsa plant has been developed and is included in
Attachment I-2.               The closure cost estimates have been based on off-site shipment of
approximately 826 gallons of FQW (from the feed and return lines) and rinsates generated from
the clean closure of the ancillary equipment and equipment decontamination activities. The
estimated decontamination costs for equipment and structures have been listed.                        The
decontamination costs include labor, sampling, and testing. The cost of obtaining a Closure
Certificate from a registered Professional Engineer is also included.             Administrative and
contingency costs of 15% each of the total closure cost estimate have been included in the
estimate. No salvage value from the recycling of scrap metal components has been incorporated
in the estimate.

Closure cost estimates are adjusted annually for inflation in accordance with 40 CFR 264.142(b)
and OAC 252:205-3-2(f).              The latest closure cost estimates and the latest adjustments for
inflation are kept in the facility Operating Record, in accordance with 40 CFR 264.142(d) and
OAC 252:205-3-2(f).




Revision 2, April 2010                             Closure Plan                                   Page I-16
Lafarge Building Materials, Inc.          Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




I.6                   FINANCIAL    ASSURANCE       MECHANISM        FOR      CLOSURE           AND
                      LIABILITY

Lafarge will establish financial assurance for the closure of the Tulsa pyroprocessing system and
Lafarge-owned ancillary equipment. The option that will be selected by Lafarge to provide
financial assurance as a bond as provided in 40 CFR 264.143(c) and OAC 252:205-3-2(f).
Documents demonstrating financial assurance for closure and liability requirements for the
Lafarge Tulsa plant pyroprocessing systems will be provided to the Department at least 60-days
before the date on which hazardous waste is first received for treatment, storage or disposal. A
copy of this document will be placed in Attachment I-3.




Revision 2, April 2010                      Closure Plan                                     Page I-17
Lafarge Building Materials, Inc.                Tulsa, Oklahoma     U.S. EPA ID No. OKD064558703




                                              Attachment I-1


                                   CLOSURE SAMPLING AND ANALYSIS PLAN




Revision 0, June 2009                             Closure Plan                     Page Att. I-1-1
Lafarge Building Materials, Inc.                    Tulsa, Oklahoma                 U.S. EPA ID No. OKD064558703




                                   CLOSURE SAMPLING AND ANALYSIS PLAN


1.0        PURPOSE

The purpose of this Plan is to provide an outline of the sampling and analyses that will be
performed during closure of the pyroprocessing system and ancillary equipment.

2.0        MEDIA TO BE SAMPLED AND ANALYZED

Samples of CKD and rinse water (if applicable) will be analyzed. Rinse water may be analyzed
for volatile organics according to Method 8260, semi-volatile organics according to Method
8270, and for total metals by using the Method 3050 digestion procedure followed by
Inductively Coupled Argon Plasma analysis for metals according to Method 6010 and the 7000
series methods for specific metals. CKD samples will be analyzed for TCLP metals utilizing
Method 1311. These analyses will provide a suitable representation of the hazardous waste
constituents managed in the pyroprocessing units and ancillary equipment. Table AI-1 provides
a list of the hazardous constituents contained in the analytical suites with the associated practical
quantitation limit (PQL).

3.0        FIELD SAMPLING PROCEDURES

           3.1          Rinsate Samples

           The rinsate sampling procedure will consist of collecting samples of the final rinsate from
           kiln combustion components and ancillary equipment. Rinse water samples will be
           collected utilizing standard sample collection techniques and placed into an appropriate
           sample jar.             QA/QC samples will also be collected as described in Section 5.0.
           Appropriate personnel protective equipment (PPE) and sample collection procedures will
           be utilized in order to minimize exposure and potential cross-contamination of samples.

           3.2          CKD Samples

           CKD samples will be collected from the discharge of the baghouse(s) every 6 hours
           during the course of the 24-hour burnout period. CKD will be collected by placing an
           appropriate sample jar into the access ports.              QA/QC samples will be collected as

Revision 0, June 2009                                 Closure Plan                                 Page Att. I-1-2
Lafarge Building Materials, Inc.                Tulsa, Oklahoma               U.S. EPA ID No. OKD064558703



           described in Section 5.0. Appropriate PPE and sample collection procedures will be
           utilized in order to minimize exposure and potential cross-contamination of samples.

