ATTACHMENT D

MULTIPLE HEARTH INCINERATOR - HWMU-32

ENGINEERING DESCRIPTION OF THE MULTIPLE HEARTH INCINERATION SYSTEM

RED ROCHESTER, LLC EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

TABLE OF CONTENTS

Multiple Hearth Incinerator

Figure D2 – Building 95 Multiple Hearth Incinerator

Figure D16 – Multiple Hearth Incinerator Waste Sludge Feed and Ash Management System

Appendices:

Appendix D-5 – SCC Burner Information

Appendix D-6 – SCC Combustion Air Fan Curve

Appendix D-7 – ID Fan (System) Performance Curve

Appendix D-8 – Weigh Conveyor Vendor Diagrams

HWMU-32 Drawings List

Trial Burn / Comprehensive Performance Test

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D1 MULTIIPLE HEARTH INCINERATOR (MHI)

The MHI, serial no. 74445, was manufactured by Envirotech System, Inc. The MHI as shown in Figure D-2 is an eight hearth (0 to 7) unit. The zero hearth, located at the top of the unit serves as a flue gas pretreatment device. The sludge is fed to the #1 hearth by a screw conveyer system. Drying of the feed occurs on hearths #1 and #2. Burning or combustion of the feed takes place on hearth levels #3, #4, and #5. Ash cools down on levels 6 and 7 and is discharged at the bottom of the unit. The waste feed proceeds from one hearth level down to the next and, the feed is distributed across each hearth with a rotating rabble arm. The calculated residence time is approximately two hours (15-20 minutes in each hearth) for the waste feed inside the hearth, before it is "ashed" out in the bottom. Natural gas is used as needed as auxiliary fuel to support the combustion temperatures inside the hearth for the 2-hour duration. Depending on which hearth level the arm is located, the blades are pitched inward or outward to promote gradual waste feed movement to the center or outside wall of the MHI. Also, the arm serves to break up the Waste feed allowing uniform heat distribution through the waste feed layer.

Non-contact cooling air is introduced at the bottom of the unit and flows through the center of the rotating hollow shaft and may either be discharged fully to atmosphere or partially returned to the #6 hearth to provide air below the burning zone. Combustion / flue gases exit from the top of the zero hearth and are sent to the SCC for further destruction of organics and hydrocarbons.

Table D-5 provides the construction details of the MHI. The specifications of the burners are listed in Table D-6.

SECONDARY COMBUSTION CHAMBER (SCC)

Organics present in the flue gases exiting from the MHI are destroyed in the SCC. The SCC operates at temperatures and residence times sufficient to meet regulatory requirements for Destruction and Removal Efficiency (DRE) for organic compounds in the waste feed. The actual temperatures that will determine operating conditions were and will again be demonstrated during Comprehensive Performance Tests that are required every 5 years. As previously mentioned, no wastes are fed directly to the SCC.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D2 The SCC specifications are listed in Table D.7, Burner specifications are given in Table D-8. Drawings 095XX-312-017-Sheet 11 (SCC general arrangement) and E095XX-310-025 (process flow diagram) indicate the dimensions used in calculating residence time.

Waste Feeds to MHI

Sludge is pumped from one of-the four holding tanks. There are three (3) 50,000 gallon and one (1) 100,000 gallon holding tanks. Sludge is pumped from a holding tank to the dewatering equipment (centrifuge) for dewatering. The dewatered sludge is dropped from the centrifuge into the sludge storage bunker by gravity. A bunker conveyor moves the sludge to the horizontal portion of the elevating conveyor. Grit conveyed with a grit conveyor can be added to the sludge on the elevating conveyor. The elevating conveyor lifts the sludge and grit and drops it from a horizontal section into a screw auger, which feeds the sludge into the #1 hearth.

RED has a waste feed measurement system. Drawings of this belt weigh scale system, are attached in Appendix D-8. As shown on the waste feed and ash handling system schematic (Figure D- 16), it is located at the end of the drag conveyor and before the drop chute to the screw conveyor. When the sludge weigh conveyor is out of service the incinerator is not operated.

Combustion Air and Fuel to MHI

Approximately 10,000 scfm of combustion air is provided to the MHI by a 100 horsepower (hp) fan. Additional combustion air is provided by a second blower with a rating of 2500 scfm at 7" static pressure and 5 hp.

Commercially available natural gas is fed to the MHI at the rate of up to about 12,400 cfh at 3.5 psig. MHI burner specifications are given in Table D-6. A maximum heat load of about 48 MMBTU/HR is available at the MHI. In the event of an automatic waste feed cutoff, natural gas will continue to be used to support the combustion temperature inside the hearth and the secondary combustion chamber at the permit limit for a duration of 2.25 hours to ensure that the sludge remaining in the hearth is burned out.

Drawing E095XX-770-003 shows combustion air and natural gas flows to the MHI. The drawing also provides details of MHI instrumentation.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D3 Auxiliary Fuel and Air to SCC

The SCC burner combustion air is provided from a blower. The SCC burner and blower specifications are listed in Table D-8. Natural gas is fed to the SCC through a burner rated at approximately 22 MM Btu/hr. The available maximum heating load to the MHI and SCC combined is about 70 MMBTU/HR.

Auxiliary Waste Feed to SCC

No wastes are fed to the SCC. The feeds to the SCC consist of the exhaust gases, from the MHI, natural gas and- auxiliary combustion air provided by a blower as referenced in Table D-8.

FEED LOCATIONS

Table D-1 identifies the various feeds and where they are introduced to the system. Generally combustion is accomplished by the heating value of the waste feed. Auxiliary natural gas is fed to the MHI as needed. In the SCC, natural gas is used to elevate the temperature of the MHI flue gases in order to complete destruction of organics.

AUTOMATIC WASTE FEED CUTOFF SYSTEMS (AWFCO)

Parameters which will cause an automatic waste feed cutoff are listed in Table E-4 of Exhibit E in Module I Schedule I. Automatic cutoffs for waste feed are accomplished by turning off the power to the waste feed conveyor. A distributed control system (DCS), known as the MOD 300, located and operated from the control room by trained operators, provides the appropriate alarm that a waste feed cutoff has occurred and indicates the cause for the cutoff.

SHUTDOWN PROCEDURES

Shutdown definitions and parameters for the MHI and SCC are listed in Table D-10. The induced draft fan will be shut off, and emergency natural draft by-pass stack on the SCC will be opened if conditions trigger an emergency shutdown. This stack is sufficiently tall to vent and disperse MHI gases directly into the atmosphere. This will prevent fugitive emissions from escaping either into the building or at ground level.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D4

AIR POLLUTION CONTROL EQUIPMENT (APCE)

Flue gases leaving the SCC enter the APCE where particulates, metals and acid gases are removed in staged equipment consisting of: a quench chamber, a packed bed condenser/scrubber, an entrainment separator, a variable throat venturi, and a WESP. Planned APCE setpoints -for these devices during normal operations are summarized in Table D-11. The various emission control processes of the APCE are described in the following sections. The hot flue gases from the SCC are first quenched to adiabatic saturation temperature in the quench. Quench water will be once through and comes from the secondary treatment effluent. The quench water will be continuously discharged from the quench bottoms sump and returned to the wastewater treatment plant to prevent build-up of suspended and dissolved solids.

The Condenser, using once through secondary treatment effluent water, is a counter current flow packed scrubber equipped with a structured packing that resists build up and plugging. As gases pass through the packed section, they will be sub-cooled and water vapor condensed. In the condensation process, fine particles are formed which further act as nuclei to promote the growth of larger particles which are more easily collected downstream by the Venturi Scrubber. The cooled gases exit the Condenser through a mist eliminator and enter the Venturi Scrubber.

The Venturi is an inertial impaction device where the gases containing particles are accelerated into the high velocity 'throat' area. At the throat, water injected from above is sheared into millions of droplets, which collide and encapsulate the gas particles. Particle collection efficiency is directly related or proportional to the pressure drop across the throat; it is inversely proportional to the size of the particle contained in the gas stream. As the gas flow varies through the scrubber, a damper in the throat can be manually or automatically modulated to maintain a constant pressure drop. The venturi differential is calculated by the MOD300 control system, once every second, by subtracting the inlet pressure (PT 1097) from the outlet pressure (PT 1091). The scrubber water is supplied by effluent (STE) recycled from the venturi and the entrainment separator.

The gases and droplets containing particles exit the Venturi and enter into the Entrainment Separator where water droplets are separated from-the gas stream and more secondary treatment effluent water is used to clean the separator. Liquid that drains into the sump below is recycled back to the Venturi. The pH of the recycled liquid is monitored and remaining acid gases are neutralized. Suspended and dissolved solids build-up is controlled by a continuous blowdown loop.

Drawings 095XX-312-018-Sheet 3 and 095XX-312-018-Sheet 4 respectively, show the plan and elevation arrangements for the quench, condenser, venturi, and entrainment separator.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D5 The gas stream from the Entrainment Separator is next passed through a wet electrostatic precipitator (WESP). The WESP is a final 'polishing' device that removes submicron particulate matter not captured by the venturi. The gas will flow into the region between discharge and collecting electrodes. The particles are charged by high intensity corona. The charged particles will then be driven electrostatically to the grounded collecting electrodes. The collecting tubes of the WESP are periodically flushed with water to remove collected matter. The WESP drains, other APCE drains, and any equipment overflows, drain into an existing sump from which they are pumped back into the wastewater treatment plant for treatment. Drawing V095XX-312-018- Sheet 19 contains the process and instrumentation details for the WESP.

The treated gas exits from the WESP through an ID fan through a silencer in the discharge duct, and is dispersed to the atmosphere by a stack. The venturi is automatically adjusted to control the MHI draft. In addition, the draft can be controlled by changing the fan speed-by the use-of a variable frequency drive (VFD). Specifications for the ID fan, motor and the VFD are shown in Table D-12.

A plume suppression burner reheat stack gases to approximately 175 deg F in order to create adequate gas exit velocity for dispersion. Reheating also minimizes plume formation. A differential pressure element mounted in the stack (described in Table D-36) measures exhaust gas flow. Details of the stack and plume suppression system are provided in Table D-13. Sampling ports are installed in the exhaust stack at rooftop and sub-roof levels and are shown in

Drawing E095XX-319-014. A complete process flow diagram is shown in Drawing E095XX-310-025.

FUGITIVE EMISSION CONTROL

Fugitive emissions to the atmosphere are unlikely during normal operation considering the negative draft maintained throughout the MHIS. An alarm for positive MHI pressure warns the operator in the control room if the process or system momentarily pressurizes. In the event of the loss of negative draft, waste feed will be automatically cutoff.

All equipment access doors, inspection openings, and the ductwork leading to the stack following the discharge of the ID fan are sealed with bolted flanges or otherwise secured.

ASH DISCHARGE Ash is discharged from the #7 hearth through a chute that feeds a crusher. From the crusher, the ash enters an- eductor and is pneumatically conveyed to an ash bin located on the fourth floor of the building. There are two sets of crashers/eductors; typically the ash is-conveyed through one crusher/eductor while the other serves as a backup. There are level indicators on the ash bin that go to the MOD300 to allow timely transfer of the ash to an enclosed transfer trailer outside the building. Ash is transferred automatically when the bin level reaches 50%. There is an ash bin high-level alarm that shuts down the MHI and feed system. Also, the transfer trailer is equipped with a level indicator. The transfer trailer is later emptied into an over-the-road trailer for shipment to a smelter for precious metals reclamation.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D6

TABLE D-1 INCINERATOR FEED LOCATIONS

Feed Stream Inputs to MHI Inputs to SCC

Sludge 1 None

Grit 1 None

Natural Gas 1(a) 1 (b)

(a) Natural gas is supplied to (10) burners inside the MHI; combustion air is available at each burner, supplied by a blower.

(b) Natural gas is supplied to one burner; combustion air is supplied to the

burner by a blower.

TABLE D-2 FEED SYSTEM DESIGN SPECIFICATIONS

Feed Type Feed System Type Capacity Delivery to MHI Material of Construction Conveyor N A NA NA Carbon Steel Carbon Steel Sludge Bunker NA Grit Tank Conveyor

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D7 TABLE D-6 MHI BURNERS SPECIFICATIONS

A total of ten (10) North American gas barriers are located inside the MHI. Fig D-2 shows the location of each burner. The table below lists the burner location, number, dimensions and heat duty.

Number North American Max.duty (MM Btu/hr) Dimensions/ Location Inside the MHI Series each Flame length Two 6422 3.2 8" x 8.2' Zero Hearth

Hearths #1 and #2 Two (2) 6422 3.2 , 8" x 8.2' (Drying Zone)

Hearths #3 and #4 Two (2) 6422 3.2 8" x 8.2' (Combustion Zone) Four Hearths #5, #6, 6422 3.2 8" x 12' (4) (Burnout Zone) Note: Burner dimensions refer to entry diameters; flame lengths will vary .depending on operating conditions.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D8 TABLE D-7 SCC SPECIFICATIONS

The SCC is a top fired downflow unit. Flue gases from the MHI enter the SCC at the top through a tangential entry approximately 6' in diameter and discharge through an outlet approximately 7'6" in diameter, located near the bottom of the unit. The unit is fitted with welded cone bottom with a 60 degree slope for ash collection and removal.

Height 37' (non-dnal)

Shell 0.D. 12' (nominal)

Shell I.D. 101-10" (nominal) Material of 3/8" thick rolled cold steel welded construction, finished with a Carboline construction Carbo Zinc 11 primer and Carboline 1248 aluminum finish high temperature paint

Refractory The SCC is lined with approximately 7" of refractory; (approximately 41/2" of KALA Refractory brick and 21/2" of KALA insulating brick manufactured by Harbison Walker)

Weight 170,000 pounds (62,000 pounds shell and 108,000 pounds refractory Drawing V095XX -312-017, Sheet 11 shows SCC arrangement with relief stack.

Emergency Relief Stack:

A refractory lined vertical stack with a refractory lined lid is installed on top of the SCC and held in normally closed position by a pneumatically operated cylinder. Stack – 1/2" carbon steel, 6' 0.D. x 5' high, rolled and welded

Lid – 1/2" carbon steel, 6.5' O.D. x 4' deep

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D9 TABLE D-8 SCC BURNER AND BLOWER SPECIFICATIONS

Burner: A North American 'Magna Flame Lo-Nox' burner is located in the SCC tangentially to the entering gas stream. The burner is rated approximately at 22 MMBtu/hr (model #4796-14), at 3-5 psig gas supply pressure to inlet of piping, and 8 psig air pressure from the combustion air blower. The burner is furnished with a pre-piped and pre- wired fuel train, approximately 10’ long x 4' wide x 7' high. The-fuel train is located inside Building 95. Manufacturer's bulletin # 4796 is included as Appendix D-5

Combustion Air Blower:

Manufacturer Chicago Blower Co., Type DI 6LS, Size 15

Size 5100 acfm at 23"wc and 70 deg F.

Motor Nominal 25 hp; 230-460/3/60, TEC

Appendix D-6 shows the fan performance curve.

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D10 Table D-10 Shutdown Definition and Parameters for the MHI and the SCC SHUTDOWN PARAMETERS SHUTDOVVN ACTIONS

1. Instrument air pressure < 25 psig 1. Stop all waste feed and fuel to the for 30 sec or MHI and SCC. 2. SCC Emergency Cap open. 2.. Maintain all water flows to the APCE. 3. ID fan loss due to loss of electric 1. Stop all waste feed and fuel to the power or MHI and SCC. 4. Quench exhaust gas > 270 F for 30 2. Shutdown ID fan. sec or 3. Open SCC emergency cap. 5. Hearth draft positive for 30 sec 4. Maintain all water flows to the APCE.

