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					   Fact Sheet               Dow Chemical Company
    October                  901 Loveridge Road, Pittsburg, CA 94565
     2001


                            Draft Hazardous Waste Facility Boiler and Industrial
                            Furnace Permit and Draft CEQA Negative Declaration

                            INTRODUCTION
                                                                                            Public Hearing &
                            The California Environmental Protection Agency                  Comment Period
                            (Cal/EPA), Department of Toxic Substances
                            Control (DTSC) is seeking public input on a                     DTSC will hold a public
                            draft hazardous waste permit for The Dow                        workshop and public hearing on
                            Chemical Company (Dow) at its facility located                  the draft Boiler and Industrial
                            on Loveridge Road in Pittsburg, California. The                 Furnace (BIF) Permit and draft
                            permit would authorize the continued storage of                 CEQA Initial Study and Negative
                            hazardous waste generated on-site and its                       Declaration on November 28,
                            processing in boiler & industrial furnaces. The                 2001.
                            treatment units consist of the two boiler &
                            industrial furnaces (also known as Halogen Acid                 Workshop: 3 p.m. - 5 p.m.
                            Furnaces) and associated hydrochloric acid                      Public Hearing: 7 p.m. - 9 p.m.
                            recovery and air pollution control systems.
                                                                                            Location: Pittsburg City Hall at
                            Past Public Participation Activities                            65 Civic Avenue, Pittsburg, CA

                            The United States Environmental Protection                      Members of the public are
                            Agency (EPA) public noticed the receipt of a                    welcome to submit comments
                            permit application for storage and processing of                between October 26, 2001 and
                            hazardous waste in the two Halogen Acid                         December 14, 2001 by writing to:
                            Furnaces (HAF units) from The Dow Chemical
                            Company, Pittsburg, California in May 1995.                     Waqar Ahmad, PhD, PE
                                                                                            DTSC
                            DTSC public noticed the receipt of the proposed                 700 Heinz Avenue, Suite 200
                            Trial Burn Plan for the HAF units on March 10,                  Berkeley, California 94702
                            1998.
                                                                                            Phone: (510) 540-3932
                            DTSC did not receive any comments from the                      Fax: (510) 540-3937
                            public during any of the above public comment                   e-mail: wahmad@dtsc.ca.gov
                            periods.



The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.
For a list of simple ways you can reduce demands and cut your energy costs, see our website at www.dtsc.ca.gov.
FACILITY LOCATION                                   THE RCRA PERMITTING
                                                    PROCESS
The Dow Chemical Co. is located at the end
of Loveridge Road in Pittsburg, Contra              The owners of hazardous waste treatment,
Costa County, California. Adjacent land is          storage, and disposal facilities (TSDF) are
primarily heavy industrial, agricultural or         required to obtain permits from the
unused. The site consists of approximately          Department of Toxic Substances Control.
450 acres, about half of which are                  DTSC is authorized by the United States
undeveloped and half are used for industrial        Environmental Protection Agency to
manufacturing activities.     The Pittsburg         implement the RCRA Permit program. The
facility is zoned for industrial use that is        owner must submit a permit application,
consistent with both the City of Pittsburg          which contains technical information about
and Contra Costa County General Plans.              the TSDF. This information includes
The closest residences are about one mile           equipment design, waste analysis plans,
from the HAF units. The nearest school and          emergency response plans, closure plans,
hospital are approximately two miles from           and other information. DTSC conducts a
the facility boundary.       No agricultural        technical review of the permit application.
activity takes places within one mile of the        Upon completion of technical review by
Pittsburg facility.                                 DTSC a determination is made on whether
                                                    the application meets all applicable
Facility Description                                standards. DTSC then either proposes to
                                                    issue a draft permit or proposes to deny the
The Dow Chemical Co. Pittsburg facility             permit application depending on the
currently operates 24-hours per day, seven          technical adequacy of the application. The
days per week. Operations include research          public is advised of the proposal to issue a
and development and the manufacture of              draft permit (or denial) by issuing a public
products for agricultural operations, pest          notice regarding the draft permit through the
control services, paper manufacturers, carpet       local media (newspaper advertisement).
mills, and biocides. During the manufacture         Also, the public notice and a fact sheet are
of chemical products at the facility, liquid        mailed to the public stating the basis for the
by-products are produced which are                  proposed decision and announcing a
thermally oxidized in the HAF units. These          minimum 45-day public comment period.
units also treat tank and process vent              During the public comment period, DTSC
gaseous emissions. Aqueous hydrochloric             receives comments from the public regarding
acid (HCl) is produced as a result of               the proposed decision. A public hearing is
thermally oxidizing the chlorinated liquids         held if requested by any member of the
and gas streams in the HAF units. The HCl           public or if DTSC determines there is
is sold as a product to various industrial          significant public interest in the proposed
customers and is also used within the Dow           decision. A court reporter is available at the
Chemical plant. The HAF units have been             public hearing to record public comments
in operation for over 20 years. The HAF             received. DTSC may revise the draft permit
units are an integral part of general               or change its decision based on public
production operations since the units               comments. Both the facility owner/operator
manufacture hydrochloric acid product.