           3.3          Background Samples

           Background samples of rinse water (if appropriate) will be collected for the purpose of
           determining if the clean closure criteria have been met. Background rinse water samples
           will be collected from the water source providing the water for rinsing activities. A
           minimum of three background samples from the media will be collected. Background
           samples will be collected utilizing standard sample collection techniques.

4.0        SAMPLING                METHODS,    EQUIPMENT,         AND      DECONTAMINATION
           PROCEDURES

Final rinsate samples from the ancillary equipment will be taken by draining the final rinsate
directly into the sample jar or using a COLIWASA after draining the rinsate in a clean container.
Background water samples of rinse water will be collected by first putting the rinse water in a
clean container and then pouring the rinse water into a sample jar, or by directly pouring the
rinse water into a sample jar from the source. CKD sampling at closure will be performed by
using a scoop, or by directly putting the CKD into the sample jar through CKD sampling ports.
Proper cleaning and decontamination of all sampling implements that contact the samples will be
ensured to prevent cross-contamination and assure valid analytical results.

Workers who clean or use the sampling implements must wear protective gloves to protect
themselves and to prevent the equipment from being contaminated. During the decontamination
procedures, all rinsate material will be accumulated for disposal as hazardous waste, in
accordance with all applicable regulations.

           4.1          Sample Preservation and Holding Times

           The samples will be collected in clean glass containers with Teflon-lined lids. The
           samples will be preserved by refrigeration at or below 4°C until extraction and analysis.
           The maximum allowable sample holding time and preservative, if any, are listed in Table
           AI-1.


Revision 0, June 2009                             Closure Plan                               Page Att. I-1-3
Lafarge Building Materials, Inc.               Tulsa, Oklahoma                  U.S. EPA ID No. OKD064558703




5.0        QA/QC

           5.1          QA/QC Plan for Field Sampling

           In order to ensure reliable sampling results, trip blanks, field blanks, and duplicate
           samples will be taken at least once with each analytical media batch with a minimum of
           once for every twenty samples in each media batch. Strict chain-of-custody procedures
           would be followed in transferring the samples to the selected analytical laboratory.

           5.2          QA/QC Plan for Laboratory Analysis

           In order to ensure reliable analytical results, a laboratory that has an established, written
           QA/QC Program that follows USEPA guidelines will be retained to perform the analyses.




Revision 0, June 2009                            Closure Plan                                  Page Att. I-1-4
      Lafarge Building Materials, Inc.                         Tulsa, Oklahoma                   U.S. EPA ID No. OKD064558703