TABLE D-11 APCE SPECIFICATIONS

1. Quench

Dimensions 7’ OD, 14’ High

Material of #11 gauge Hastelloy C-276

Min 50 GPM by four (4) full cone spray, TF24CY by Bete Primary (up) Nozzles

Secondary Nozzles Min. 100 GPM by four (4) full cone spray, TF-32C by Bete

Maximum Temperature 1800 F

270 F Quench Gas Exit Temperature

Reference Drawing No. E095XX-770-005B:

2. Condenser (packed bed)

Dimensions' 10' dia x 24' High Material of #1l Gauge Hastelloy C-276

Packing Depth 8"

Packing Material Mufflers PPLMGC 45 Pack

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D11 Flow 1000 GPM through seven (7) teflon Bete TF-72FC full cone spray nozzles 6'' depth of materials as in Mist Eliminator packing Depth

Mist Eliminator Flow Periodic flow through seven (7) Bete TF-20FC nozzles

Reference Drawing No. E095XX-770-005B:

TABLE D-11 APCE SPECIFICATIONS 3. Venturi Scrubber:

Height 10.5'(excluding support legs)

Diameter 3' . . . Material of Construction 3/16" thick plate Hastelloy C276

Flow The scrubber is equipped with 2 Bete Teflon spray nozzles, TF4$FC, one placed above the other concentrically above the throat of the venturi. A minimum of 80 GPM is pumped through each nozzle Reference Drawing No. E095XX-770-006

4.Separator:

Height 23'

Diameter 9'

Material of Construction 3/16" thick AL6XN alloy

Mist Eliminating Section Consists of 6 Munters T-271 polypropylene chevron style panels are 36 inch x 24 inch in plan, located in the top of

Mist Eliminator Wash Intermittent washdown spray header with 4 Bete Teflon TF24FC spray nozzles providing up to 80 GPM

Reference Drawing No E095XX-770-006

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D12

TABLE D-11 APCE SPECIFICATIONS

5. Wet Electrostatic Precipitator

Height 35' - 3" (including support legs)

Diameter 10'

Material of Construction 3161 Stainless Steel, Inlet and outlet sections of the WESP are 1/4" thick and the hexagonal tube bundle (collector tubes) are 18 gage if internal and 3/16" thick if on the exterior periphery and exposed atmospheric temperature

Collector Assembly The collector surface consist of (85) 13 ft long hex tubes in a bundle with concentric charge discharge electrode masts (one per tube). The masts are suspended by a high voltage grid that has mast alignment mechanisms to maintain concentricity and prevent arcing. • . Purge Air Heaters Four (4) total and two (2) per each insulator compartment are maintained at 150 F. Purge air is blown through the heaters by either the ID fan or by two (2) separate air blowers to prevent moist process gas from condensing out on the high voltage surfaces and dropping DC voltage

Power Supply to Grid and Masts Full-wave rectified DC power to 65 KV voltage, 300 made continuous current produced by silicon-controlled transformer rectifier. Input primary power is 480 V single-phase 58 AMP DC current

Preconditioning In the inlet duct to the WESP produces an inlet fog using 80 PSIG Atomized Water compressed air and 0.5 GPM of water running continuously. A nozzles Spray "spider" consisting of 5 Sonic SESNZ-ST47A00 nozzles combines the compressed air and water.

Intermittent Spray 1to 2 minutes duration approximately 2-3 times per day irrigates the Washdown tube bundle using 8 Bete NCM0707W nozzles, material CPVC, 3/4" NPT connections, for cleaning purposes

Reference Drawing No. V095XX-312-018, Sheet 19

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D13

TABLE D-12 ID FAN AND MOTOR SPECIFICATIONS

ID FAN:

Manufacturer Robinson Industries

RPM 1,750

BHP 279 . Design Maximum 20,500 ACFM at - 60" H2O system pressure Air Flow .

Material of Construction 316 SS inlet and discharge housings; fan wheel, hub and shaft sleeve made of Hastelloy C-276

Reference Drawing No. V095XX-312-019, Sheet 2

Appendix D-7 shows the fan curve for static pressure and acfm relationship.

MOTOR:

Manufacturer Reliance Electric Co.

Size Three Phase, 60 Hertz, 460 volts, 300hp, 1800 RPM

Motor Speed Adjustable by a separate variable frequency (VFD)

VFD: The function of the VHD is to adjust the fan motor speed depending on load conditions. If the drive fails, the motor will be automatically directed to full speed.

Manufacturer Reliance Electric Co.

Size 350 hp, 480 volts, 60 Hz, output rating of 420 amps

Enclosure NEMA I, force ventilated

TABLE D-13 STACK AND PLUME ABATEMENT SYSTEM

Stack The cleaned gases exiting from the WESP are exhausted by the ID Fan through a duct

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D14 system and a stack into the atmosphere.

Material of Construction 316 SS, flanged. and welded sections

Diameter 42" ID

Height Approx. 70' from the roof level, gas discharges at 191' from the base of the terrain Ports 4

Continuous Emission Monitoring Located above sampling ports System (CEM)

Reference Drawing No. E095XX-319-014

Plume Abatement System

The plume abatement system consists of a natural gas fired burner Ideated concentrically at the bottom of the APCE discharge stack. The system includes a combustion air blower, pre- piped natural gas train and a spark ignition burner

Blower: North American Model 2408-F-TIOD direct drive unit with inlet filter. The blower is rated at 115,000 SCFH at 8 osig. The a 10 hp unit wired at 460 volts, 3 phase, 60 Hz.

Burner:

The natural gas train and the burner.(North American Model 4570-12) consist of Factory Mutual approved and UL listed components and are designed to produce 7 MMBTU/Hr with natural gas-input at 5 psi. At high fire, the burner flame is approximately 2' wide and 6' long. The plume abatement burner usually runs at low fire approximately 8 months of the year and operates between 10 and 25.% the other four months of the year. Gas flow rates shown below are varying slightly to maintain the proper stack exit temperature. The flow rates shown are based on a pitot tube measurements at the 3 damper positions.

Low Fire 10% 25% Air Damper Opening Air Damper Opening Air 185 240 370 (scfm)

Gas 6.8 13.7 22.4 (scfm)

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D15 TABLE D-50 MHI SYSTEM TEMPERATURE MEASUREMENT

Process Device Description Instrument tag No. Drawing No. Range Accuracy Parameter * % of reading

#3 Hearth Thermocouples, TYPE K TE 943S, TE 943N E095XX-770-003K 0-2000 F + / - 0.75 % *

#4 Hearth Thermocouples, TYPE K TE 944S, TE 944N E095XX-770-003K 0-2000 F + / - 0.75 % *

# 6 Hearth Thermocouples, TYPE K TE 946S, TE 946N E095XX-770-003K 0-2000 F + / - 0.75 % *

#0 Hearth Thermocouples, TYPE K TE 940A. TE 940B E095XX-770-003K 0-2000 F + / - 0.75 % *

SCC Outlet Thermocouples, TYPE K TE 1021A,B E095XX-770-004F 0-2000 F + / - 0.75 % *

Quench Exit Resistance Thermal Device TE 1055A,B E095XX-770-005G 0-500 F + / - 0.62 % *

ID Fan inlet Resistance Thermal Device TE 1103 E095XX-770-006H 0-500 F + / - 0.62 % *

Stack Gas Thermocouples, TYPE K TE 910 E095XX-770-007H 0-2000 F + / - 0.75 % *

D16 TABLE D-51 MHI FLOW MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

Natural gas to MHI (all burners) TEMP Differential flow meter FE 920 E095XX-770-003K 0-25000 SCFH +/- 1 % FS **

Natural gas to SCC burner TEMP Differential flow meter FE 1008 E095XX-770-004F 0-30000 SCFH +/- 1 % FS **

Quench Lower Sprays Vortex flow meter FE 1053 E095XX-770-005G 0-300 GPM +/- 0.8 %*

Condenser (once through) water Vortex flow meter FE 1076 E095XX-770-005G 0-2000 GPM +/- 0.8 %*

Venturi blowdown Vortex flow meter FE 1096 E095XX-770-006H 0-75 GPM +/- 0.8 %*

Venturi approach Vortex flow meter FE 1093 E095XX-770-006H 0-150 GPM +/- 0.8 %*

Venturi Throat Vortex flow meter FE 1092 E095XX-770-006H 0-150 GPM +/- 0.8 %*

Stack Flow, DP flowmeter Anubar, pitot tube FE1147 E095XX-770-007H 0-25000 SCFM +/- 3 % FS **

* % of reading ** Full Scale

D17 TABLE D-52 MHI PRESSURE MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

MHI combustion air Pressure Switch Low PSL 969 E095XX-770-003K ON/OFF, SP=26" wc decr*

MHI natural gas Pressure Switch High PSH 353-1, V095NA-312-002 ON/OFF, SP=6.7 psig rising Pressure Switch Low PSL 352-1 (SH. 66) ON/OFF, SP=2 psig decr*

SCC combustion air Pressure Switch Low PSL 1014 E095XX-770-004F ON/OFF, SP=20 wc decr* Pressure Switch Low PSL1005 ON/OFF, SP=12 OSI* decr* SCC natural gas Pressure Switch High PSH1007 E095XX-770-004F ON/OFF, SP=4 psig rising PT 968 A Offgas From Hearth Pressure transducers PT 968 B E095XX-770-004F -1" TO +1"wc +/-0.25% FS* PT1091 Venturi differential Pressure transducers PT 1097 E095XX-770-006H -90" TO +10"wc +/-0.25% FS*

Condenser pressure drop Pressure transducers PT 1073 E095XX-770-005G PT 1097 E095XX-770-006H 30" TO +10"wc +/-0.25% FS*

ID fan outlet Gauge (local) PI 1133 E095XX-770-007H 0" TO +10"wc +/-2% FS*

*decr: decreasing, osi: ounces per square inch, FS: Full Scale

TABLE D-53 MHI PROCESS MEASUREMENT

Process Parameter Device Description Instrument Tag No. Drawing No. Range Accuracy

Venturi blowdown pH pH meter AE 1094 E095XX-770-006H 0-14 pH +/-0.03 pH

Oxygen Level O2 sensor AE 990 E095XX-770-003J 0-25% O2 +/-0.5 O2 0-200 PPM & +/-10% or 10 ppm Carbon monoxide level CO sensor AE 1146 E095XX-770-007H 0-3000 PPM of PTM

D18 D19 D20 D21 D22 D23 D24 D25 D26 D27 D28 D29

ATTACHMENT D – DRAWING LIST

HWMU‐32 B‐95 MHI Drawing List Title Drawing# Multiple Hearth Incinerator Instrument E095XX-770-003 Controls Secondary Combustion Chamber Instrument E095XX-770-004 Controls Quench/Condenser Instrumentation E095XX-770-005 Venturi/Separator/WESP Instrumentation E095XX-770-006

Stack & Plume Instrumentation E095XX-770-007 Hearth Burner Controls E095XX-770-008 SCC General Arrangement V095XX-312-017, sheet #11

Process Flow Diagram E095XX-310-025 I.D. Fan/Duct/Stack Fabrication Details E095XX-319-014 Plan Arrangement of Incinerator Off Gas V095XX-312-018, sheet #3 Condensing Scrubbing System

Elevation Arrangement of Incinerator Off Gas V095XX-312-018, sheet #4 Condensing Scrubbing System WESP Process and Instrumentation Details V095XX-312-018, sheet #19 Induced Draft Fan V095XX-312-019, sheet #2 General system Overview 095XX-776-000, sheet 2 General system Overview 095XX-776-000, sheet 3 Rabble Teeth Assembly for MHI D095NA-313-003

(DRAWINGS IN ATTACHMENT J)

D30

ATTACHMENT D

MULTIPLE HEARTH INCINERATOR - HWMU-32

TRIAL BURN/COMPREHENSIVE PERFORMANCE TEST

RED ROCHESTER, LLC EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

These are separate submissions and are incorporated by reference:

Refer to the Test Reports for HWMU-32

Trial Burn Test Report dated March 2002

Miniburn #7 Test Report dated November 2002

Comprehensive Performance Test Report dated October 2008

and

Comprehensive Performance Test Report dated September 2013

Part 373 Permit Attachment D Submitted to NYSDEC — December 9, 2013 D31

ATTACHMENT D-2

PROCESS INFORMATION TANKS - HWMU-33

EASTMAN KODAK COMPANY EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

December 13, 2013

D2-1 TABLE OF CONTENTS ATTACHMENT D-2 TANKS

D-2 HWMU-33 TANK STORAGE 2 D-2b DESIGN OF NEW TANK SYSTEM 2 D-2b(1) GENERAL INFORMATION 2 D-2b(2) TANK DESIGN SPECIFICATIONS 3 D-2b(3) ANCILLARY EQUIPMENT DESIGN 4 SPECIFICATIONS D-2b(4) OVERFILL PROTECTION 4 D-2b(5) FOUNDATIONS AND ANCHORING 6 D-2b(6) CORROSION PROTECTION 6 D-2b(7) TANK SYSTEM INTEGRITY INSPECTIONS 7 D-2c INSTALLATION OF NEW TANK SYSTEM 7 D-2c(1) STORAGE TANKS 7 D-2c(2) ANCILLARY EQUIPMENT 7 D-2d SECONDARY CONTAINMENT FOR TANK 7 SYSTEM D-2e GENERAL TANK OPERATING REQUIREMENTS 8 D-2e(1) OPERATION OF FLOW CONTROL SYSTEM 8 D-2e(2) LOADING AND UNLOADING PRACTICES 8 D-2f REQUIREMENTS FOR IGNITABLE AND 8 REACTIVE WASTES D-2g REQUIREMENTS FOR INCOMPATIBLE WASTES 9 D-2h TANK INSPECTIONS 10 D-2h(1) DAILY INSPECTIONS 10 D-2h(2) TANK INTEGRITY ASSESSMENT SCHEDULE 10 D-2i TANKS SPILLS AND LEAKAGE 11 D-2j CLOSURE AND POST CLOSURE 12 D-2k Air Emission Standards 12 APPENDICES DRAWING LIST

- 1 - December 13, 2013 D2-2 D-2 TANKS D-2 HWMU-33 TANK STORAGE D-2b DESIGN OF NEW TANK SYSTEM D-2b(1) GENERAL INFORMATION

Hazardous Waste Management Unit 33 (HWMU-33) consists of two horizontal underground storage tanks located in two separate tank farm areas at the Building 322 distillation complex. . One 30,000 gallon tank is located in the tank farm near the southeast corner of Building 322. One 35,000 gallon tank is located in a tank farm south of Building 322. These tanks were installed as part of Kodak’s Storage Tank Improvement Program with oversight from the New York State Department of Environmental Conservation (NYSDEC). The tanks are used for the storage of waste solvents prior to reclamation. These solvents come from on-site manufacturing operations as well as off-site hazardous waste generators. The U.S. Environmental Protection Agency (U.S. EPA) waste codes, identifying these wastes, are listed in Module IV of this permit.

The 30,000 gallon horizontal tank, Tank EPV-163 (Division I.D. No. T-682) is buried in washed stone. The location of the tank is shown on Drawing E322-201-001. Tank 682 is secured to a concrete hold down slab designed to drain to avoid standing water on the tank exterior for extended periods of time.

The 35,000 gallon horizontal tank, Tank EPV-160 (Division I.D. No. T-675), is also buried in washed stone. The location of the tank is shown on Drawing E322-201-001. Tank 675 is also secured to a concrete hold down slab designed to drain to avoid standing water on the tank exterior for extended periods of time.

Tank integrity assessments were prepared and certified by an independent, qualified, registered, professional engineer in January, 2009 in accordance with New York Codes, Rules, and Regulations (6NYCRR) Part 373-2.10(b). A copy of the integrity assessment certifications for the tanks is included in Appendix.D-2-1.

- 2 - December 13, 2013 D2-3

Tank System Service Process flow/piping and instrumentation diagrams for T-682 and T-675 are shown on the drawings listed below:

Drawing No. Title D322TF-700-682 Tank 682 Syn. Chem. Crude HW P&ID D322TF-700-675 Tank 675 Crude EA HW P&ID

These tanks are used for the storage of on-site and off-site waste solvents prior to recovery.

D-2b(2) TANK DESIGN SPECIFICATIONS

T-682 is a double walled horizontal underground storage tank consisting of a stainless steel internal wall and a fiberglass coated carbon steel external shell. This tank was installed in 1995 as part of STIP and the design and installation was consistent with the programs requirements. Construction of the tank was in accordance with American Society of Mechanical Engineers (ASME) Code Section VIII, Division 1, 1992 and the 1992 Addendum. The physical characteristics of the tank are given in Appendix.D-2-2. Engineering details for the tank are shown on the drawing listed below:

Drawing No. Title

V322TF-627-003 30,000 Gallon Underground Storage Tank

T-675 is a double walled horizontal underground storage tank consisting of a stainless steel internal wall and a fiberglass coated carbon steel external shell. This tank was installed in 1996 as part of STIP. Construction of the tank was in accordance with ASME Code Section VIII, Division 1, 1995. The physical characteristics of the storage tanks are given in Appendix D-2-2. Engineering details for the tank are shown on the drawing listed below:

Drawing No. Title

V322TF-627-013 35,000 Gallon Underground Storage Tank

- 3 - December 13, 2013 D2-4 D-2b(3) ANCILLARY EQUIPMENT DESIGN SPECIFICATIONS

Piping System The piping system associated with the tanks is constructed of Type 304 stainless steel and Monel alloy. Pipe connections are lap joint flanges with a standard serrated surface finish. All of the piping is located above grade and is accessible. Any threaded connections associated with the tank system are located over secondary containment structures.

Valves The valves associated with T-682 and T-675 consist of 316 stainless and Monel alloy hand valves, control valves, check valves and release valves. Valve placements are shown on the tank P&IDs. All valves are located over secondary containment or are double sealed or sealess.

Pumps The pumps associated with HWMU-33 tanks are Durco Mark III, Group II, stainless steel pumps and stainless steel flow switches. The pump seals are a carbon, ceramic mechanical seal. Pump placements are within the tank collar secondary containment.

D-2b(4) OVERFILL PROTECTION

Level Sensors

Two independent level monitoring devices provide overfill protection for the storage tanks. Each tank has a high level independent switching device set at 93% of the tank capacity. At 93% of tank capacity the switching device will automatically close the tank fill valves. The tank fill valves will also close upon loss of power or air supply. In addition, each tank is equipped with a continuous level monitor which will alarm the control room of a high level event (96% of tank capacity). These independent level sensors have been selected to be a fail safe design with system diagnostics to detect problems.