                                                2
and participating public have a right to            PERMITTING HISTORY
appeal the final permit decision.
                                                    Dow Chemical is operating under interim
Regulated Hazardous Waste                           status. The HAF units have been regulated
Management Units That Would Be                      by the US Environmental Protection Agency
Authorized By the BIF Permit                        (USEPA) since the BIF rule became law in
                                                    1991. In February 1992, Dow submitted a
The following regulated units will be               BIF permit application to USEPA. For
authorized for continued operation under the        existing facilities like Dow, the BIF rule
draft BIF Permit.                                   required compliance certifications (to be
                                                    prepared every three years) while they were
1. Symtet Halogen Acid Furnace (ST                  operating under interim status.       These
HAF): The ST HAF unit burns about 500               certifications document conformance with
pounds per hour (lb/hr) of liquid chlorinated       air emission standards specified in the BIF
hydrocarbons and variable amounts of gases          rule (40 CFR 266.104-107). Dow submitted
and vapors from Dow manufacturing                   compliance certifications in August 1992,
processes and tanks.                                1995, 1998, and 2001.
2. Manufacturing Services Halogen Acid              The operation of the HAF units have also
Furnace (MS HAF): The MS HAF unit                   been regulated by Bay Area Air Quality
burns about 600 lb/hr of chlorinated                Management District (BAAQMD) permit
pyridines and variable amounts of gaseous           since June 1973. The BAAQMD permit
process vent streams.                               contains specific conditions and limitations
                                                    for operation of the HAF units. The Dow
3.   Liquid Hazardous Waste Storage                 Pittsburg site is also subject to the
Tanks T-501B and T-502A: These two                  BAAQMD Toxic Hot Spots legislation and
tanks store liquid hazardous waste feed that        BAAQMD fugitive emission control rules.
is processed in the ST HAF unit. The                The primary air contaminant of the HAF
volume of each tank is approximately                units is nitrogen oxides.
15,000 gallons.

4. Waste Storage Tank T-12: This tank
                                                    Trial Burn
stores liquid hazardous waste that is
                                                    To estimate actual emissions of constituents
processed in the MS HAF unit. The volume
                                                    of concern for input into a Health Risk
of the tank is approximately 3,750 gallons.
                                                    Assessment (HRA) and to establish
                                                    operating conditions for the HAF units, a
Both halogen acid furnaces produce
                                                    Trial Burn Plan was prepared in March
hydrochloric acid by thermal oxidation at
                                                    1999.      The plan was designed to
temperatures between 1,000 degrees
                                                    demonstrate that the HAF units meet
              °
Centigrade ( C) and 1,500 °C. The HAF
                                                    applicable air emission standards, and gather
units have destruction and removal                  actual    emissions    data    for    various
efficiencies (DREs) greater than 99.99%.            constituents of concern for input into the
This means that 99.99% of feed waste                HRA.
constituents are converted to hydrochloric
acid, water, and carbon dioxide.

                                                3
Trial burns were conducted between                   facility. A SWMU is any facility equipment
October 1999 and March 2000. The HAF                 that handled hazardous waste or hazardous
units were operated under three different            material that released or had the potential to
operating conditions and samples were                release     hazardous      constituents     to
collected for each condition. The trial burn         environmental media.
defined worst-case operating conditions for
the HAF units and demonstrated that the              Sitewide RCRA corrective action cleanup at
units can meet air emission standards for            the Dow Pittsburg facility is currently being
this wide range of operating conditions.             overseen by the San Francisco Regional
These operating conditions have been used            Water Quality Control Board.
to establish permit conditions in the draft
BIF permit.