                                         Table AI-1: Liquid Analytical Parameters
                                                                                                         Sample           Sample
    Test                                                                                                 Holding         Container
Parameters        Method1          Instrument                Analytes (CAS No.)             PQLs2         Times         Preservative
Total Metals      SW6010               ICP       Antimony (Sb) (7440-36-0)                0.06 (mg/l)    180 days           liter
                  (metals)                       Arsenic (As) (7440-38-2)                     0.05                      polyethylene,
                                                 Barium (Ba) (7440-39-3)                      0.02                       HN03, 4oC
                                                 Beryllium (Be) (7440-41-7)                  0.005
                                                 Cadmium (Cd) (7440-43-9)                    0.005
                                                 Chromium (Cr) (7440-47-3)                   0.005
                                                 Lead (Pb) (7439-92-1)                        0.05
                                                 Nickel (Ni) (7440-02-0)                      0.01
                                                 Silver (Ag) (7440-22-4)                      0.01
                                                 Selenium (Se) (7782-49-2)                    0.10
                                                 Thallium (Tl) (7440-28-0)                    0.10
                  SW7470           Cold Vapor    Mercury (Hg) (7439-97-6)                 0.20 (mg/l      28 days       (See above)
                 (mercury)
 Organic          SW8270             GC/MS       Phenol (108-95-2)                         10 (ppb)       14 days       1 liter amber,
Constituents       (semi-                        Bis(2-Chloroethyl)Ether(111-44-4)            10                              4oC
                 volatiles)                      2-Chlorophenol (95-57-8)                     10
                                                 1,3-Dichlorobenzene (541-73-1)               10
                                                 1,4-Dichlorobenzene (106-46-7)               10
                                                 Benzyl Alcohol (100-51-6)                    10
                                                 1,2-Dichlorobenzene (95-50-1)                10
                                                 2-Methylphenol (1319-77-3)                   10
                                                 Bis(2-Chloroisopropyl)Ether (108-60-1)       10
                                                 4-Methylphenol (108-39-4)                    10
                                                 N-Nitroso-Di-n-Propylamine                   10
                                                 Hexachloroethane (67-72-1)                   10
                                                 Nitrobenzene (98-95-3)                       10
                                                 Isophorone (78-59-1)                         10
                                                 2,4-Dimethylphenol (105-67-9)                10
                                                 2-Nitrophenol (88-75-5)                      10
                                                 Benzoic Acid (65-85-0)                       50
                                                 Bis(2-Chloroethoxy)Methane                   10
                                                 2,4-Dichlorophenol (120-83-2)                10
                                                 1,2,4-Trichlorobenzene (120-82-1)            10
                                                 Naphthalene (91-20-3)                        10
                                                 4-Chloroaniline (108-42-9)                   10
                                                 Hexachlorobutadiene (87-68-3)                10
                                                 4-Chloro-3-Methylphenol                      10
                                                 2-Methylnaphthalene (91-57-6)                10
                                                 Hexachlorocyclopentadiene (77-47-4)          10
                                                 2,4,6-Trichlorophenol (88-06-2)              10
                                                 2,4,5-Trichlorophenol (95-95-4)              50
                                                 2-Chloronaphthalene (91-58-7)                10
                                                 2-Nitroaniline (88-74-4)                     50
                                                 Dimethylphthalate (131-11-3)                 10
                                                 2,6-Dinitrotoluene (606-20-2)                10
                                                 Acenaphthylene (208-96-8)                    10
                                                 3-Nitroaniline (100-01-6)                    50
                                                 Acenaphthene (83-32-9)                       10
                                                 2,4-Dinitrophenol (51-28-5)                  50
                                                 4-Nitrophenol (100-02-7)                     50
                                                 2,4-Dinitrotoluene (121-14-2)                10
                                                 Dibenzofuran (132-64-9)                      10
                                                 Diethylphthalate (84-66-2)                   10
                                                 4-Chlorophenyl-Phenylether                   10
                                                 Fluorene (86-73-7)                           10
                                                 4-Nitroaniline (99-09-2)                     50
                                                 4,6-Dinitro-2-Methylphenol                   50
                                                 N-Nitrosodiphenylamine (86-30-6)             10



      Revision 0, June 2009                                      Closure Plan                                   Page Att. I-1-5
      Lafarge Building Materials, Inc.                          Tulsa, Oklahoma                           U.S. EPA ID No. OKD064558703