- 4 - December 13, 2013 D2-5

The catch tank, servicing the tank collars, is equipped with a level monitoring system providing data directly to the control room. A continuous level sensor will alarm the control room when the catch tank is filled to a level of twenty five inches. In addition, the inlet and outlet piping to the catch tank are equipped with vapor sensors. The vapor sensors will alarm the control room in response to a release.

Pressure Controls

Each of the tanks is protected against over-pressurization by a rupture disc set at 13 PSIG and a vacuum relief valve set at 0.25 PSIG vacuum.

The catch tank vents to the atmosphere through a conservation vent set at eight inches of water.

Vapor Control System

Both of the tanks are equipped with a vapor recovery system that vents tank vapors to a scrubbing control device. The tanks are blanketed with nitrogen at a pressure 10 PSIG. When the tank pressure reaches 2.9 PSIG, tank vapors vent through the vapor recovery system to the B322 pollution control device. The control valve to the vapor recovery system closes once the tank pressure drops to 2.9 PSIG. If the tank pressure drops to 2.2 PSIG, the nitrogen purge system opens and remains open until the tank pressure reaches 2.2 PSIG.

The B322 air pollution control equipment includes a refrigerated vent condenser, a 2-stage methanol scrubber and a water scrubber that provide greater than 95% control for the Hazardous Air Pollutants (HAPS) and Volatile Organic Compounds (VOCs) that are vented from the B-322 process equipment and storage tanks. Performance testing on the emission control system demonstrated compliance with MON MACT requirements. Permit conditions which include operating parameters and limits for the emission control system are included in Kodak’s Title V Air Permit. RCRA air emission requirements are met by conforming to the permit conditions and complying with the MON MACT requirements.

- 5 - December 13, 2013 D2-6 D-2b(5) FOUNDATIONS AND ANCHORING

T-682 and T-675 are underground storage tanks that are anchored to concrete holdown pads. The tanks are approximately fifteen feet below grade at the bottom of the tank. The tank systems were conservatively designed to withstand full hydrostatic pressure based on the assumption that the ground water level will be at grade level with an empty tank. Typical details of the tank anchoring are included on Drawing E322TF-201-003 - Tank Foundations and Hold Downs.

D-2b(6) CORROSION PROTECTION

Characteristics of the waste to be stored in the HWMU-33 tanks are provided in Module IV and Attachment C of the permit. Tank 682 and 675 were installed in 1995 and 1996 respectively and are constructed with inner shells of Type 316L stainless steel. The stainless steel is considered a good material selection for the mixed solvent waste and the tanks have stored this type of material since installation. To ensure corrosion problems are not encountered , an internal inspection of the tanks is done on a periodic basis. The most recent inspection records for the tanks are included in Appendix D-2-3. No significant corrosion problems have been observed for the tanks and the structural properties of the tanks have retained their original capabilities.

Other parts of the system (i.e. valves, pumps, and piping) are constructed of Type 304 stainless steel and Monel alloy. High fluid velocity through ancillary equipment maintains the corrosion resistance of stainless steel by removing debris and deposits. Other parts of the system include Teflon and elastomeric compounds for gaskets, o-rings, etc. Some of the elastomers are considered marginally resistant to some of the fluids handled but are selected to provide the best combination of desirable characteristics. Failure due to incompatibility is avoided through regular preventive maintenance and daily inspections.

These tanks are buried in washed crushed stone. The exterior of each tank is coated with a fiberglass mastic coating as indicated in Appendix D-2-4 which provides a measure of corrosion protection to the exterior of the shell.

The burial of tanks in washed gravel or crushed stone has been an approved and common practice at Eastman Business Park. The specification for the fill material is included in Appendix D-2-5. This design negates the need for cathodic protection; "soil" conditions are typically dry, neutral pH, and very high resistivity with low levels of chloride.

A corrosion certification in accordance with 6 NYCRR Part 373-2.10(c)(6) is included as Appendix D-2-6.

- 6 - December 13, 2013 D2-7

D-2b(7) TANK SYSTEM INTEGRITY INSPECTIONS

Visual inspections and ultrasonic wall thickness tests were performed on T-682 and T-675 in July, 2013 and July, 2005, respectively. The testing indicated that the tanks were in favorable condition. Internal inspections are performed at the discretion of the Materials Engineering Laboratory, based on the expected life of the tank and any changes in service. Currently, T- 682 has been placed on a three year cycle for internal inspections. T-675 has been placed on a ten year cycle. Copies of the most recent internal inspections are included in Appendix D-2-3.

D-2c INSTALLATION OF NEW TANK SYSTEM

A quality assurance program was conducted in conjunction with the installation of the HWMU- 33 tank system. Qualified inspectors audited each phase of the vault and tank system installations.

D-2d SECONDARY CONTAINMENT FOR TANK SYSTEMS The two HWMU-33 storage tanks are double walled in construction. Top mounted equipment (pumps, mixers, piping, valves etc.) are contained in the tank collars. The tank collars drain to a 36,000 gallon catch tank which may be pumped back into the storage tanks or to the industrial sewer. Each tank has been designed as an integral structure such that a release from the inner tank will be totally contained by the outer shell. The interstitial space of each tank is continuously monitored for the presence of vapors. Sensors monitoring the interstitial space on each tank will warn of wastes leaking into the interstitial space. Upon detection of a leak, an alarm is immediately given to the control room. The integrity of the double walled tank can also be checked using a pressure transmitter and air pressurization of the interstitial space.

The vapor sensors used in the interstitial space of the tanks, and the conveyance piping to the catch tank, are total hydrocarbon vapor analyzers, model number Tankguard VIII manufactured by Mine Safety Appliance Company (MSA).

Visual inspections of the tank systems are performed daily for signs of leakage as described in Attachment F.

- 7 - December 13, 2013 D2-8

D-2e GENERAL TANK OPERATING REQUIREMENTS

D-2e(1) OPERATION OF FLOW CONTROL SYSTEM

Hazardous waste tanks are rated for Class I Hazards and are clearly labeled "Hazardous Waste".

The fluid levels in the tanks are continuously monitored with readouts available at the control room in Building 322. When the fluid level in a tank reaches 90 percent of capacity, audible and visible alarms are activated in the control room and the valves are automatically closed, preventing further addition to the tanks.

Two methods are available for the detection of spills or leaks in any of the HWMU-33 storage tanks: (1) the control room operator monitors the level readout of each tank, and (2) the inventory sheets are monitored for each tank. Inventories for the tanks are taken once each operating shift and are recorded on log sheets.

D-2e(2) LOADING/UNLOADING PRACTICES

Typically, off-site liquid hazardous wastes arrive at Building 322 in tank trailers. Transfer operations occur at the trailer unloading station which consists of a curbed concrete pad that drains to a 36,000 gallon catch tank. When a tank trailer enters the trailer unloading station the wheels are blocked to prevent movement during unloading. A flexible transfer hose is connected to the trailer for unloading. The hose is inspected for damage before being connected to the trailer and is inspected for leaks once the transfer ahs begun. Operator oversight is provided throughout the trailer unloading process.

D-2f REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE

Reactive wastes are not stored in the HWMU-33 tanks. All tanks have the potential to store ignitable wastes; therefore, wastes are handled to minimize conditions that may cause the wastes to ignite. Standard practices to ensure that ignition sources are not present in flammable vapor areas include a Kodak policy that prohibits smoking and a permitting system for open flames and other sources of ignition. Ignition sources are allowed in flammable vapor areas only when a Temporary Open Flame Permit has been issued after a review of existing conditions and the appropriate precautions have been taken in order to prevent ignition of flammable vapors. Electrical controls within the vicinity of the tanks are either of explosion-proof design or are wired to be intrinsically safe. Signs are posted in areas where flammable wastes are stored.

- 8 - December 13, 2013 D2-9 Only authorized personnel are allowed and employees' protective equipment and clothing are checked to verify safe operation in these areas. Pipes and pumps in the area are grounded, as are containers and tank trailers in the unloading stations.

D-2g REQUIREMENTS FOR INCOMPATIBLE WASTES Compatibility is based on solvent type and characteristics of the wastes. Decisions as to the compatibility and joint storage of the wastes are based on an evaluation of the solubility and potential reactivity of the mixture. Compatibility is determined through a review of the individual processes generating the waste. Where the compatibility of a waste with other wastes is unknown, it will be determined based on the judgment of a chemist, engineer, or other person trained, experienced, and designated to make such a determination based upon the known characteristics of the waste involved. In addition, bench scale and analytical testing may be conducted to verify the compatibility of material prior to acceptance.

- 9 - December 13, 2013 D2-10 D-2h TANK INSPECTION

D-2h(1) DAILY INSPECTIONS

An inspection schedule for HWMU-33 is included in Attachment F, Table F-1. The inspection schedule covers inspection of monitoring equipment, safety and emergency equipment, security devices, operating equipment, and structural equipment that are important in preventing, detecting, or responding to environmental and/or human health hazards due to releases. The schedule identifies the item to be inspected, the types of problems to be addressed during the inspection, and the minimum frequency of inspection.

The tank system, including valves, pipes, fittings, and other ancillary equipment, is inspected daily. Results of these inspections are maintained in the HWMU's operating record and are accessible to operating and inspection personnel. The inspection log includes the date and time of inspection, the name of the inspector, a notation of the observations made (for each item listed in the inspection schedule), and the date and nature of any repairs or other remedial measures. Samples of the inspection logs are presented in Attachment F, Appendix F-1.

D-2h(2) TANK INTEGRITY ASSESSMENT SCHEDULE

Visual inspections and ultrasonic wall thickness tests were performed on T- 682 and T-675 in July, 2013 and July, 2005, respectively. Internal inspections are performed at the discretion of the Materials Engineering Laboratory, based on the expected life of the tank and any changes in service. Currently, T-682 has been placed on a three year cycle for internal inspections. T- 675 has been placed on a ten year cycle. Copies of the most recent internal inspections are included in Appendix D-2-3.

Leak observation tests and external inspections are performed on the ancillary equipment annually. Any deterioration or malfunction of equipment or structures revealed as a result of any inspection is remedied on a schedule to ensure the problem will not lead to an environmental and/or human health hazard. Where a hazard is imminent or has already occurred, remedial action will be taken immediately.

- 10 - December 13, 2013 D2-11 D-2i TANK SPILLS AND LEAKAGE

The Rochester Imaging Chemical Flow maintains a written copy of the Contingency Plan, Attachment G on file at Eastman Business Park. Employees are trained in its purpose, scope and application. Periodic review of this plan ensures that established procedures and controls are operational and current. Hazardous waste regulations [6 NYCRR 373-2.10(g)] require specific actions in the event of a leak or spill from hazardous waste tank systems. These requirements as outlined below, apply to both tank and secondary containment systems.

1. When a leak or spill from a tank is discovered, operating personnel will immediately stop the flow of hazardous waste into the tank and inspect the system to determine the cause of the release.

2. Hazardous waste will be removed from the tank system as is necessary to prevent further release and to allow inspection and repair to commence.

3. Hazardous waste will be removed from the secondary containment system within 24 hours of discovering the release or in as timely a manner as is possible to

prevent harm to human health and the environment. (Revised June, 2009)

4. Where visible releases of hazardous waste to the environment are observed, these releases will be controlled to prevent further migration of the wastes.

5. Any release to the environment from a hazardous tank system will be reported to the New York State Department of Environmental Conservation (NYSDEC) Commissioner within 24 hours of its occurrence, unless it is less than or equal to one pound and it is immediately (within 2 hours) contained and cleaned up.

6. Within 30 days of detection of the release, a report will be submitted to the Commissioner, containing the following information:  The likely route of migration of the release.  The characteristics of the surrounding soil.  The results of any sampling or monitoring conducted in connection with the release.  Proximity of the release to downgradient drinking water, surface water, and populated areas.  A description of response actions taken or planned.

- 11 - December 13, 2013 D2-12 7. Following a release from a tank system, these provisions will be satisfied, or the tank will be closed:

 If the cause of the release has not damaged the integrity of the system, the system may be repaired and returned to operation.  If the release was caused by a leak from a primary system into a secondary system, then the primary system will be repaired prior to being returned to service.

8. In the event that major repairs are made, such as repair of a ruptured primary or secondary containment vessel, or installation of an internal liner, then the repairs will be certified before returning the tank system to service. A qualified, professional engineer registered in the State of New York will certify that the repaired system is capable of handling hazardous waste without release for the intended life of the system. The certification will be submitted to the NYSDEC Commissioner within 7 days of returning the tank to service.

D-2j CLOSURE AND POST-CLOSURE

Closure and post-closure plans for the Kodak hazardous waste facility are included in Attachment I of the Kodak Part 373 Permit.

D-2k AIR EMISSION STANDARDS

6NYCRR 373-2.27 Air Emission Standards for Process Vents

All distillation processes are recycling units exempt from RCRA permitting. However, all vents from these distillation processes are connected to air emission control systems. There are three separate control systems. The B-322 control system is described in Section D-2b(4). The other two are the B-120 and the B-142 control systems. Both of these systems have 2-stage methanol scrubbers followed by a water scrubber. All of the distillation process vents connected to these three systems comply with the process vent standards of 373-2.27 as provided in 373-2.27a(3) by complying with the Miscellaneous Organic Chemical Manufacturing NESHAP (Subpart FFFF – 63.2455 and 63.2460) process vent requirements. Specific conditions for complying with these requirements are contained in Kodak’s Title V air permit for EBP.

6NYCRR 373-2.28 Air Emission Standards for Equipment Leaks

- 12 - December 13, 2013 D2-13

All distilling process equipment in hazardous waste service is subject to the leak detection and repair requirements (LDAR) of 373-2.28. Components (e.g. valves, pumps) are identified, monitored and repaired as required.

6NYCRR 373-2.29 Air Emission Standards for Tanks, Surface Impoundments and Containers

For the distilling operations at EBP, applicability of 373-2.29 is limited to the two permitted hazardous waste storage tanks (HWMU-33). The vents for both of these tanks are connected to the B-322 emission control system that complies with the MON MACT. Specific conditions for complying with these requirements are contained in Kodak’s Title V air permit for EBP.

- 13 - December 13, 2013 D2-14 Appendix D-2-1 Independent Professional Engineering Certification

- 14 - December 13, 2013 D2-15 D2-16 Appendix D-2-2 Tank Characteristics

- 15 - December 13, 2013 D2-17 D2-18 D2-19 Appendix D-2-3 Tanks Inspections

- 16 - December 13, 2013 D2-20 D2-21 D2-22 D2-23 D2-24 D2-25 D2-26 D2-27 D2-28 Appendix D-2-4 Engineering Specification FRP Cladding Metal Tanks

- 17 - December 13, 2013 D2-29 D2-30 D2-31 Appendix D-2-5 Engineering Specification Backfill

- 18 - December 13, 2013 D2-32 D2-33 D2-34 D2-35 D2-36 D2-37 D2-38 Appendix D-2-6 Corrosion Certification

- 19 - December 13, 2013 D2-39

February 12, 2009

Mr. Bryan Gallagher Eastman Kodak Company 1669 Lake Road Rochester, NY 14652

Re: Building 322 Storage Tanks

File: 1447/43982

VIA EMAIL: [email protected]

Dear Mr. Gallagher:

Consistent with O’Brien & Gere’s proposal dated January 16, 2009 please find the accompanying Corrosion Certification performed for the following tanks located outside of Building 322 at the Eastman Business Park:

Tank # 682 – 30,000 gallon Tank # 675 – 35,000 gallon

Please note that the accompanying certification has been prepared consistent with the requirements outlined within 6 New York Code of Rules and Regulations (NYCRR) Part 373-2.10.

If you have any questions regarding this submittal please do not hesitate to contact the undersigned at 585-263-2820 or Mr. Albert Lyons, Jr., P.E. at 716-827-0700.

Very truly yours, O’BRIEN & GERE ENGINEERS, INC.

Jamie D. Newtown Managing Scientist

D2-40 GREAT LAKES ENVIRONMENTAL & SAFETY CONSULTANTS, INC.

February 11, 2009

Mr. Jamie Newtown O’Brien & Gere 400 Andrews Street Suite 400 Rochester, NY 14604

RE: Kodak Building 322 Storage Tanks; Corrosion Certification

Mr. Newtown:

Per your request, Great Lakes Environmental & Safety Consultants, Inc. (Great Lakes) has reviewed the applicable portions of the proposed hazardous waste tank design and installation procedures as presented in the attached information. The tank systems are located belowground at Building 322 and are owned and operated by Eastman Kodak Company in Rochester, New York. The tanks are known as Tank #682 (30,000 gallon) and Tank #675 (35,000 gallon) and were installed in 1995 under the Kodak Park Storage Tank Improvement Program (STIP). Based on information provided, the double wall tanks are constructed of 316L stainless steel and are externally coated with a fiberglass reinforced plastic cladding. Based on my review of the information provided in accordance with 6 NYCRR Part 373- 2.10(c)(6), the tank systems are designed and installed in a manner that provides appropriate external corrosion protection.

I further certify under penalty of law that I have personally examined and am familiar with the information submitted on corrosion protection requirements and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true accurate and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fine and imprisonment.

