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Memorandum Date: 6/21/04 To: David Littell, Deputy Commissioner, Department of Environmental Protection
From: Carla Hopkins RE: BRWM Compliance Briefing - Dragon Products Company OVERVIEW Dragon Products Company (Dragon) operates a cement manufacturing plant in Thomaston, Maine (Site). Cement production began at the plant in 1927. The cement manufacturing process (1) starts with raw ingredients that include limestone, sand and iron ore: The raw materials are crushed and mixed with water and the resulting raw feedstock is fed to the cement kiln where it is superheated to temperatures that exceed 2500 degrees Fahrenheit. The high temperatures recrystalize the raw feedstock into an interim product known as clinker. Clinker is then interground with gypsum to form cement. Heat within the kiln runs counter to the flow of the feedstock. Material blown back with the heat currents is captured in the kiln air pollution control device (kiln baghouse). This material is known as cement kiln dust (CKD). Previously, clinker that did not meet strict quality control specifications (such as strength, color and chemical composition) was removed from the process and stockpiled. This material is known as "waste clinker'. Prior to 1996, all CKD captured in the kiln baghouse was removed from the process and stockpiled. WASTE CLINKER DISPOSAL STORAGE AREA The waste clinker stockpile is located on the east side of the Site and is approximately 12 acres in size. According to information supplied by Dragon, the area was used as a disposal site as early as 1927 when the first cement plant was constructed at the Site. Dragon estimates that approximately 3000 to 5000 tons of waste clinker material and 3000 to 5000 tons of waste cement, refractory and coating material, limestone and rock, and coal was disposed in the area. A lagoon system on the southern side of the stockpile collects leachate from the stockpile and conveys (Footnote 1 : Please keep in mind that the cement manufacturing process at Dragon has or will in the near future change with the upgrade of the plant to a "dry' process. I am not familiar with this new process at this time.) Page 1 of 4 ================================== it via pumps and a piping system to Quarry #4 (see attached map). According to Dragon, no new waste has been disposed in this area for at least five years and will not be used in the future for disposal. CKD DISPOSAL/STORAGE AREA The CKD stockpile is approximately 15 acres in size and contains an estimated 845,000 tons of material. Prior to 1969, Dragon discharged CKD directly to the atmosphere. In 1969 and 1970, the facility installed a fabric filtration system for capturing airborne CKD. With the collection of CKD in the early 1970s, the facility began stockpiling CKD on the western portion of the Site, in and adjacent to Quarry #4. In 1997, Dragon installed a dust scoop system to recycle material captured in the dust collection system back into the kiln. The dust scoops have significantly reduced the amount of CKD that is stockpiled. Additionally, Dragon has pursued options to beneficially reuse CKD and currently they are not increasing the amount of CKD stockpiled at the site. Leachate from the CKD stockpile is collected in Quarry #4. Quarry #4 also receives the leachate from the waste clinker stockpile and also facility wastewater. Quarry #4 "water", including the leachate from the waste clinker and CKD stockpiles and facility wastewater, is then pumped back to the facility mill as process water. WATER QUALITY MONITORING RESULTS Dragon has been monitoring the groundwater and surface water in proximity to the two stockpile areas since 1990. Based upon review by Richard Heath, Project Geologist, of data through 2003 several conclusions can be made. 1. Monitoring well B2, which is associated with the CKD stockpile has shown statistically significant increases in inorganic parameters including specific conductance (SpC), total dissolved solids (TDS), calcium (Ca) and sodium (Na). It also appears that sulfate (S04) is increasing at this monitoring well. This is especially significant because S04 is the predominant ion associated with CKD leachate (DQ1). Parameter concentrations at the remaining B-series monitoring wells appear slightly to moderately elevated. 2. The C-series monitoring wells, which are associated with the waste clinker stockpile appear to be slightly to moderately elevated for several parameters including those mentioned above. 3. The leachate monitoring points DQ1 (CKD) and CD1 (waste clinker) show a pH value routinely above 12 standard pH units and have on several occasions exceeded the defined hazardous characteristic of 12.5 standard pH units. 4. Surface water monitoring points SP1 and UNS1 appear to be moderately to strongly impacted. It is possible that this impact is due to airborne dust at the facility. Page 2 of 4 ================================================ 5. Richard Heath is recommending that Dragon be required to investigate the cause of the impact to monitoring well B2 since it is significantly impacted and continues to degrade. 06-096 CMR 405.2.C(2)(i) and (j) requires Dragon to evaluate the cause of the deterioration within 30 days of receipt of laboratory results and then submit a report of the evaluation to the Department within 90 days of the date the evaluation is initiated. Within 90 days of the date of the report, Dragon would be required to initiate assessment monitoring if the Department does not concur that a source other than the solid waste facility is the likely source of the deterioration. I concur with this recommendation since it is clear that the water quality at the Site continues to degrade. PENDING SPECIAL WASTE LANDFILL LICENSE APPLICATIONS In 1992, Dragon submitted two special waste landfill license applications (#S- 020777-WD-A-R and #S-020778-WD-A-R). These applications were accepted for processing on February 4, 1992 and would be subject to the standards the Solid Waste Management Regulations effective May 4, 1989. However, 38 M.R.S.A § 1308 states, in relevant part, "Rules and regulations adopted pursuant to this chapter concerning the location, establishment and construction of solid waste disposal facilities, but not concerning alteration or operation, shall not affect such facilities in existence prior to October 3, 1973." Therefore, these two disposal facilities are not subject to the siting requirements of the 1989 Rules. Since 1992, the Department has had many discussions and meetings regarding the complexity of the issues involved and the appropriate regulatory approach for this Site. Dragon has recently upgraded its facility. Based on conversations with Ann Thayer, Dragon's Environmental Manager, it is Dragon's intent to reincorporate waste clinker and CKD back into the cement manufacturing process. If this turns out to be the case, the CKD stockpile area will more appropriately be licensed as a storage facility. If is Dragon's intention to remove waste clinker from the stockpile area and permanently discontinue use of this area for disposal of waste clinker. - Therefore, the Department believes that addressing this issue in a Schedule of Compliance would be more appropriate that requiring Dragon to get a solid waste storage license. A draft Schedule of Compliance is currently being reviewed for this facility. SCHEDULE OF COMPLIANCE Based on the water quality monitoring information, it is clear that the Department could not issue Dragon any type of license at this time. Therefore, a Schedule of Compliance (SOC) has been drafted and is currently being reviewed by James Glasgow and Paula Clark of the Division of Solid Waste Management. The SOC was drafted with much input from Ann Thayer, Dragon's Environmental Manager. The SOC, as it currently reads, would require among other things, that Dragon continue and improve its current groundwater monitoring program. Additionally, the Department would likely address the fact that the CKD stockpile area would be better regulated as storage facility rather than a landfill since it is Dragon's intention to reuse Page 3 of 4 ============================================== the CKD in their new process. In addition; the SOC would address the re- incorporation of the waste clinker back into the process and the discontinuation of this area for disposal. The SOC may also address the need for closure of the waste clinker area once all reusable waste clinker material has been removed since other wastes were disposed in this area. At the end of the term of the SOC, it is the Department's hope that Dragon will withdraw its two special waste landfill license applications, which up to this point they have been unwilling to do, and apply for a solid waste storage license for the CKD stockpile. BENEFICIAL USE LICENSES Dragon holds several beneficial use licenses, which are summarized on the following pages. Dragon is in substantial compliance with respect to these licenses. Encl:
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