                                                                                                                     Sample              Sample
   Test                                                                                                              Holding           Container
Parameters        Method1          Instrument                Analytes (CAS No.)                      PQLs2            Times          Preservative
 Organic          SW8270             GC/MS       4-Bromophenyl-Phenylether (101-55-3)                  10            14 days       1 liter amber, 4oC
Constituents       (semi-                        Hexachlorobenzene (118-74-1)                          10
 (Cont'd)         volatiles)                     Pentachlorophenol (87-86-5)                           50
                  (cont’d)                       Phenanthrene (85-01-8)                                10
                                                 Anthracene (120-12-7)                                 10
                                                 Di-N-Butylphthalate (84-74-2)                         10
                                                 Fluoranthene (206-44-0)                               10
                                                 Pyrene (129-00-0)                                     10
                                                 Butylbenzylphthalate                                  10
                                                 Bis(2-Ethylhexyl)phthalate (117-81-7)                 10
                                                 3,3'-Dichlorobenzidine (91-94-1)                      50
                                                 Benzo(A)Anthracene (56-55-3)                          10
                                                 Chrysene (218-01-9)                                   10
                                                 Di-N-Octylphthalate (117-84-0)                        10
                                                 Benzo(b)Fluoranthene (205-99-2)                       10
                                                 Benzo(k)Fluoranthene (207-08-9)                       10
                                                 Benzo(a)Pyrene (50-32-8)                              10
                                                 Dibenzo(A,H)Anthracene (53-70-3)                      10
                                                 Indeno(1,2,3-CD)Pyrene (193-39-5)                     10
                                                 Benzo(G, H, I)Perylene (191-24-2)                     10
                  SW8260             GC/MS       Chloromethane (74-87-3)                            10 (ppb)         14 days         2-40 ml vials,
                 (volatiles)                     Bromomethane (74-83-9)                                10                              HCL, 4oC
                                                 Vinyl Chloride (75-01-4)                              10
                                                 Chloroethane (75-00-3)                                10
                                                 Methylene Chloride (75-09-2)                           5
                                                 Acetone (67-64-1)                                     10
                                                 Carbon Disulfide (75-15-0)                             5
                                                 1,1-Dichloroethene (75-35-4)                           5
                                                 1,1-Dichloroethane (75-34-3)                           5
                                                 Total-1,2-Dichloroethene (540-59-0)                    5
                                                 Chloroform (67-66-3)                                   5
                                                 1,2-Dichloroethane (107-106-2)                         5
                                                 2-Butanone (78-93-3)                                  10
                                                 1,1,1-Trichloroethane (71-55-6)                        5
                                                 Carbon Tetrachloride (56-23-5)                         5
                                                 Vinyl Acetate (108-05-4)                              10
                                                 Bromodichloromethane (75-27-4)                         5
                                                 1,1,2,2-Tetrachloroethane (79-34-5)                    5
                                                 1,2-Dichloropropane (78-87-5)                          5
                                                 Trans-1,3-Dichloropropene (10061-02-6)                 5
                                                 Trichloroethene (79-01-6)                              5
                                                 Dibromochloromethane                                   5
                                                 1,1,2-Trichloroethane (79-00-5)                        5
                                                 Benzene (71-43-2)                                      5
                                                 Cis-1,3-Dichloropropene (10061-01-5)                   5
                                                 Bromoform (75-25-2)                                    5
                                                 2-Hexanone (591-78-6)                                 10
                                                 4-Methyl-2-Pentanone (108-10-1)                       10
                                                 Tetrachloroethene                                      5
                                                 Toluene (108-88-3)                                     5
                                                 Chlorobenzene (108-90-7)                               5
                                                 Ethylbenzene (100-41-4)                                5
                                                 Styrene (100-42-5)                                     5
                                                 Total Xylenes (1330-20-7)                              5
      1
       Methods are from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods SW-846, USEPA.
      2
       PQLs - Practical Quantitation Limits. These PQLs represent typical laboratory reporting limits for liquids.
      CAS No. - Chemical Abstract Service Number
      GC/MS - Gas Chromatography/Mass Spectrometer
      GC - Gas Chromatography
      ICP - Inductivity Coupled Plasma


      Revision 0, June 2009                                       Closure Plan                                                 Page Att. I-1-6
Lafarge Building Materials, Inc.          Tulsa, Oklahoma   U.S. EPA ID No. OKD064558703




                                        Attachment I-2


                                   CLOSURE COST ESTIMATE




Revision 0, June 2009                       Closure Plan                   Page Att. I-2-1
Lafarge Building Materials, Inc.                     Tulsa, Oklahoma                         U.S. EPA ID No. OKD064558703