If you have any questions or require further information, please do not hesitate to contact me at (716) 827- 0700.

Sincerely,

Albert G. Lyons, Jr., P.E. Vice President

GATEWAY EXECUTIVE PARK 3556 LAKESHORE ROAD BUFFALO, NY 14219 PHONE: (716) 827-0700 FAX: (716) 824-4734

WWW.GREATLAKESENVIRONMENTAL.COM D2-41

ATTACHMENT D2 – DRAWING LIST

HWMU‐33 Tanks Drawing List Title Drawing# Tank Foundations & Hold Down Plan E322TF-201-001G Tank Foundations & Hold Down Details ‐ E322TF-201-003C South Area

Tank 674 Double Wall Tank General V322TF-627-003 Assembly Tank 674 Double Wall Tank General V322TF-627-013 Assembly Tank 675 Instrumentation and Flow E322TF-700-675D TK‐682 Instrumentation and Flow D322TF-700-682B

(DRAWINGS IN ATTACHMENT J)

D2-42 June 2014

ATTACHMENT E

CORRECTIVE ACTION REQUIREMENTS

EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NO. NYD980592497

Master List of SWMUs at Eastman Business Park

E-1 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Industrial Sewer components of the Waste Water Treatment Unit E-001 EIA-IS IS located in KPE B-000 KPE Park Section ACTIVE Open1 90-Day Container Storage Platform K, North Side, near E-004 UNGROUPED CS Area B-006 column 105. INACTIVE Closed Platform K, North Side (Loading Dock), near column E-005 UNGROUPED MA Marshaling Area B-006 98 INACTIVE Closed Silver Recovery Equipment Basement, Near Rm 26, E-006 UNGROUPED PMR / Processes B-006 Inside on Concrete Floor. INACTIVE Closed Southeast Corner on Covered E-007 UNGROUPED MA Marshaling Area B-007 Loading Dock INACTIVE Closed E-009 UNGROUPED MA Marshaling Area B-009 Northwest Door J INACTIVE Closed E-010 UNGROUPED MA Marshaling Area B-011 Northeast Corner INACTIVE Closed South Side, Loading Dock TENANT E-011 UNGROUPED MA Marshaling Area B-012 Room B117 CONTROL Closed

E-013 UNGROUPED MA Marshaling Area B-014 West Wall, Outside on Asphalt INACTIVE Closed

B-20 North Interior, on Asphalt E-016 UNGROUPED MA Marshaling Area B-020 Floor near RR tracks INACTIVE Closed E-017 UNGROUPED MA Marshaling Area B-021 B-21 North Interior INACTIVE Closed B-23 North Side, Inside Bldg., E-018 UNGROUPED MA Marshaling Area B-023 Door I INACTIVE Closed E-019 UNGROUPED MA Marshaling Area B-025 B-25 East Side INACTIVE Closed E-020 EIA-27 MA Marshaling Area B-027 West Side, Door L INACTIVE Closed E-021 EIA-27 TT Trap Tank ID TT0271IS B-027 Under #46 Unit ACTIVE Closed1

E-022 EIA-27 TT Trap Tank ID TT0274IS B-027 West of Salvage Water Tank ACTIVE Closed1 E-023 EIA-27 TT Trap Tank ID TT0272IS B-027 Under #47 Machine ACTIVE Closed1 Under #31 Machine, Salvage E-024 EIA-27 TT Trap Tank ID TT0273IS B-027 Water Tank ACTIVE Closed1 E-025 EIA-27 TT Trap Tank ID TT0275IS B-027 Under #33 Unit ACTIVE Closed1 E-026 EIA-27 TT Trap Tank ID TT0276IS B-027 Under #23 Machine ACTIVE Closed1 E-027 EIA-27 TT Trap Tank ID TT0278IS B-027 Under #34 Unit ACTIVE Closed1 E-028 EIA-27 TT Trap Tank ID TT0277IS B-027 Under #24 Machine ACTIVE Closed1 E-029 UNGROUPED MA Marshaling Area B-029 B-29 South INACTIVE Closed E-030 UNGROUPED PMR Silver Recovery Rich Pit B-029 B-29-10 East INACTIVE Closed E-031 UNGROUPED PMR Silver Recovery Rich Pit B-029 B-29-10 West ACTIVE Closed1 B-29-13 Room North, Spill collection sump (Record Silver Recovery Tank updated 7/15/1998 to incl. E- E-032 UNGROUPED PMR System B-029 033 tank information) ACTIVE Closed1 B-29-14 Room (Basement Silver Recovery Tank level); 3,300 Gal Sec. E-034 UNGROUPED PMR System B-029 Containment ACTIVE Closed1 E-035 EIA-30 MA Marshaling Area B-030 Door LL, Northeast, Inside INACTIVE Closed E-036 EIA-30 PMR Silver Recovery Rich Pit B-030 B-30-A ACTIVE Closed1 E-037 EIA-30 PMR Silver Recovery Rich Pit B-030 B-30-C ACTIVE Closed1

E-038 EIA-30 TS HWMU-01 Transfer Station B-030 Northwest Corner INACTIVE Closed Basement, Below Floor Slab; E-039 EIA-30 TAS HWMU-01 Closed Tank B-030 B-30-C INACTIVE Closed E-040 EIA-30 TAS HWMU-01 Storage Tank B-030 Vault, Northeast Corner ACTIVE Closed1 B-31 West Wall, Outside, on E-041 UNGROUPED MA Marshaling Area B-031 asphalt INACTIVE Closed B-33 Southwest Wall, Inside, E-042 UNGROUPED MA Marshaling Area B-033 Loading Dock INACTIVE Closed E-043 EIA-53 PMR Silver Recovery B-046 B-46, Basement INACTIVE Closed

B-33 South Inside Bldg., E-044 UNGROUPED PMR Silver Recovery Rich Pit B-033 Basement, on concrete floor INACTIVE Closed E-045 UNGROUPED MA Marshaling Area B-034 West Side Loading Dock INACTIVE Closed B-35 East Center, west of E-046 UNGROUPED MA Marshaling Area B-035 door K INACTIVE Closed Silver Recovery, concrete secondary containment B-35, West side of building, E-047 UNGROUPED PMR system B-035 south of door DD ACTIVE Closed1 B-35, West side of building, E-048 UNGROUPED PMR Silver Recovery B-035 east of door DD INACTIVE Closed B-35, West side of building, E-049 UNGROUPED PMR Silver Recovery B-035 east of door F ACTIVE Closed1 Loading Dock, North East E-050 UNGROUPED MA Marshaling Area B-042 Corner of B-42 INACTIVE Closed

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 1 of 16 SWMU Master List

E-2 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS E-051 UNGROUPED PMR Silver Recovery B-036 B-36, Northwest INACTIVE Closed B-38 Northeast Corner, 1st E-052 UNGROUPED MA Marshaling Area B-038 floor INACTIVE Closed B-38 Above basement E-053 UNGROUPED PMR Silver Recovery B-038 southwest corner INACTIVE Closed B-38-RW Center, SW E-054 UNGROUPED PMR Silver Recovery B-038 Basement ACTIVE Closed1 E-055 EIA-27 MA Marshaling Area B-043 North Side, Inside Bldg. INACTIVE Closed E-056a EIA-27 S Waste Trenches B-043 Northwest of B-43, Inside INACTIVE Closed E-056b EIA-27 S Waste Trenches B-043 B-43 Southeast, Inside INACTIVE Closed B-45 West Center, inside building, loading dock at Door E-057 EIA-27 MA Marshaling Area B-045 M, SW quadrant INACTIVE Closed

E-058 EIA-27 CS Waste Accumulation Area B-046 B-46 South INACTIVE Closed E-059 EIA-27 MA Marshaling Area B-046 B-46 North Side, Inside INACTIVE Closed

E-061 EIA-53 MA Marshaling Area B-048 B-48 Northwest, Loading Dock NEW OWNER Closed E-062 UNGROUPED MA Marshaling Area B-049 B-49 South INACTIVE Closed E-063 UNGROUPED PMR Silver Recovery B-049 B-49 1st Flr., column 55 INACTIVE Closed E-064 UNGROUPED CS Marshaling Area B-050 B-50 North Platform INACTIVE Closed E-066 EIA-53 PMR Silver Recovery B-052 B-52, West Corner INACTIVE Closed E-067 EIA-53 MA Marshaling Area B-053 B-53 South Center INACTIVE Closed 90-Day Container Storage E-068 EIA-53 CS Area B-054 B-54 East Side INACTIVE Closed E-069 EIA-53 TT Trap Tank ID TT0100IS B-054 B-54 Northeast Corner INACTIVE Closed E-070 UNGROUPED MA Marshaling Area B-056 B-56 South Center INACTIVE Closed Northeast Corner of B-57, E-071a EIA-53 MA Marshaling Area B-057 Door M INACTIVE Closed E-071b EIA-53 MA Marshaling Area B-057 B-57 Center West INACTIVE Closed E-071c EIA-53 MA Marshaling Area B-057 South Loading Dock Door F INACTIVE Closed E-072 EIA-53 PMR Silver Recovery B-057 B-57 Northeast Side INACTIVE Closed West Side (Southern half of E-073 EIA-53 PMR Silver Recovery B-057 Bldg.) INACTIVE Closed E-074 EIA-53 PMR Silver Recovery B-057 B-57 North Center INACTIVE Closed E-075 UNGROUPED MA Marshaling Area B-058 B-58 North Side INACTIVE Closed 90-Day Container Storage E-076 UNGROUPED CS Area B-059 B-59 West Side INACTIVE Closed B-59 North Side, inside, E-077 UNGROUPED MA Marshaling Area B-059 loading dock door G ACTIVE Closed1 E-078 UNGROUPED PMR Silver Recovery B-059 Sub-Basement ACTIVE Closed1 E-079 UNGROUPED MA Marshaling Area B-060 B-60 Northwest, Door H INACTIVE Closed B-69 East Side, Basement, E-084 UNGROUPED PMR Silver Recovery B-069 rm0302 INACTIVE Closed E-086 UNGROUPED PMR Silver Recovery B-067 B-67 West, Inside INACTIVE Closed 90-Day Container Storage E-088 UNGROUPED CS Area B-082 B-82D Chemical Stockroom ACTIVE Closed1 HWMU-24 Inactive Lugger B-82B, Courtyard, south of E-089 EIA-82 CS Pad B-082 loading dock INACTIVE Closed

E-090 UNGROUPED MA Marshaling Area B-082 B-82B South of Loading Dock INACTIVE Closed Transfer Pad adjacent to B-82 E-091 EIA-82 TS HWMU-24 Transfer Station B-082 Tank Farm ACTIVE Closed1 B-82 Courtyard tank farm, SW E-093 EIA-82 TT Trap Tank ID TT0200IS B-082 of B-82A INACTIVE Closed E-094 EIA-82 UST HWMU-24 Storage Tank B-082 B-82 Tank Farm Vault INACTIVE Closed Waste Water Treament B-91 Floor Drains and B-91 E-096 EIA-KL S Unit Sump ID SP0091IS B-091 Sanitary Sewage ACTIVE Closed1

Waste Water Treament E-097 EIA-KL S Unit Sump ID SP00171IS B-093 B-93 Center, outside lab ACTIVE Closed1 Waste Water Treament E-098 EIA-KL S Unit Sump ID SP0099IS B-093 Northeast of B-93 (R-17) ACTIVE Closed1 Waste Water Treament E-099 EIA-KL S Unit Sump ID SP0200ST B-094 South of B-94 ACTIVE Closed1 90-Day Container Storage B-95, 1st floor, Northeast, by E-100 EIA-KL CS Area B-095 hearth ACTIVE Closed1 HWMU-32 Multiple Hearth Incinerator/Ash Handling E-101 EIA-KL I System B-095 King's Landing (B-95) ACTIVE Closed1 E-102 EIA-KL I Rotary Kiln Incinerator B-095 West of B-95 INACTIVE Closed Former Landfill Open Current King's Landing Site, E-103 EIA-KL L Burning Site B-095 Shed R-(24,9) INACTIVE Closed Waste Water Treament E-105 EIA-KL S Unit Sump ID SP0089IS B-095 Southeast of B-95, Inside ACTIVE Closed1

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E-3 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Waste Water Treament E-106 EIA-KL S Unit Sump ID SP0097IS B-095 West of B-95 ACTIVE Closed1

Wastewater Treatment E-107 EIA-KL WTS Plant (associated releases) B-095 KLWPP ACTIVE Closed1 Waste Water Treament E-109 EIA-KL S Unit Sump ID SP0013IS B-099 West of B-99 INACTIVE Closed Waste Water Treament Unit Sump ID SP0090IS, E-110 EIA-KL S Return sludge pits B-099 West of B-99 ACTIVE Closed1 Waste Water Treament Unit Sump ID SP0092IS, E-111 EIA-KL S Return sludge pits B-099 North of B-99 ACTIVE Closed1 Waste Water Treament Unit Sump ID SP0093IS, E-112 EIA-KL S Return sludge pits B-099 North of B-99 ACTIVE Closed1 E-113 UNGROUPED CS Container Storage Area B-060 B-60 Center INACTIVE Closed E-116 EIA-KL CS Shaker Screens B-095 West of B-99 INACTIVE Closed

Waste Water Treament Unit lift station to aeration E-117 EIA-KL S basin, Sump ID SP0098IS B-095 South of aeration basins ACTIVE Closed1 E-119 EIA-53 S Sump ID SP0250ST B-053 Northwest Side of B-53 ACTIVE Closed1 Multiple Hearth Scrubber E-120 EIA-KL S Sump ID SP0096IS B-095 Basement, B-95 West ACTIVE Closed1 Trap Tank ID TT0030IS, Under cantilever, North, E-122 EIA-30 TT No. C-912 B-030 Center INACTIVE Closed E-125 UNGROUPED MA Marshaling Area B-069 B-69 South Side, Inside INACTIVE Closed E-127 UNGROUPED MA Marshaling Area B-087 B-87 North Side INACTIVE Closed

Several releases recorded E-128 WIA-KPW RS along distilling pipelines. B-065 South of B-65 (Under Pass) SPILL Closed

E-129 EIA-82 UST Underground Storage Tank B-082 South Side of B-82, Courtyard INACTIVE Closed Underground Storage Tank E-130 UNGROUPED UST C986 B-050 West Side of B-050 INACTIVE Closed East Side B-045 (Between B- E-131 EIA-27 UST Underground Storage Tank B-045 045 and B-057) INACTIVE Closed Underground Storage E-132 EIA-30 UST Tank. B-030 Basement, Northeast Corner INACTIVE Closed

E-133 EIA-KL RS Underground Storage Tank B-095 Southeast Corner INACTIVE Closed E-134 EIA-53 RS Release Site B-053 West Side of B-053 SPILL Closed

E-135 EIA-30 RS Between B-30A and B-30C B-030 Between B-30a and B-30c SPILL Closed Two 15,000 gallon fuel E-136 EIA-27 RS storage tanks. B-046 Foundation, Southeast Corner SPILL Closed

King's Landing Wastewater Treatment Plant - Entire Facility, including all King's Landing Area, Shed (R- E-138 EIA-KL RS ancillary equipment B-095 24) SPILL Closed E-139 EIA-30 RS Courtyard north of B-30 B-030 Northwest SPILL Closed E-140 UNGROUPED RS Release Site B-059 Between B-42 and B-59 SPILL Closed E-142 EIA-53 RS Release Site B-018 Between B-18 and B-48 SPILL Closed E-143 EIA-53 RS B-054 Tank Farm B-054 Tank Farm, West of B-54 SPILL Closed E-144 EIA-27 RS Cooling tower B-027 B-27, Inside, Southwest SPILL Closed King's Landing Discharge King's Landing Discharge to E-147 EIA-KL RS to River B-095 Genesee River ACTIVE Open1 KPE Sanitary Sewer E-148 UNGROUPED SAS System B-000 KPE Park Section ACTIVE Closed1 Storage Tank (Gelatin E-149 EIA-53 TAS Settling Basins) B-047 Area Surrounding B-47 INACTIVE Closed E-150 UNGROUPED S Sump B-011 Southeast Corner, Inside INACTIVE Closed Waste Water Treament E-151 EIA-KL S Unit Sump ID SP0088IS B-099 Northwest of B-99 ACTIVE Closed1 Suspected release, Vinyl E-152 EIA-62 RS Chloride detected. B-062 Southwest of B-62 SPILL Closed E-153 EIA-53 RS Release Site B-049 B-49 NE SPILL Closed Assumed Release Site Northwest of B-2, between B-2 E-154 EIA-2 RS Unit B-002 and B-13 SPILL Closed E-155 UNGROUPED MA Marshaling area B-038 Basement INACTIVE Closed Lot 40, Petroleum Storage Parking Lot 40, formerly E-156 UNGROUPED RS Tank Release B-092 Spector Tire SPILL Open2 TENANT E-157 UNGROUPED MA Marshaling Area B-014 Northwest Corner of B-14 CONTROL Closed