Health Risk Assessment                               COMPLIANCE HISTORY

The Dow Chemical Company has prepared a              DTSC conducts periodic inspections of this
Health Risk Assessment (HRA) to support              facility. The last inspection was made in
the permit application and CEQA initial              April 2001. No violations were found.
study.      This HRA was prepared in
accordance with procedures approved by               California Environmental
DTSC. Emissions from the HAF units were              Quality Act (CEQA)
determined by the trial burn program. The
emissions calculated from trial burns were           DTSC has prepared an Initial Study in
entered into a DTSC/EPA approved health              accordance with the provisions of the
risk assessment model with specified                 California Environmental Quality Act. The
exposure assumptions to estimate potential           results of this Initial Study are that there are
risk to human receptors. The results of the          no significant adverse effects on human
HRA conclude that the estimated upper limit          health and the environment associated with
of additional cancer risk at the nearest             the operation of these furnaces. Therefore,
residences is approximately one in a million         DTSC has prepared a draft CEQA Negative
(1.43 × 10-6). The risk to an onsite worker is       Declaration.
less than the nearest resident due to the
reduced exposure time assumed in the HRA.
DTSC and USEPA consider this additional
level of risk to be insignificant.                   GLOSSARY

RCRA Corrective Action                               BIF: Boiler and Industrial Furnace:
Activities
                                                     Boiler: means an enclosed device using
In 1986, the United States EPA prepared a            controlled flame combustion that has
Resource Conservation and Recovery Act               physical provisions for recovering and
(RCRA) Facility Assessment (RFA) report              exporting thermal energy in the form of
that identified 25 Solid Waste Management            steam, heated fluids or heated gases.
Units (SWMUs) at the Dow Pittsburg

                                                 4
       Industrial Furnace: means any enclosed              Hydrochloric acid : A corrosive and fuming
       devices that are integral components of             liquid.
       manufacturing processes and use thermal
       treatment to accomplish recovery of                 Interim status: means the authorization
       materials or energy: cement kilns, halogen          granted by the Department or the USEPA
       acid furnaces, etc.                                 which allows a facility to continue to
                                                           operate pending review and decision of the
       CEQA: California Environmental Quality              facility's permit application.
       Act: A statute established in 1970 that
       requires state and local agencies to                Nitrogen oxides: This is a generic term used
       determine      if   there are    significant        to include all forms of oxides of this
       environmental impacts associated with their         compound (e.g., nitrous oxide, nitric oxide,
       actions, and to avoid or mitigate those             etc.).
       impacts, if feasible.
                                                           RCRA: The Resource Conservation and
       HAF: Halogen Acid Furnace: This is a                Recovery Act, an amendment to the Solid
       combustion unit that processes materials            Waste Disposal Act, enacted in 1976 by the
       containing fluorides, bromides, or chlorides        U.S. Congress to address the problems
       to produce acids such as hydrochloric acid.         associated with municipal and industrial
                                                           solid waste generated nationwide.



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Si prefiere hablar con alguien en español acerca de ésta información, favor de llamar a Jacinto Soto,
Departamento de Control de Substancias Tóxicas. El número de teléfono es (510) 540-3842.

For More Information
If you would like more information about the Site, please call Project Manager, Waqar Ahmad at
(510) 540-3932 or DTSC Public Participation Specialist, Jesus Cruz at (510) 540-3933.
Information Repositories
The permit application, draft permit, CEQA Initial Study, and the Negative Declaration are available for
public review at the following locations:

               Pittsburg Public Library                    Antioch Public Library
               80 Power Avenue                             501 West 18th Street
               Pittsburg, CA 94509                         Antioch, CA 94509
               Phone (925) 427-8390                        Phone (925) 757-9224

The full administrative record is available at:

               DTSC File Room
               700 Heinz Avenue
               Berkeley, CA 94710
               Phone (510) 540-3800
Notice to Hearing Impaired Individuals                 5
TDD users can obtain additional information about the Site by using the California State Relay Service
(1-888-877-5378) to reach Public Participation Specialist at (510) 540- 3933.
PPS - Jesus Cruz
Department of Toxic Substances Control
700 Heinz Avenue, Suite 200
Berkeley, California 94710-2721




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