                                               ATTACHMENT I-2
                                        CLOSURE COST ESTIMATE

                     Closure Cost Estimate 1                                                Cost
                 Lafarge Kilns and Feed System                          Quantity          Per Unit              Cost
1.    Disposal of FQW in Piping on Lafarge Property
      a. Cost of 55-gallon drums (15 drums @ $67/drum)                    15 ea           $67/drum       $         1,005
      b. Cost of loading drums on trucks ($2.85/drum)                     15 ea          $2.85/drum      $            43
      c. Transportation cost (125 miles @ $4/mile)                      125 miles          $4/mile       $           500
      d. Disposal Cost                                                   826 gal          $0.25/gal      $           207
                Subtotal 1                                                                               $         1,755
2.    Dismantling of Burner Lances and Ancillary Piping               2 burner lances
      (approximately 10 feet per kiln)                                  20’ piping
      a. Labor (2 persons @ $52.48/hr x 8 hr/kiln x 2 kilns)              32 hrs          $52.48/hr      $         1,679
      b. Equipment, supplies, and PPE                                        1              $600         $           600
                Subtotal 2                                                                               $         2,279
3.    Decontamination of Burner Lances and Ancillary Piping           2 burner lances
      (approximately 10 feet per kiln)                                  20’ piping
      a. Labor (2 persons @ $52.48/hr x 4 hr/kiln x 2 kilns)              16 hrs          $52.48/hr      $           840
      b. Equipment, supplies, and PPE                                        1              $800         $           800
      c. 55-gal drums (4 drums/kiln x 2 kilns x $67/drum)                    8            $67/drum       $           536
                Subtotal 3                                                                               $         2,176
4.    Off-site Transportation and Disposal of Generated                  400 gal
      Rinsate at Off-Site Thermal Treatment Facility
      a. Transport of rinsate (8 55-gal drums; 1 box truck; 16          1 shipment         $4/mile       $             64
           miles/truck)
      b. Disposal cost                                                   400 gal          $0.25/gal                  100
                Subtotal 4                                                                               $           164
5.    Removal of Fuel Feed Lines and Return Line on Lafarge
      Property
      a. Roll-off rental ($430/week)                                     1 week           $430/week      $           430
      b. Labor for cutting feed and return lines (No. of cuts -          37.5 hr           $52.48/hr     $         1,968
      2,250 ft / 15 ft = 150; time per cut = 15 minutes)
           Subtotal 5                                                                                    $         2,398
6.    Decontamination of Kilns by Burning Fuel Other Than                 2 kilns
      FQW
      a. Kiln operator                                                    48 hr            $75/hr        $        3,600
      b. Laborer                                                          48 hr           $52.48/hr      $        3,936
      c. Fuel costs (5 tons/hr x 24 hr x 2 kilns)                        240 tons          $58/ton       $       13,920
                Subtotal 6                                                                               $       21,456
7.    Decontamination Verification
      a. Analysis of CKD for TCLP metals                                10 samples      $569.25/sample   $         5,693
      b. Analysis of rinsate for organics and metals                    4 samples        $878/sample     $         3,512
      c. Labor                                                             8 hr           $52.48/hr      $           420
                Subtotal 7                                                                               $         9,625
8.    Closure Certification
      a. Third-party oversight (1 person @ $110/hr x 40 hr)               40 hr            $110/hr       $         4,400
           (expenses)                                                     5 days          $125/day       $           625
      b. Registered Professional Engineer (1 person @                     16 hr            $110/hr       $         1,760
           $110/hr x 16 hr)

1
    Based on values from CostPro 6.0 (May 2009) supplemented by disposal cost quotations.


Revision 0, June 2009                                  Closure Plan                                          Page Att. I-2-2
Lafarge Building Materials, Inc.          Tulsa, Oklahoma                U.S. EPA ID No. OKD064558703



                  Closure Cost Estimate 1                                Cost
             Lafarge Kilns and Feed System                  Quantity   Per Unit             Cost
    c. Closure report preparation and certification            1        $5,000       $        5,000
        Expenses                                               1         $200        $          200
             Subtotal 8                                                              $       11,985
                            SUBTOTAL (1 THROUGH 8)                                   $       51,838
9. Administration (15%)                                                              $        7,776
10. Contingency (15%)                                                                $        7,776
                      GRAND TOTAL (1 THROUGH 10)                                     $       67,389




Revision 0, June 2009                       Closure Plan                                 Page Att. I-2-3
Lafarge Building Materials, Inc.                  Tulsa, Oklahoma              U.S. EPA ID No. OKD064558703




                                                Attachment I-3


                                   FINANCIAL ASSURANCE DOCUMENTS


                                   To Be Provided Prior to First FQW Receipt




Revision 0, June 2009                               Closure Plan                              Page Att. I-3-1

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:9
posted:7/27/2012
language:Latin
pages:204