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E-4 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS B-46 Basement, Northwest E-158 EIA-53 S Floor Sump B-046 Corner INACTIVE Closed Waste Water Treament E-159 EIA-KL S Unit Sump ID SP0087IS B-091 North East Corner B-91, (R-6) ACTIVE Closed1 90-Day Storage Area/Tube E-160 UNGROUPED CS Crusher B-023 First Floor, Room 109 INACTIVE Closed 90-Day Storage Area/Tube E-161 UNGROUPED CS Crusher B-009 Inside Room 605 INACTIVE Closed

E-162 EIA-27 S Sewer Building Drainage B-043 Inside, below slab INACTIVE Closed 90-Day Exempt Storage Along primary clarifier on E-163 EIA-KL CS Area, RO containers B-091 asphalt with diking ACTIVE Closed1 90-Day Storage Area, East of R-9. Outside on E-164 EIA-KL CS Totes and RO Boxes B-095 Asphalt. ACTIVE Closed1

Inside Building, on Concrete, E-165 EIA-27 MA Marshaling Area B-027 Next to door GG, East side INACTIVE Closed 90-Day Container Storage Inside Building, Room 690, 6th E-166 UNGROUPED CS Area B-059 Floor INACTIVE Closed 90-Day Container Storage E-167 EIA-KL CS Area B-091 By MEMO Shop - Concrete ACTIVE Closed1 90-Day Container Storage Basement Lab - Tile covered E-168 EIA-KL CS Area B-091 concrete INACTIVE Closed 90-Day Container Storage E-170 EIA-KL CS Area B-095 Basement - Concrete ACTIVE Closed1 90-Day Container Storage Outside eductor room in E-171 EIA-KL CS Area B-095 basement - Concrete INACTIVE Closed 90-Day Container Storage E-172 EIA-KL CS Area B-095 Lab in Basement - Concrete ACTIVE Closed1 90-Day Container Storage E-174 EIA-KL CS Area B-096 1st Floor ACTIVE Closed1

Railroad unloading station, E-204 UNGROUPED RS NE corner of the building B-049 Northeast corner SPILL Closed E-210 UNGROUPED RS Release Site B-050 Northwest corner SPILL Closed E-212 EIA-53 RS Release Site B-052 North SPILL Closed E-214 EIA-53 RS Release Site B-053 North SPILL Closed E-222 WIA-KPW RS Release Site B-069 East side SPILL Closed Trench located at former shed E-226 EIA-53 RS Release Site B-053 E-44, NW of B-054 SPILL Closed E-227 UNGROUPED R Release B-031 South side of building SPILL Closed

E-229 EIA-53 R Fuel oil unloading station B-024 North side of E-24 SPILL Closed

P-3 Solvent storage shed, SW E-233 EIA-82 CS Container Storage Area B-082 corner of B-082A (no waste) INACTIVE Closed B-087 west of the locker room E-234 UNGROUPED TT Sump B-087 area ACTIVE Closed1 90-Day Container Storage Inside B-095, 1st floor in lab - E-235 EIA-KL CS Area B-095 Tile covered concrete ACTIVE Closed1 90-Day Container Storage E-236 EIA-KL CS Area B-093 Inside Shed R-24 INACTIVE Closed E-237 EIA-27 RS Release Site B-046 North side of B-046 SPILL Closed B-095, in basement near the E-238 EIA-KL S Sump B-095 grit conveyor INACTIVE Closed B-82, inside, west side of 90-Day Container Storage Room B004 (due north of B- E-239 EIA-82 CS Area B-082 wing loading docks). INACTIVE Closed B-82, inside, east side of 90-Day Container Storage Room B004 (due north of B- E-240 EIA-82 CS Area B-082 wing loading docks). INACTIVE Closed Bldg. 27, inside and immediately east of door R on concrete, north side of E-241 EIA-27 MA Marshaling Area B-027 building. INACTIVE Closed Bldg. 31, inside and slightly east of Door N on concrete, E-242 UNGROUPED MA Marshaling Area B-031 north side of building. INACTIVE Closed 90-Day Container Storage Building 48, inside on the 5th E-243 EIA-53 CS Area B-048 floor NEW OWNER Closed North of Building 6 (in the 90-Day Container Storage footprint of where B-34 used E-244 UNGROUPED CS Area B-034 to stand) INACTIVE Closed

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E-5 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Basement of Building 6, north of Room 26, within portions of Industrial Sewer Silver Recovery Area (SWMU E-245 UNGROUPED RS Compromise B-006 E-006) INACTIVE Closed B-30; inside; first floor, south of loading dock LL; located between columns H2-H3 and E-246 EIA-30 MA Marshaling Area B-030 G2-G3 ACTIVE Closed1 90-Day Container Storage E-247 EIA-KL CS Area B-095 Basement, B-95 ACTIVE Closed1 90-Day Container Storage E-248 EIA-30 CS Area B-030 Building 30, Room 812 INACTIVE Closed 90-Day Container Storage South of B-29N, at former B- E-249 UNGROUPED CS Area B-029 58 footprint INACTIVE Closed B-82, inside, Room A-17 90-Day Container Storage (basement), A-Wing of the E-250 EIA-82 CS Area B-082 KRL North Complex INACTIVE Closed 90-Day Container Storage Inside B-20, northeast corner E-251 UNGROUPED CS Area B-020 of 2nd floor INACTIVE Closed 90-Day Container Storage inside northeast corner of B- E-252 EIA-53 CS Area B-052 52 at loading dock INACTIVE Closed Hazardous Solids and Inside Building 19 at Room E-253 UNGROUPED CS Liquids B-019 203/1 INACTIVE Closed 90-Day Container Storage E-254 EIA-30 CS Area B-030 Building 30, Room 726 ACTIVE Closed1 90-Day Container Storage Inside Building 65, Basement E-255 WIA-KPW CS Area B-065 Level at Door G INACTIVE Closed

North of the former B-23, near E-256 UNGROUPED RS Release Site Area B-023 a former heat treatment area SPILL Closed 90-Day Container Storage E-257 EIA-82 CS Area B-082 B-82, inside room D004 ACTIVE Closed1 E-258 EIA-53 MA Marshaling Area B-053 B-53 Loading Dock K ACTIVE Closed1

E-259 UNGROUPED WTS Water Treatment Filtration B-042 B-42 1st Floor ACTIVE Closed1 Industrial Sewer components of the Waste Water Treatment Unit M-001 MIA-IS IS located in KPM B-300 KPM Park Section ACTIVE Closed1 90-Day Container Storage M-002 MIA-301 CS Area B-301 B-301 West, Bay 7 INACTIVE Closed B-301 Tunnel Scrubber M-003 MIA-301 S Sump B-301 Inside, NW Corner INACTIVE Closed HWMU-09 Temporary M-004 MIA-301 TS Transfer Station (3-Day) B-301 West of B-302 INACTIVE Closed M-005 MIA-301 CS HWMU-09 Trailer Station B-302 East of Tank Farm ACTIVE Closed1 M-006 MIA-301 TT Trap Tank ID TT3300IS B-301 Outside, Bay 3, South Side INACTIVE Closed M-007 MIA-301 TT Trap Tank ID TT3301IS B-301 Outside, Bay 5, South Side INACTIVE Closed M-008 MIA-301 TT Trap Tank ID TT3302IS B-301 Outside, Bay 10, North Side INACTIVE Closed M-009 MIA-301 TT Trap Tank ID TT3303IS B-301 Outside, Bay 12 INACTIVE Closed

HWMU-09 Closed Storage M-010 MIA-301 TAS Tanks (2 x 20,000 gal.) B-301 West of B-302 INACTIVE Closed B-302 Tunnel Scrubber M-011 MIA-301 S Sump B-302 Inside, Northwest Corner INACTIVE Closed M-012 MIA-301 TT Trap Tank ID TT3321IS B-302 Outside, South, Bay 5 INACTIVE Closed M-013 MIA-301 TT Trap Tank ID TT3323IS B-302 Outside, North, Bay 12 INACTIVE Closed M-014 MIA-301 TT Trap Tank ID TT3325IS B-302 Outside North, Bay 10 INACTIVE Closed M-015 MIA-301 TT Trap Tank ID TT4000IS B-302 East Side of Yard INACTIVE Closed

M-016 MIA-301 MA Marshaling Area B-303 East Side, Inside Headhouse ACTIVE Closed1 B-303 Tunnel Scrubber M-017 MIA-301 S Sump B-303 Inside NW Corner ACTIVE Closed1 M-018 MIA-301 TT Trap Tank ID TT3350IS B-303 Outside South, Bay 4 INACTIVE Closed M-019 MIA-301 TT Trap Tank ID TT3351IS B-303 Outside South, Bay 7 ACTIVE Closed1 M-020 MIA-301 TT Trap Tank ID TT4005IS B-303 North Side, Bay 16 INACTIVE Closed Side Sump (for labs), B-303 M-021 MIA-301 TT Trap Tank ID TT4010IS B-303 East INACTIVE Closed M-022 MIA-301 TT Trap Tank ID TT4040IS B-303 Outside North, Bay 13 ACTIVE Closed1 Outside South, Bay 2 and Bay M-023 MIA-301 TT Trap Tank ID TT3360IS B-304 3 INACTIVE Closed Outside South, Bay 4, Bay 5, M-024 MIA-301 TT Trap Tank ID TT3361IS B-304 and Bay 6 INACTIVE Closed Outside South, Bay 7 and Bay M-025 MIA-301 TT Trap Tank ID TT3362IS B-304 8 INACTIVE Closed

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E-6 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Outside, North, Bay 9 Side M-026 MIA-301 TT Trap Tank ID SP4010IS B-304 Sump ACTIVE Closed1 Outside North, Bay 10, Side M-027 MIA-301 TT Trap Tank ID TT3364IS B-304 Sump ACTIVE Closed1 Outside North, Bay 11, Side M-028 MIA-301 TT Trap Tank ID TT3365IS B-304 Sump ACTIVE Closed1 Outside South, Bay 1 M-029 MIA-301 TT Trap Tank ID TT3366IS B-304 (Blender) ACTIVE Closed1 Outside North, Bay 17 M-030 MIA-301 TT Trap Tank ID TT3363IS B-304 (Blender) ACTIVE Closed1

M-031 MIA-301 TT Trap Tank ID TT4005(2)IS B-304 Trap Tank, West ACTIVE Closed1 Ash stored in pile on M-033 MIA-301 PMR concrete pad B-305 Near Railroad Tracks INACTIVE Closed B-306, Door J (East), on M-034 UNGROUPED MA Marshaling Area B-306 Concrete Floor INACTIVE Closed M-035 MIA-308 MA Marshaling Area B-307 B-307 North, Outside INACTIVE Closed M-036 MIA-308 TT Trap Tank ID TT3307IS B-307 East of B-307 INACTIVE Closed M-037 MIA-308 TT Trap Tank ID TT3309IS B-307 East of B-307 INACTIVE Closed M-038 MIA-308 TT Trap Tank ID TT3310IS B-307 East of B-307 INACTIVE Closed M-039 MIA-308 TT Trap Tank ID TT3301IS B-307 East of B-307 INACTIVE Closed M-040 MIA-308 S Sump ID SP3316IS B-307 East of B-307 INACTIVE Closed SWMU-09 DPI Surface M-041 MIA-308 SI Impoundment B-307 East of B-307 INACTIVE Closed Trap Tank ID TT4020IS M-042 MIA-308 TT (catch tank) B-308 Outside, North of B-307 ACTIVE Closed1 M-044 MIA-308 S Sump ID SP4045IS B-308 B-308 INACTIVE Closed North of B-312 and West of M- M-045 MIA-308 SI Surface Impoundments B-312 56 INACTIVE Closed M-046 MIA-308 TT Trap Tank ID TT4015IS B-308 B-308 ACTIVE Closed1 SWMU-08 DPI Drum M-048 MIA-308 L Disposal Site B-312 Northwest of B-312 INACTIVE Closed M-049 MIA-308 S Sump B-312 North of B-312 INACTIVE Closed M-050 MIA-308 S Sump ID SP3313IS B-312 B-312 West Side INACTIVE Closed M-051 MIA-308 S Sump ID SP3314IS B-312 West Side of B-312 INACTIVE Closed M-052 MIA-308 S Sump ID SP3315IS B-312 West side of B-312 INACTIVE Closed

M-053 MIA-308 TT Trap Tank ID TT4060IS B-312 Shed at M-56, North of B-307 INACTIVE Closed Waste Luggers & M-061 MIA-317 CS Containers B-317 Southwest Corner of B-317 INACTIVE Closed

M-062a MIA-317 MA Marshaling Area B-317 Northwest Corner O & P Dock INACTIVE Closed B-317 East South, Inside, on M-062b MIA-317 MA Marshaling Area B-317 Concrete Floor, C-Dock. INACTIVE Closed 90-Day Container Storage M-062c MIA-317 CS Area B-317 QQ Dock Door. ACTIVE Closed1 Southeast Corner of Current B- M-063 MIA-317 OBOD Open Burn Area B-317 317site INACTIVE Closed West of B-317 and South of M- M-066 MIA-317 TS Trailer Station B-317 38 INACTIVE Closed HWMU-27 Closed Storage M-067 MIA-317 TAS Tanks B-317 B-317 Southeast, Outside INACTIVE Closed Northwest corner of B-318 M-068 UNGROUPED MA Marshaling Area B-318 central warehouse NEW OWNER Closed B-319 Southwest Corner, M-069 UNGROUPED MA Marshaling Area B-319 Inside on Concrete Floor INACTIVE Closed 90-Day Container Storage B-320, Northeast Corner, M-070 UNGROUPED CS Area B-320 Inside on Concrete Floor INACTIVE Closed B-320, Northside, Inside, on M-071 UNGROUPED MA Marshaling Area B-320 Concrete Floor INACTIVE Closed HWMU-29 Container M-072 UNGROUPED CS Storage B-321 Lot 76, South of B-321 INACTIVE Closed North of B-322. Retention pond. Contiguous with MIA- M-076 MIA-308 SI Surface Impoundment B-322 308. INACTIVE Closed Northwest Trailer Station in B- M-077 MIA-308 TS West Trailer Station B-322 322 Courtyard ACTIVE Closed1 Trap Tank ID TT3322IS M-078 MIA-308 TT (Tank removed in 1996) B-322 Southwest of B-322 INACTIVE Closed Trap Tank ID TT3324IS M-079 MIA-308 TT (Tank removed in 1996) B-322 Southwest of B-322 INACTIVE Closed

M-080 MIA-308 TAS HWMU-20 Storage Tanks B-322 Tank Farm-Waste Tanks INACTIVE Closed M-083 MIA-301 TT Trap Tank ID TT4055IS B-323 B-323 Southeast Corner ACTIVE Closed1 HWMU-13 Closed Storage M-084 MIA-301 TAS Tank #C-1365 B-323 B-323 North INACTIVE Closed

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E-7 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS M-085 MIA-VH L Ver Hulst Site B-324 North of B-324 INACTIVE Closed Loading Dock, West Side, M-086 MIA-301 MA Marshaling Area B-325 Inside on Concrete Floor ACTIVE Closed1 Trap Tank ID TT3376IS, Inspected in 1993. Good Bay 3, Side Sump, Northwest M-096 MIA-301 TT condition. B-325 of B-325 ACTIVE Closed1 Bay 8, Side Sump, Northeast M-097 MIA-301 TT Trap Tank ID TT3377IS B-325 of B-325 ACTIVE Closed1 Trap Tank ID TT3378IS, Inspected in 1993. Good Bay 18, Side Sump, Outside, M-098 MIA-301 TT condition. B-325 Southwest ACTIVE Closed1 M-099 MIA-301 TT Trap Tank ID TT3379IS B-325 Southeast Corner of B-325 ACTIVE Closed1

Northeast Corner on East Side M-100 MIA-301 TT Trap Tank ID TT4350IS B-325 of North/South Head House ACTIVE Closed1 Solvent Recovery, North of B- M-101 MIA-301 TAS RMMU Tank B-325 325 INACTIVE Closed M-102 MIA-301 TAS HWMU-12 Storage Tank B-325 North of B-325 INACTIVE Closed South Central area of building, "C" section, Door N, Inside on M-103 UNGROUPED MA Marshaling Area B-326 Concrete Floor INACTIVE Closed Door R & Q Between Cols 29 M-105 UNGROUPED TT Trap Tank ID TT4030IS B-326 & 28, Outside, South ACTIVE Closed1 M-107 MIA-329 CS HWMU-15 Lugger Pad B-329 East of M-31 INACTIVE Closed M-108 MIA-329 MA Marshaling Areas B-329 Southeast Side, Inside INACTIVE Closed Inside Southeast Corner of B- M-109 MIA-329 PMR Silver Treatment Unit B-329 329. INACTIVE Closed Trap Tank ID TT3329IS. M-110 MIA-329 TT Removed B-329 Southside of B-329 INACTIVE Closed

HWMU-15 Storage Tanks M-111 MIA-329 TAS (Two 270 gal tanks) B-329 Side of M-31 INACTIVE Closed M-112 UNGROUPED MA Marshaling Area B-332 North Side, Inside INACTIVE Closed 90-Day Container Storage M-113 MIA-333 CS Area B-333 South Side INACTIVE Closed South Side, Inside, Bay 4/Bay M-114 MIA-333 MA Marshaling Area B-333 3 INACTIVE Closed M-115 MIA-333 TT M95 Fuel Oil Site B-333 South of B-326, Near M-95 INACTIVE Closed M-116 MIA-333 TT Trap Tank ID TT4100ST B-333 South of B-333 INACTIVE Closed SWMU-10 Solid Waste M-117 MIA-WRL L Landfill B-334 Weiland Road INACTIVE Closed Sump ID SP4060IS,Leachate West of B-334, Intersection of collection system for Latona and Weiland Road, M- M-118 MIA-WRL S WRLF B-334 7 ACTIVE Closed1 North Side, Inside on Concrete M-120 MIA-301 MA Marshaling Area B-337 Floor ACTIVE Closed1 North Side, Inside, on 90-Day Container Storage Concrete Floor on the loading M-121 MIA-329 CS Area B-349 dock, Door J INACTIVE Closed M-122 MIA-329 TT Trap Tank ID TT4025IS B-349 East Side, Outside ACTIVE Closed1 Northeast, Inside, on Concrete M-123 UNGROUPED MA Marshaling Area B-350 Floor INACTIVE Closed M-125 MIA-351 MA Marshaling Area B-351 East, Outside INACTIVE Closed

M-126 MIA-351 PMR Silver Recovery vaults (2) B-352 East of B-352, Inside INACTIVE Closed Transfer Station (Sludge/Caustic) to tank M-128 MIA-351 TS wagons. B-351 West Side of B-351 INACTIVE Closed Transfer Station (Rich M-129 MIA-351 TS Water) B-351 Dock Area-North Bays INACTIVE Closed M-130 MIA-317 TS M43 waste lugger pad B-317 NW Corner of B-317 INACTIVE Closed Southwest Corner of B-317, M-131 MIA-317 TS Lugger Station #317-511 B-317 Outside INACTIVE Closed Spent Solvent (Transfer M-132 MIA-301 TS Station) B-325 North of B-325 ACTIVE Closed1

Drum Pad (Associated with M-133 MIA-301 TS HWMU-13, SWMU M-084) B-323 North of B-323 INACTIVE Closed M-135 MIA-301 TT Trap Tank ID SP3320IS B-302 Out side South, Bay 3 INACTIVE Closed M-136 MIA-301 S Sump ID SP3324IS B-302 Bay 4, Ejector Sump INACTIVE Closed M-137 MIA-301 S Sump ID SP3325IS B-302 Bay 11, Ejector Sump INACTIVE Closed Sump ID SP3326IS, Scrubber sump for A-115 East Side, Outside of Room M-138 MIA-301 S Blender B-302 102-1 INACTIVE Closed M-139 MIA-301 S Sump ID SP3355IS B-303 Bay 3, Ejector Sump ACTIVE Closed1

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 7 of 16 SWMU Master List

E-8 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS

M-140 MIA-301 S Sump ID SP3356IS B-303 Bay 16, Ejector Sump, North ACTIVE Closed1 M-141 MIA-301 S Sump ID SP4005SA B-303 Northwest Corner of B-303 INACTIVE Closed

M-142 MIA-301 CS Empty Drum Storage Area B-325 Outside, East Side of B-325 INACTIVE Closed M-143 MIA-301 CS Drum Storage Area B-337 West of B-337 INACTIVE Closed

M-144 MIA-301 CS Drum Storage Area B-337 West Wall, Outside of B-337 INACTIVE Closed M-145 MIA-329 S Sump ID SP4080IS B-329 South Courtyard INACTIVE Closed

M-146 UNGROUPED S Sump ID SP4000ST B-332 Southeast Corner, Basement ACTIVE Closed1

90-Day Storage (Portable Located near southwest M-148 MIA-351 TAS Lugger) B-351 corner of distillation complex INACTIVE Closed

M-149 UNGROUPED TAS Septic Tank B-306 Northeast of B-306, Outside INACTIVE Closed Underground Storage M-150 MIA-329 UST Tanks B-329 South Courtyard INACTIVE Closed M-151 MIA-333 OBOD M-104 OB/OD's (2) B-333 South of B-326, M-95 INACTIVE Closed

M-152 MIA-308 UST Underground Storage Tank B-322 Tank Farm, South of B-322 ACTIVE Closed1 Underground Storage Tank, (Tank Closed) and M-153 UNGROUPED UST associated piping. B-350 East of B-350 INACTIVE Closed Underground Storage Tanks(5), removed 1992- Outside, Southeast Courtyard. M-154 MIA-333 UST 1993 B-333 B-333 INACTIVE Closed

M-155 MIA-329 UST Underground Storage Tank B-349 Between B-329 and B-349 INACTIVE Closed M-156 MIA-351 RS Release Site B-351 Undetermined SPILL Closed M-157 MIA-329 RS Release Site B-329 South end of west wing SPILL Closed M-158 MIA-333 RS Release Site B-333 Northside of B-333 SPILL Closed Several releases west of M-160 MIA-317 RS Bldg-317 B-317 West End of B-317 SPILL Closed M-161 MIA-317 RS Release Site B-317 East of B-317 SPILL Closed M-162 MIA-308 RS Release Site B-322 B-322 area SPILL Closed M-163 MIA-351 RS Release Site B-351 B-351/B-352 Area SPILL Closed M-164 MIA-301 RS Release Site B-302 East of B-302 SPILL Closed M-165 MIA-301 RS Release Site B-325 B-325 North Courtyard SPILL Closed South of B-325, Several M-166 MIA-301 RS Release Site B-325 releases recorded. SPILL Closed M-167 UNGROUPED RS Release Site B-321 B-321, South SPILL Closed M-169 MIA-351 SI Retention Pond B-352 West of B-352 ACTIVE Closed1 KPM Sanitary Sewer M-170 UNGROUPED SAS System B-300 KPM Park Section ACTIVE Closed1 East, Tank Farm, Sub- M-171 MIA-308 RS Release Site B-307 Basement SPILL Closed Misc. releases to Storm Sewer, and releases from West side of B-312 Tank M-173 MIA-308 RS tank farm B-312 Farm SPILL Closed M-174 MIA-WRL R Release B-334 Near M-32 Tractor Shed ACTIVE Closed1 90-Day Container Storage M-175 MIA-301 CS Area B-304 Inside B-304, West, Bay 14 INACTIVE Closed 90-Day Container Storage Headhouse, Inside East of B- M-176 MIA-301 CS Area B-325 325, on Concrete Floor INACTIVE Closed M-177 UNGROUPED MA Marshaling Area B-321 West Side of B-321 ACTIVE Closed1 90-Day Tube Crushing M-178 UNGROUPED CS Area (Container) B-318 Northwest Side of B-318 NEW OWNER Closed Northwest area of Building, 90-Day Tube Crushing unit, "D" section, Inside on M-179 UNGROUPED CS portable B-326 Concrete Floor, 1st floor INACTIVE Closed M-181 MIA-301 CS Drum Storage Areas B-331 South of B-331 INACTIVE Closed Southwest Corner of B-349, M-182 MIA-329 MA Marshaling Area B-349 Inside INACTIVE Closed M-183 MIA-308 RS Release Site B-308 North of B-308 SPILL Closed Southwest Corner, Inside on M-184 UNGROUPED CS 90-Day Storage Area B-324 Concrete Floor INACTIVE Closed South of B-351 (Near RR M-185 MIA-351 TS Sewer Station B-351 tracks) INACTIVE Closed

Southwest side of B-351/352 M-186 MIA-351 CS Container Storage Area B-351 Complex. on cinder area. INACTIVE Closed M-187 UNGROUPED MA Marshaling Area B-319 Located Inside on concrete. INACTIVE Closed M-188 MIA-317 MA Marshaling Area B-317 M38, Southeast Dock INACTIVE Closed UST (5 tanks) at M95 Fuel M-189 MIA-333 UST Site B-333 At M95 Fuel Site INACTIVE Closed

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E-9 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Storm Sewer Out Fall West of B-349, SPDES Discharge- M-192 UNGROUPED RS Release Site B-349 003. SPILL Closed B-349 Roof on west Side to M-193 MIA-329 RS Release Site B-349 Storm Sewer Below SPILL Closed M-196 MIA-333 RS Release Site B-333 B-333, Bay 15 SPILL Closed Off of the Northeast corner of M-199 MIA-329 RS Release Site B-329 B-329, road/shoulder SPILL Closed M-200 MIA-329 RS Release Site B-329 South end, west wing SPILL Closed M-228 MIA-301 RS Release Site B-304 North of B-304 SPILL Closed Routine and systematic M-235 MIA-317 R release site B-321 Near M-41 fuel tanks SPILL Closed From B-349 passivating area M-240 MIA-329 RS Release Site B-349 (Rm 118C) SPILL Closed

90-Day Container Storage B-325, 1st Floor Head House, M-243 MIA-301 CS Area B-325 adjacent to Marshaling Area ACTIVE Closed1

90-Day Container Storage B-303, 1st Floor Head House, M-244 MIA-301 CS Area B-303 adjacent to Marshaling Area ACTIVE Closed1

M-245 MIA-317 MA Marshaling Area B-317 West end of B-317, Dock PP INACTIVE Closed Northeast corner of B-317, M-246 MIA-317 MA Marshaling Area B-317 Dock N INACTIVE Closed Inside B-325, 1st floor in the 90-Day Container Storage Southeast corner of the M-247 MIA-301 CS Area B-325 building, in the Cold Room INACTIVE Closed B-319, inside on the 1st floor M-248 UNGROUPED MA Marshaling Area B-319 near Door G INACTIVE Closed B-351, outside on the SW M-249 MIA-351 MA Marshaling Area B-351 corner of the Bldg. INACTIVE Closed Draw-off valve which is opened to fill drums - Outside, near the northeast M-250 MIA-351 TS "Screen Pot" B-351 corner of M-77 INACTIVE Closed Transfer Station. Concrete pad draining to IS. It is used for caustic cleaning of B-329, outside near the M-251 MIA-329 TS load luggers. B-329 southeast corner INACTIVE Closed Bldg. 310, inside on the west 90-Day Container Storage side of the building, just off the M-252 MIA-308 CS Area B-310 loading dock. INACTIVE Closed Building 320, Rm 253, Northeast wing of building 90-Day Container Storage (overlooking the interior M-253 UNGROUPED CS Area B-320 courtyard). INACTIVE Closed M-255 MIA-351 RS Release Site B-351 South side of Building 351 SPILL Closed Building 320, loading dock 90-Day Container Storage area in "recycling room", M-256 UNGROUPED CS Area B-320 accessed through door "S" INACTIVE Closed Inside B-308, east of Dock G 90-Day Container Storage in the NE corner of the M-257 MIA-308 CS Area B-308 building. INACTIVE Closed Outside, west side of building 304, where building 331 used 90-Day Container Storage to stand on a concrete M-258 MIA-301 CS Area B-304 foundation. INACTIVE Closed West side of Building 304 (Old M-259 MIA-301 TT Trap Tank B-304 Building 331 pad) INACTIVE Closed 90-Day Container Storage southside of M31, in M-261 MIA-329 CS Area B-329 containment area INACTIVE Closed 90-Day Container Storage Bld 308, 1st floor, near M-262 MIA-308 CS Area B-308 overhead door "J" INACTIVE Closed Decon Pad : with drain to DPI Decon Pad north of shed M-263 MIA-301 TS industrial sewer B-312 M-56, near bld 312 INACTIVE Closed 90-Day Container Storage Outside NE corner of B325 in M-264 MIA-308 CS Area B-325 cinder lot INACTIVE Closed Inside B-308, near docks U and V (south west corner of M-265 MIA-308 MA Marshalling Area B-308 the building) INACTIVE Closed 180-Day Container Storage Area operated by Inside B-308, northwest-side, M-266 MIA-308 CS Nexpress B-308 near door L INACTIVE Closed 180-Day Container Storage Area operated by Inside B-349, East side of M-267 MIA-329 CS Nexpress B-349 building, near door E INACTIVE Closed M-268 MIA-301 TT Trap Tank ID TT3367IS B-304 East of Building 303 ACTIVE Closed1

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E-10 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS 90-Day Container Storage At the northwest corner of the M-269 MIA-308 CS Area B-308 B-308 Train Shed ACTIVE Closed1 90-Day Container Storage Inside room 122, southwest M-270 MIA-301 CS Area B-337 corner of B-337 INACTIVE Closed 90-Day Container Storage M-271 MIA-301 CS Area B-301 B-301 1st floor, center aisle INACTIVE Closed 90-Day Container Storage M-272 MIA-301 CS Area B-301 B-301/302 Courtyard Corridor INACTIVE Closed 90-Day Container Storage Inside B-319, adjacent to M-273 UNGROUPED CS Area B-319 Dock N and O INACTIVE Closed Inside B-319, southwest M-274 UNGROUPED TaS Waste Storage Tank B-319 quadrant of the building INACTIVE Closed M-275 UNGROUPED MA Marshaling Area B-326 B-326 at Loading dock E-1 ACTIVE Closed1 90-Day Container Storage M-276 UNGROUPED CS Area B-350 B-350, on the west dock area INACTIVE Closed 90-Day Container Storage M-277 MIA-329 CS Area B-349 B-349, south side of room 118 ACTIVE Closed1 90-Day Container Storage M-278 MIA-308 CS Area B-322 B-322 Trailer Unloading Area ACTIVE Closed1 B-322 Tanks, TK-682 and TK- M-280 MIA-308 TaS HWMU-33 Tank Storage B-322 675 ACTIVE Closed1 North of B-333 in gravel trailer M-281 UNGROUPED RS Release Site B-333 area SPILL Closed Industrial Sewer components of the Waste Water Treatment Unit W-001 WIA-IS IS located in KPW B-100 KPW Park Section ACTIVE Open1 40' and 60' Silver Recovery W-002A WIA-KPW PMR Clarifiers B-110 B-110 East Side ACTIVE Closed1 70' Silver Recovery W-002B WIA-KPW PMR Clarifiers B-110 North of B-145 ACTIVE Closed1 W-003 WIA-KPW MA Marshaling Area B-112 North of B-112, Inside INACTIVE Closed SWMU-2 KPW Cinder Fill W-005 WIA-KPW L Area B-105 B-105 Southeast Corner INACTIVE Closed W-007 WIA-KPW MA Marshaling Area B-110 B-110 East Side INACTIVE Closed W-008 WIA-KPW PMR Silver Recovery Pit B-110 Center of B-110 ACTIVE Closed1

Sump identified as a Trap East Side of B-111. (Building W-009 WIA-KPW TT Tank, ID TT1300IS B-111 demolished in 1996). INACTIVE Closed W-010 WIA-KPW S Sump ID SP1480IS B-115 North Side of B-115 INACTIVE Closed W-011 WIA-KPW S Sump ID SP1490IS B-115 North of B-115 INACTIVE Closed

W-012 WIA-KPW TS HWMU-03 Transfer Station B-107 East Side- Station 1 INACTIVE Closed

W-013 WIA-KPW TAS HWMU-03 Closed Tanks B-115 B-115 Tank Farm INACTIVE Closed W-016 WIA-KPW TT Trap Tank ID TT1120IS B-117 B-117 South Courtyard INACTIVE Closed Northeast Corner of B-119, W-017 WIA-KPW CS J-wing Lugger Station B-119 Outside INACTIVE Closed Northeast Dock, Door AD/AE, W-018A WIA-KPW MA Marshaling Area B-119 H-wing INACTIVE Closed W-018B WIA-KPW MA Marshaling Area B-119 South, B-Wing Dock INACTIVE Closed W-019 WIA-KPW S Sump ID SP1001IS B-119 B-Wing, Basement INACTIVE Closed Outside Northwest corner of B- W-021 WIA-KPW TS M-wing Station B-119 119 INACTIVE Closed E-wing Station TS # 119- W-022 WIA-KPW TS 419 B-119 Outside Southeast Corner INACTIVE Closed W-023 WIA-KPW TT Trap Tank ID TT1000IS B-119 D-Wing, West INACTIVE Closed W-024 WIA-KPW TT Trap Tank ID TT1005IS B-119 B-119, J-Wing, Outside INACTIVE Closed Outside, West of E-Wing, Side W-025 WIA-KPW TT Trap Tank ID TT1010IS B-119 Sump INACTIVE Closed East Side M-Wing, Bay 10, W-026 WIA-KPW TT Trap Tank ID TT1050IS B-119 Side Sump INACTIVE Closed I-Wing, West Side Sump, W-027 WIA-KPW TT Trap Tank ID TT1060IS B-119 Outside INACTIVE Closed M-Wing, West Side, LEL W-028 WIA-KPW TT Trap Tank ID TT1070IS B-119 Monitor Well INACTIVE Closed W-029 WIA-KPW TT Trap Tank ID TT1122IS B-119 L-Wing, Bay 6, Outside INACTIVE Closed W-030 WIA-KPW TT Trap Tank ID TT1123IS B-119 L-Wing, Bay 8 INACTIVE Closed W-031 WIA-KPW TT Trap Tank ID TT1124IS B-119 D-Wing, East Side Sump INACTIVE Closed

W-032 WIA-KPW TT Trap Tank ID TT1126IS B-119 M-Wing, Bunker, Side Sump ACTIVE Closed1 W-033 WIA-KPW TT Trap Tank ID TT1166IS B-119 J-Wing, West Side Sump INACTIVE Closed W-034 WIA-KPW TT Trap Tank ID TT4090IS B-119 F-Wing, West Trap Tank INACTIVE Closed

W-035 WIA-KPW TT Trap Tank ID TT4200IS B-119 M-Wing, Courtyard, Trap Tank INACTIVE Closed

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 10 of 16 SWMU Master List

E-11 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS

W-036 WIA-KPW TT Trap Tank ID TT4250IS B-119 I-Wing, Courtyard, Trap Tank INACTIVE Closed 90-Day Storage Area Outside, Southeast Corner of W-037 WIA-KPW TAS (Tank) B-119 B-119, E-Wing Vault INACTIVE Closed

W-038 WIA-KPW TAS HWMU-02 Closed Tanks B-119 Outside Southeast of E-Wing INACTIVE Closed

W-039 WIA-KPW TAS Storage Tanks B-119 M-Wing, Outside, Northwest INACTIVE Closed W-040 WIA-KPW DT HWMU-03 Still B-120 Still INACTIVE Closed W-042 WIA-KPW S Sump ID SP1450IS B-120 B-120, Northwest Side ACTIVE Closed1

W-043 WIA-KPW S Sump ID SP1460IS B-120 South of B-120 Bay 11, Inside ACTIVE Closed1 W-045 WIA-KPW S Sump ID SP14856I B-120 B-120 Bay 4 ACTIVE Closed1 Transfer Station TS #120- B-121 Courtyard, North of B- W-046 WIA-KPW TS 264 B-120 121 ACTIVE Closed1

Trap Tank ID TT1350IS. W-047 WIA-KPW TT (Tank has been removed) B-120 B-120 Southwest, Outside INACTIVE Closed

Trap Tank ID TT4100IS. W-048 WIA-KPW TT (Tank has been removed) B-120 B-120 Southwest, Outside INACTIVE Closed

W-049 WIA-KPW TAS HWMU-03 Closed Tanks B-120 Northwest of B-120, Vault 50 INACTIVE Closed Outside of B-120, Vault 50, HWMU-03 Storage Tank/ Outside; Also includes W-050 WIA-KPW TAS Decant Tank B-120 Decanter-Outside; INACTIVE Closed W-051 WIA-KPW TT Trap Tank ID TT1150IS B-122 B-122 North INACTIVE Closed North of B-123, Inside (Building has been W-052 WIA-KPW TT Trap Tank ID TT1250IS B-123 demolished) INACTIVE Closed West Side of B-123, Outside (Building has been W-053 WIA-KPW TAS HWMU-03 Closed Tanks B-123 demolished) INACTIVE Closed W-054 WIA-KPW MA Marshaling Area B-126 B-126 West INACTIVE Closed SWMU-6 Drum Storage W-055 WIA-KPW CS Area B-129 NE of B-129, on Concrete Pad INACTIVE Closed W-056 WIA-KPW MA Marshaling Area B-129 B-129 North Addition INACTIVE Closed 90-Day Container Storage W-057 WIA-KPW CS Area B-130 B-130 South Side INACTIVE Closed South side of the former B-130 W-058 WIA-KPW CS Waste Solvent Lugger Pad B-130 (south of B-148) INACTIVE Closed W-059 WIA-KPW MA Marshaling Area B-130 B-130 Headhouse INACTIVE Closed W-060 WIA-KPW TT Trap Tank ID TT1155IS B-130 South, East Side INACTIVE Closed Side Sump, B-130, Northeast, W-061 WIA-KPW TT Trap Tank ID TT1100IS B-130 East Side INACTIVE Closed Trap Tank ID TT4150IS. Steam Condensate from B- W-062 WIA-KPW TT 148 B-130 B-130 Southeast, Outside INACTIVE Closed

Headhouse (B-130 & 131), W-063 WIA-KPW MA Marshaling Area B-130 Inside Bldg. on Concrete Floor INACTIVE Closed W-064 WIA-KPW TT Trap Tank ID TT1131IS B-131 Northeast of B-131 INACTIVE Closed W-065 WIA-KPW MA Marshaling Area B-132 B-132 Southwest, Outside INACTIVE Closed west side of B-135 to the north W-067 WIA-KPW MA Marshaling Area B-135 of door "R" INACTIVE Closed Inside B-135, North Central W-068 WIA-KPW TT Trap Tank ID TT1135IS B-135 Wall INACTIVE Closed Solvent Room, E, Inside W-069 WIA-KPW TT Trap Tank ID TT1136IS B-135 Building INACTIVE Closed SWMU-6 Syn. Chem. W-070 WIA-KPW CS Container Accumulation B-137 Northeast Corner, Outside INACTIVE Closed East Wall, Lab 5, Outside B- W-072 WIA-KPW TT Trap Tank ID TT1100IS B-137 137 INACTIVE Closed East Wall, Lab 9, Outside B- W-073 WIA-KPW TT Trap Tank ID TT1110IS B-137 137 INACTIVE Closed East Wall, Lab 8, Outside B- W-074 WIA-KPW TT Trap Tank ID TT1125IS B-137 137 INACTIVE Closed East Wall, Lab 7, Outside B- W-075 WIA-KPW TT Trap Tank ID TT1130IS B-137 137 INACTIVE Closed East Wall, Lab 6, Outside B- W-076 WIA-KPW TT Trap Tank ID TT1137IS B-137 137 INACTIVE Closed Outside B-137, Lab 1, East W-077 WIA-KPW TT Trap Tank ID TT1220IS B-137 Wall INACTIVE Closed East Wall, Lab 3, Outside B- W-078 WIA-KPW TT Trap Tank ID TT1230IS B-137 137 INACTIVE Closed

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E-12 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS East Wall, Lab 2, Outside B- W-079 WIA-KPW TT Trap Tank ID TT1240IS B-137 137 INACTIVE Closed East Wall, Lab 4, Outside B- W-080 WIA-KPW TT Trap Tank ID TT1260IS B-137 137 INACTIVE Closed SWMU-5 PCB Storage W-081 WIA-KPW CS Area B-138 Demolished Bldg. 138 INACTIVE Closed W-082 WIA-KPW I SWMU-4 Incinerator B-138 Demolished B-138 INACTIVE Closed

W-083 WIA-KPW MA Marshaling Area B-140 Inside, B-140 Southwest Dock INACTIVE Closed B-140 North Wall Inside W-084 WIA-KPW TT Trap Tank ID TT1140IS B-140 Building INACTIVE Closed SWMU-3 Solid Waste W-087 WIA-KPW I Incinerator B-145 B-145 INACTIVE Closed Wastewater Treatment W-088 WIA-KPW I Plant Sludge Dryer B-145 B-145 West INACTIVE Closed B-145 Southeast Corner W-089 WIA-KPW MA Marshaling Area B-145 Courtyard INACTIVE Closed B-145 Southwest Corner, W-090 WIA-KPW TT Trap Tank ID TT1141IS B-145 Outside INACTIVE Closed W-092 WIA-KPW TT Trap Tank ID TT1145IS B-145 Outside B-145, East Wall INACTIVE Closed B-145 Southeast Corner, W-093 WIA-KPW TT Trap Tank ID TT1146IS B-145 Outside INACTIVE Closed

W-095 WIA-KPW MA Marshaling Area B-148 North Addition, Loading Dock INACTIVE Closed W-096 WIA-KPW TS Transfer Station B-148 B-148 North Side INACTIVE Closed W-097 WIA-KPW TT Trap Tank ID TT1105IS B-148 Outside, North of B-148 INACTIVE Closed W-098 WIA-KPW TT Trap Tank ID TT1165IS B-148 Outside, B-148, South ACTIVE Closed1 W-099 WIA-KPW TT Trap Tank ID TT1170IS B-148 Outside, B-148, South ACTIVE Closed1 W-100 WIA-KPW TT Trap Tank ID TT1180IS B-148 Outside B-148, South ACTIVE Closed1 W-101 WIA-KPW TT Trap Tank ID TT1190IS B-148 Outside B-148, South ACTIVE Closed1 W-102 WIA-KPW TT Trap Tank ID TT1200IS B-148 Outside B-148, South ACTIVE Closed1 W-103 WIA-KPW TT Trap Tank ID TT1210IS B-148 South ACTIVE Closed1 W-104 WIA-KPW TAS HWMU-05 Storage Tank B-148 North Side of B-148 INACTIVE Closed W-105 WIA-KPW MA Marshaling Area B-151 B-151 South Side INACTIVE Closed W-108 WIA-KPW MA Marshaling Area B-155 B-155 East Side INACTIVE Closed W-109 WIA-KPW PMR Silver Recovery B-156 B-156 ACTIVE Closed1 Transfer Station TS #120- W-110 WIA-KPW TS 273 B-120 Southwest of B-120 INACTIVE Closed Transfer Station TS # 110- W-111 WIA-KPW TS 287 B-110 B-110 North Side ACTIVE Closed1

W-112 WIA-KPW TAS HWMU-03 Tank Storage B-115 North of B-115 West of B-107 INACTIVE Closed Transfer Station TS # 101- W-113 WIA-KPW TS 338 B-101 South of B-101 INACTIVE Closed Northeast Corner, Outside B- W-115 WIA-KPW S Sump ID SP1130IS B-117 117 ACTIVE Closed1 W-116 WIA-KPW S Sump ID SP1006IS B-119 Inside F-Wing, Eastside INACTIVE Closed F-Wing, West Trench, Inside W-117 WIA-KPW S Sump ID SP1119IS B-119 West Wall INACTIVE Closed Inside East Wall, F-Wing, East W-118 WIA-KPW S Sump ID SP1121IS B-119 Trench INACTIVE Closed Sump ID SP1125IS; W-119 WIA-KPW S Steam Jet Ejector Sump B-119 Outside, West Wall, E-Wing INACTIVE Closed D-Wing, West Ejector Hot W-120 WIA-KPW S Sump ID SP1128IS B-119 Well INACTIVE Closed

W-121 WIA-KPW S Sump ID SP1260IS B-129 Lab 19 and Lab 21, Outside INACTIVE Closed W-122 WIA-KPW S Sump ID SP1410IS B-143 Outside B-143, South Wall ACTIVE Closed1 Center of B-108 (Building W-123 WIA-KPW S Sump ID SP1420IS B-108 demolished in 1996) INACTIVE Closed

W-124 WIA-KPW CS Drum Storage Area B-134 East and Southeast of B-134 INACTIVE Closed

South Side of B-109 (Building W-125 WIA-KPW S Sump ID SP1400IS B-109 demolished in 1996) INACTIVE Closed W-143 WIA-KPW CS Drum Storage Area B-148 Along South Wall - West INACTIVE Closed W-144 WIA-KPW CS Drum Storage Area B-148 North of B-148 INACTIVE Closed W-145 WIA-KPW CS Drum Storage Area B-148 East of B-148 INACTIVE Closed

W-146 WIA-KPW CS Drum Storage Area B-148 West of B-148 along Railroad INACTIVE Closed B-145 Southwest Corner, W-147 WIA-KPW S Sump ID SP1145IS B-145 Outside INACTIVE Closed Sump - West Shredder W-149 WIA-KPW S Pump; SP2495IS B-145 B-145 Northwest INACTIVE Closed

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 12 of 16 SWMU Master List

E-13 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS Refuse Pit Sump, W-150 WIA-KPW S SP2496IS B-145 North Center B-145 INACTIVE Closed W-151 WIA-KPW S Sump ID SP1380IS B-138 Southeast of B-138 INACTIVE Closed W-152 WIA-KPW S Sump ID SP1390IS B-138 South of B-138 INACTIVE Closed W-155 WIA-KPW S Sump ID SP1430IS B-120 Southwest of B-120 ACTIVE Closed1 W-156 WIA-KPW S Sump ID SP1510IS B-142 Outside, West of B-142 ACTIVE Closed1 Basement East Wall Between W-157 WIA-KPW TT Trap Tank ID TT1320IS B-114 Cols 301 and 302 ACTIVE Closed1 Northeast Corner of B-117 W-158 WIA-KPW S Sump ID SP1117IS B-117 (Room 115) ACTIVE Closed1 W-159 WIA-KPW MA Marshaling Area B-101 East Side of B-101 INACTIVE Closed W-160 WIA-KPW MA Marshaling Area B-102 East Side of B-102 INACTIVE Closed North-Center of B-117, Rm W-162 WIA-KPW S Sump ID SP1116IS B-117 110, Reactor Room East ACTIVE Closed1 W-163 WIA-KPW S Sump ID SP1270IS B-129 B-129 Lab 34 INACTIVE Closed W-164 WIA-KPW S Sump ID SP1280IS B-129 Lab 36, outside INACTIVE Closed W-165 WIA-KPW S Sump ID SP1290IS B-129 Lab 40, outside INACTIVE Closed W-166 WIA-KPW S Sump ID SP1300IS B-129 Lab 44, outside INACTIVE Closed W-167 WIA-KPW S Sump ID SP1310IS B-129 Lab 48, outside INACTIVE Closed Outside B-129, Between Labs W-168 WIA-KPW S Sump ID SP1320IS B-129 20 and 21 INACTIVE Closed W-169 WIA-KPW S Sump ID SP1330IS B-129 Lab 47, outside INACTIVE Closed W-170 WIA-KPW S Sump ID SP1340IS B-129 Lab 43, outside INACTIVE Closed W-171 WIA-KPW S Sump ID SP1350IS B-129 Lab 37, outside INACTIVE Closed W-172 WIA-KPW S Sump ID SP1360IS B-129 Lab 35, outside INACTIVE Closed W-173 WIA-KPW S Sump ID SP1365IS B-129 Labs 9 and 11, outside INACTIVE Closed Silver Recovery Pond. W-174 WIA-KPW PMR (Pond has been filled in) B-110 B-110 Northeast INACTIVE Closed Precious Metals Recovery Filters (Walnut Filter W-175 WIA-KPW PMR System) B-144 B-144 ACTIVE Closed1

West side of B-123 (Building W-176 WIA-KPW UST Underground Storage Tank B-123 has been demolished) INACTIVE Closed Underground Storage W-177 WIA-KPW UST Tank. B-120 B-120 SW Tank Farm INACTIVE Closed Underground Storage B-120 Northwest of Tank W-178 WIA-KPW UST Tank. B-120 Farm INACTIVE Closed Underground Storage Tank W-179 WIA-KPW UST Farm. B-115 East Side of B-120 INACTIVE Closed

W-180 WIA-KPW UST Underground Storage Tank B-142 South of B-142, Tank Farm INACTIVE Closed Underground Storage Tank with Secondary W-181 WIA-KPW UST Containment B-110 East Side of B-110, outside INACTIVE Closed

W-182 WIA-KPW UST Underground Storage Tank B-119 E-Wing, Bunker INACTIVE Closed

W-183 WIA-KPW UST Underground Storage Tank B-119 B-119 Courtyard INACTIVE Closed Underground Storage W-184 WIA-KPW UST Tanks (5 Tanks in Vault) B-119 M-Wing, Bunker INACTIVE Closed W-185 WIA-KPW RS Release Site B-114 North of B-114 SPILL Closed W-186 WIA-KPW RS Release Site B-107 Northeast of B-107 SPILL Closed W-187 WIA-KPW RS Release Site B-145 Northwest Corner SPILL Closed W-188 WIA-KPW RS Release Site B-108 West of B-108 SPILL Closed W-189 WIA-KPW RS Release Site B-110 B-110 SPILL Closed W-190 WIA-KPW RS Release Site B-115 B-115 Tank Farm SPILL Closed W-191 WIA-KPW RS Release Site B-123 B-123 SPILL Closed W-192 WIA-KPW RS Release Site B-119 B-119 North Courtyard SPILL Closed B-119 Central, Under H-Wing, W-194 WIA-KPW RS Release Site B-119 I-Wing and K-Wing SPILL Closed W-195 WIA-KPW RS Release Site B-119 F-Wing and G-Wing SPILL Closed W-196 WIA-KPW RS Release Site B-119 B-119 West Courtyard SPILL Closed W-197 WIA-KPW RS Release # NH00284 B-140 Outside B-140, South Wall SPILL Closed Underground Storage W-198 WIA-KPW UST Tanks (2 X 11,000 gal.) B-119 West of B-119, D-Wing INACTIVE Closed W-200 WIA-KPW RS Railroad System B-151 West Side of KPW SPILL Closed KPW Sanitary Sewer W-201 WIA-KPW SAS System B-100 KPW Park Section ACTIVE Closed1 W-202 WIA-KPW S Sump ID SP1100SA B-129 North Wing-3rd from West INACTIVE Closed W-203 WIA-KPW RS Release Site B-107 Northeast corner of B-107 SPILL Closed 90-Day Container Storage W-204 WIA-KPW CS Area B-119 K-Wing INACTIVE Closed 90-Day Container Storage W-205 WIA-KPW CS Area B-130 Northeast of B-131 INACTIVE Closed

Final SWMU Table Revised for Permit Application 2014 lmt.xlsx Page 13 of 16 SWMU Master List

E-14 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS 90-Day Container Storage W-206 WIA-KPW CS Area B-148 B-148 INACTIVE Closed W-207 WIA-KPW R Rich Water Release B-143 Southwest of B-143 SPILL Closed 90-Day Container Storage W-208 WIA-KPW CS Area B-137 B-137 INACTIVE Closed W-209 WIA-KPW MA Marshaling Area B-117 B-117 Courtyard, in Shed INACTIVE Closed Southeast Corner, B-151, W-210 WIA-KPW MA Marshaling Area B-151 Inside, Loading Dock INACTIVE Closed Drum Excavation Area, Central, H-Wing, I-Wing, K- W-211 WIA-KPW L drums removed B-119 Wing INACTIVE Closed 90-Day Container Storage Outside, West Side of B-129 W-212 WIA-KPW CS Area B-129 (Center) INACTIVE Closed Inside B-117, Room 110 W-213 WIA-KPW S Sump ID SP1118IS B-117 (Reactor Room West) ACTIVE Closed1 W-214 WIA-KPW S Sump WSP117020ISI B-117 Inside B-117, Room 118 ACTIVE Closed1 W-215 WIA-KPW S Sump WSP117024ISI B-117 Door M ACTIVE Closed1 90-Day Container Storage W-216 WIA-KPW CS Area B-135 Inside, North INACTIVE Closed W-217 WIA-KPW TT Trap Tank ID TT1150IS B-145 Outside, South B-145 INACTIVE Closed W-218 WIA-KPW TT Catch Tank B-151 South of B-151 INACTIVE Closed W-219 WIA-KPW TT Catch Tank B-151 South of B-151 INACTIVE Closed

W-220 WIA-KPW S Tunnel Scrubber Sump B-119 Northwest Corner of D-Wing INACTIVE Closed W-221 WIA-KPW S Tunnel Scrubber Sump B-129 Inside Shed D-5 INACTIVE Closed W-222 WIA-KPW S Tunnel Scrubber Sump B-130 West of B-130 INACTIVE Closed W-223 WIA-KPW S Tunnel Scrubber Sump B-131 North of B-130 INACTIVE Closed W-224 WIA-KPW S Tunnel Scrubber Sump B-137 Southwest Corner of B-137 INACTIVE Closed W-225 WIA-KPW S Tunnel Scrubber Sump B-119 Southeast end of B Wing INACTIVE Closed TENANT W-226 WIA-KPW MA Marshaling Area B-117 Inside B-117, Room 164G CONTROL Closed North side, near railroad W-228 WIA-KPW RS Release Site B-107 tracks SPILL Closed Railroad tracks southwest Southwest corner; in the W-232 WIA-KPW RS of B-109. B-109 railroad yard SPILL Closed W-233 WIA-KPW RS Release Site B-109 North, near B-108 SPILL Closed W-238 WIA-KPW RS Release Site B-119 East side; center dock SPILL Closed West side, near center of the W-244 WIA-KPW RS Release Site B-132 Bldg SPILL Closed W-252 WIA-KPW RS Release Site B-140 North side of building SPILL Closed W-253 WIA-KPW RS Release Site B-140 Northwest SPILL Closed W-255 WIA-KPW RS Release Site B-140 Northeast corner SPILL Closed 90-Day Container Storage W-258 WIA-KPW CS Area B-110 Southwest side of B-110 INACTIVE Closed

90-Day Container Storage Center of B-116 at D-32 which W-259 WIA-KPW CS Area B-116 is a dock attached to B-116 ACTIVE Closed1

90-Day Container Storage H-Wing Cold Room in B-119 W-260 WIA-KPW CS Area B-119 and south wall spotting area INACTIVE Closed SE Corner of B-143, inside W-261 WIA-KPW MA Marshaling Area B-143 loading dock area INACTIVE Closed

Pumping wells on the North side of B-119. Approximated SWMU location shown on map. Specific site was not W-262 WIA-KPW RS Release Site B-119 documented. SPILL Closed W-263 WIA-KPW MA Marshaling Area B-110 B-110, Rm 128 INACTIVE Closed 90-Day Container Storage W-264 WIA-KPW CS Area B-148 Bldg. 148 North of Building INACTIVE Closed 90-Day Container Storage W-265 WIA-KPW CS Area B-119 Bldg. 119 North Court Yard INACTIVE Closed

Surge Tank STK-77 used to collect relief valve discharge W-266 WIA-KPW TAS 90-Day Tank Storage B-115 on pipeline 20 inside B-115 INACTIVE Closed Surge tank STK-64, used to collect a variety of streams in W-267 WIA-KPW TAS 90-Day Storage Tank B-120 B-120 ACTIVE Closed1 90-Day Container Storage Located on the former B-102 W-268 WIA-KPW CS Area B-102 floor slab INACTIVE Closed

B-101 exhaust stack. Located W-269 WIA-KPW RS Release Site B-101 between B-101 and B-110 INACTIVE Closed 90-Day Container Storage North of B-101, and west of B- W-270 WIA-KPW CS Area B-101 145 INACTIVE Closed

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E-15 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS 90-Day Container Storage W-271 WIA-KPW CS Area B-110 Bld 110, Room 129 INACTIVE Closed Building 101, under B-101 W-272 WIA-KPW MA Marshaling Area B-101 stack area INACTIVE Closed W-273 WIA-KPW MA Marshaling Area B-148 B-148, Door M ACTIVE Closed1 W-274 WIA-KPW RS Release Site B-156 B-156, south side SPILL Closed Industrial Sewer components of the Waste Water Treatment Unit X-001 XIA-IS IS located in KPX B-200 KPX Park Section ACTIVE Closed1

Former Open Burn & Vicinity of B-202, B-215 and B- X-004 XIA-202 OBOD Refuse Management Site B-202 217 INACTIVE Closed

Was formerly located in the center of B-202. Building 202 has been demolished, so this is now just the site. Building X-005 XIA-202 PMR Silver Recovery Burner B-202 demolished April, 2002 INACTIVE Closed

X-006 UNGROUPED CS HWMU-22 Drum Storage B-203 B-203 East, Inside INACTIVE Closed X-007 UNGROUPED MA Marshaling Area B-203 B-203 Northwest Side INACTIVE Closed X-009a UNGROUPED MA Marshaling Area B-205 B-205 East Side, Inside INACTIVE Closed X-009b UNGROUPED MA Marshaling Area B-205 B-205 West Side, Inside INACTIVE Closed X-010 UNGROUPED TT Trap Tank ID TT2000IS B-205 B-205 Southeast INACTIVE Closed

X-011 UNGROUPED TT Trap Tank ID TT2205IS B-205 B-205, East Center, Outside INACTIVE Closed X-013 UNGROUPED TT Trap Tank ID TT2206IS B-206 Northwest of B-206 INACTIVE Closed X-014 UNGROUPED MA Marshaling Area B-207 B-207 Southwest Corner INACTIVE Closed X-016 UNGROUPED MA Marshaling Area B-209 B-209 Center INACTIVE Closed North of Current B-202 and B- X-017 XIA-202 CS Drum Storage Area B-210 217 Site Building 202 INACTIVE Closed SWMU-07 B-210 Drum X-018 XIA-202 I Decontaminator B-210 Northeast of B-202 INACTIVE Closed HWMU-08 Storage Area (Container), Exempt and X-020 XIA-208 CS permitted B-212 Inside, B-212 INACTIVE Closed

X-022 XIA-208 CS HWMU-08 Drum Storage B-212 Inside, B-212 INACTIVE Closed B-212, Metal Salvage Yard on X-023 XIA-208 WP Salvage Yard B-212 Cinder Base. INACTIVE Closed X-024 XIA-208 SI Truck Wash Station B-213 South East of B-213 INACTIVE Closed X-025 XIA-208 MA Marshaling Area B-213 B-213 Outside, North Side INACTIVE Closed 90-Day Container Storage B-218 Northwest, Outside, on X-028 XIA-218 CS Area B-218 Concrete INACTIVE Closed

X-030 XIA-218 CS HWMU-07 Drum Storage B-218 B-218 Indoor ACTIVE Closed1 HWMU-07 Container X-031 XIA-218 CS Storage B-218 Northeast of B-218, Outside ACTIVE Closed1 X-033 XIA-218 I HWMU-07 Rotary Kiln B-218 B-218 INACTIVE Closed Tank Farm Trailer Station with secondary X-034 XIA-218 TS containment B-218 Trailer station west of B-218 INACTIVE Closed X-035 XIA-218 TS Transfer Station B-218 Northwest of B-218 INACTIVE Closed X-036 XIA-218 TT Trap Tank ID TT4075IS B-218 West of B-218 INACTIVE Closed HWMU-07 Closed Storage X-037 XIA-218 TAS Tanks B-218 B-218 Northwest INACTIVE Closed HWMU-07 Receiving X-038 XIA-218 TAS Tanks B-218 B-218 (outside west wall) INACTIVE Closed

X-039 XIA-218 TAS HWMU-07 Storage Tanks B-218 B-218 Northwest INACTIVE Closed X-040 XIA-218 TS West Lugger B-218 B-218 INACTIVE Closed X-041 XIA-218 TS Sewer Station B-218 South of B-218 ACTIVE Closed1 Sewer Station TS #202- X-042 XIA-202 TS 326 B-202 South west of B-202 INACTIVE Closed X-043 XIA-218 TS East Lugger B-218 B-218 INACTIVE Closed X-046 UNGROUPED TAS Storage Tanks B-209 North of B-209 INACTIVE Closed

X-048 XIA-218 UST Underground Storage Tank B-218 West side of B-218 INACTIVE Closed X-049 UNGROUPED RS Release # DC00016 B-203 Southwest of B-203 SPILL Closed X-051 UNGROUPED RS Release Site B-205 Northeast side of B-205 SPILL Closed X-052 XIA-218 RS Release Site B-218 West of B-218 SPILL Closed KPX Sanitary Sewer X-053 UNGROUPED SAS System B-200 KPX Park Section ACTIVE Closed1 X-054 UNGROUPED RS Release Site B-207 B-207 SPILL Closed

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E-16 Attachment E - Corrective Action Requirements Eastman Business Park : SWMU Master List

UNIT BUILDING OPERATIONAL CORRECTIVE ACTION ID INVESTIGATION AREA GENERAL DESCRIPTION LOCATION NOTES TYPE NUMBER STATUS STATUS

X-057 XIA-208 CS Container Crushing Area B-213 Southeast of B-213. INACTIVE Closed X-059 XIA-208 TS Wash Pad B-213 East of B-213 INACTIVE Closed X-061 UNGROUPED RS H-42 Train Fueling Area B-202 West side of shed H-42 SPILL Closed X-064 UNGROUPED RS Release Site B-205 Northwest side of B-205 SPILL Closed X-065 UNGROUPED RS Release Site B-205 West side center of B-205 SPILL Closed X-066 UNGROUPED RS Release Site B-206 Northeast of B-206 SPILL Closed X-067 UNGROUPED RS Release Site B-216 East of B-216 SPILL Closed IMM Purchasing, Investment Recovery Dept., Bldg. 205 90-Day Container Storage (inside), Room C, near Dock X-069 UNGROUPED CS Area B-205 16 INACTIVE Closed Bldg. 205 Loading Dock on 90-Day Container Storage the South West end of the X-070 UNGROUPED CS Area B-205 building INACTIVE Closed South of B-218 and 90-Day Container Storage coincidental with former B-213 X-071 XIA-208 CS Area B-213 site INACTIVE Closed X-073 UNGROUPED MA Marshaling Area B-205 B-205, West Side, Dock 55 INACTIVE Closed 90-Day Container Storage B-218 at the north side loading X-074 XIA-218 CS Area B-218 dock ACTIVE Closed1

90-Day Container Storage Decontamination and Disposal X-075 XIA-208 CS Area B-213 Facility, south of former B-213 ACTIVE Closed1 Notes: 1. Closed - previously designated as No Further Action ("NFA"). Releases from these units have been evaluated and remedies have been implemented where necessary. Unit is no longer in active service. 1 2. Closed - previously designated as No Further Action ("NFA"). Releases from these units have been evaluated and remedies have been implemented where necessary. Unit remains in active service and potentially subject to corrective action in event of future release. Unit subject to decommissioning inspection when removed from active service. Corrective action in event of future release is Permittee responsibility. 1 3. Open - "Pre-existing contamination" from SWMU is active EBP-ET obligation per Exhibit B-3. However, unit remains in active service and potentially subject to corrective action in event of future release. Unit subject to decommissioning inspection when removed from active service. Corrective action in event of future release is RED responsibility. 2 4. Open - "Unit is inactive. "Pre-existing contamination" from SWMU is active EBP-ET obligation per Exhibit B-3.

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E-17 ATTACHMENT F

PROCEDURES TO PREVENT HAZARDS

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

Table of Contents

Attachment F: Procedures to Prevent Hazards (HWMU-32 & HWMU-33)

Appendices

Appendix F-1: Inspection Schedule (HWMU-32 & HWMU-33)

Appendix F-2: Sample Inspection Forms (HWMU-32 & HWMU-33)

F1

Attachment F: Procedures to Prevent Hazards

Building 95 Multiple .Hearth Incinerator Operated by RED (HWMU-32) & Building 322 Hazardous Waste Storage Tank System Operated by Kodak (HWMU-33)

Provided below are the sections/items off of the checklist that pertain to HWMU-32 & HWMU-33, outlining the procedures used to prevent hazards for those particular hazardous waste management- units at the Eastman Business Park facility. Overall Kodak is responsible for security at both permitted units and at EBP in general.

F-1a(2)(a) Barrier

The active portions of HWMU 32 & HWMU-33 are completely enclosed with a chain link fence, by building walls, by natural barriers, by controlled entry [Section F-1a(2)(b)] or by another similar and suitable, barrier preventing unauthorized access to the HWMUs.

F-1a(2)(b) Means to Control Entry

A 24-hour surveillance system (e.g., television monitoring or surveillance by guards or facility personnel) that continuously monitors and controls entry onto the active portion of the facility, including Building 322 in the KPM section of Eastman Business Park (HWMU-33). . . Access to Building 95 at King's Landing (HWMU-32) is only allowed through an entrance that is electronically monitored with a security camera 24 hours/day, 7 days/week.

F-1a(3) Warning Signs

Warning signs that are legible from a distance of 25 feet are posted at the HWMUs. There is no smoking allowed within the Eastman Business Park facility except in designated areas specifically selected or arranged for this purpose, and all facility entrances are posted with signs indicating "No Smoking Beyond This Point". All signs are in English; there is no requirement for bilingual signs in Monroe County.

F-2c Remedial Action

Any deteriorated or malfunctioning equipment revealed during an inspection will be repaired or replaced in an appropriate time frame, or the equipment will be removed from service. Where an

F2 environmental and/or human health hazard is imminent, the response will take place immediately. Where a spill or environmental and/or human health hazard has occurred, spill response procedures described in Attachment G will be followed for remedial action.

F-3a(1)(2) Internal and External Communications

HWMU-32 and HWMU-33 have communication systems and alarms that are capable of providing emergency instruction/notification in case of an emergency situation.

F-3 a(4) Water for Fire Control .

Eastman Business Park has a water system owned and operated by RED that services fire control and provides water at an adequate volume and pressure to supply water hose streams. Building 95 (HWMU-32) has an internal sprinkler system for portions of the building and outside responders would-provide any additional control measures needed. In addition, Building 322 (HWMU-33) in the West Distilling complex is equipped with an automatic fire suppression system, as well as a hardwired Emergency Shutdown System (ESD). The ESD automatically shuts down all equipment within the West Distilling complex when it is activated by pushing one of the approximately dozen dedicated buttons located throughout the complex.

F-4d Equipment and Power Failure

In the event of a power failure at HWMU-32, "fail-safe" operation of fuel feed equipment and combustion air equipment would stop the transfer of waste and/or fuel. In the event of a power failure at HWMU-33, all equipment would be shut down to a “fail-safe” state.

F-4e Personal Protective Equipment (PPE) Handling of the HWMU-32 and HWMU-33 waste streams does not require any special PPE.

F3

ATTACHMENT F - APPENDIX F-1

INSPECTION SCHEDULE (HWMU-32 & HWMU-33)

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSINESS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497.

F4 F5 F6 F7 F8 F9

ATTACHMENT F - APPENDIX F-2

SAMPLES INSPECTION FORMS (HWMU-32 & HWMU-33)

EASTMAN KODAK COMPANY and RED-ROCHESTER, LLC EASTMAN BUSIENSS PARK HAZARDOUS WASTE MANAGEMENT FACILITY EPA ID NUMBER NYD 980592497

F10 Appendix F-2 Sample Inspection Forms (HWMU-33)

Unit No: Condition No: Record ID: Schedule: Time Period: HWMU-33 HWMU-33.TAS-Employee 2009-12-31 Daily 12/31/2009 Requirement Daily storage tank inspections

Last Update:

Monitoring Description Hazardous Waste Storage Tank System Tank 675 and 682

F11 F12 F13 F14 F15 F16