OQ5!003

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401 E. Fifth St.Dayton, Ohio 45402

State of Ohio Environmental Protection Agency

Southwest District OfficeTELE: 937) 265-6357 Fc: (937) 2e55249

vAvw.eta state ohusTed Strickland, Governor

Lee Fisher, Lieutenant GovernorChris Korleski, Director

August 20, 2008

Mr. James HolycrossService-Safety DirectorCity of Bellefontaine135 North Detroit StreetBellefontaine, Ohio 43311

Dear Mr. Holycross:

Ohio EPA is writing this letter in an attempt to obtain a more detailed response to ourNotice of Violation (NOV) letter dated June 13, 2008 regarding hazardous wasteviolations discovered during our May 20, 2008 inspection. Jamie Aldo responded to ourJune 13, 2008 NOV on July 9, 2008, but did not provide sufficient detail to satisfy ourquestions and concerns. To summarize, Ohio EPA needs the City of Bellefontaine toprovide the following specific information:

Provide specific information regarding the occurrence(s) when hazardous wastegenerated by the City of Bellefontaine was transported to the Logan County Solid WasteManagement District's household hazardous waste collection location. For example,provide the number of times this occurred and provide specific or estimated dates whenthese activities occurred. Also provide a specific or estimated quantity of hazardouswaste that was delivered for each of these occurrences.

I am providing you with a copy of both letters for your review. Your response is requiredwithin 30 days upon your receipt of this letter.

In Mr. Aldo's letter of July 9, 2008, he indicates that the Logan County Solid WasteManagement District (LCSWMD) picked up the paint from the City of Bellefontaine forproper disposal. Alan Hale with LCSWMD informed me during a July 24, 2008telephone conversation, that LCSWMD did not transport this waste. Please be advisedthat regardless of who transported the hazardous waste in 2007, it still is a violation ofOhio Revised Code 3734.02(F) [refer to violation 2 identified in Ohio EPA's June 13,2008 NOV] and needs to be addressed.

Pnnted on Recyded Paper Ohio EPA is an Equal Opportunity Employer Printed in-house

. I-L-1

Mr. James HolycrossAugust 20, 2008Page 2

Please call me at (937) 285-6091 if you have any questions.

Sincerely,

Pam HullDistrict RepresentativeDivision of Hazardous Waste Management

Enclosures

cc: Dinah Crawford, SWDO-DHWM/SWDO file\SWDO-file: City of Bellefontaine, Logan County, 0HR000015305

Alan Hale, Logan County Solid Waste Management District (LCSWMD)Logan County Commissioners (do LCSWMD)

PH\bp

NOTICE:Ohio EPA's failure to list specific deficiencies or violations in this letter does not relieveyour comDanv from havin q to comply with all applicable regulations.

0

MbEPAState of Ohio Environmental Protection Agency.

Southwest District40 East Fifth Street TELE: (937)265.6357 FAX (937)265.6249 Ted Strickland, GovernorDayton, Ohio 45402-2911 wwe0as121e.DtLjs Lee. Fisher, Lieutenant Governor

Chris Korleski, Director

June 13, 2008

Re:. City of BeI!efontaineOHR0000I 5305Logan County, SWDONOV

Mr. Jamie AldoStreet SuperintendentCity of.Beflefontaihe135 North Detroit StreetBellefontaine. ON 43311

Dear Mr. Aldo:

Thank you for accompanying Tom Ontko and me during Ohio EPA's May 20, 2008 inspection of theCity of Bellefontaine's Street Department (CoBSD). We inspected CoBSD Department to determineits compliance with Ohio's hazardous waste laws as found in Chapter 3734. of the Ohio RevisedCode (ORC) and Chapter 3745. of the Ohio Administrative Code (OAC). During the inspection wealso informed you that we would send info regarding water-based street paint in order to preventpollution by reducing waste.

We found the following violations of Ohio's hazardous waste laws. In order to correct theseviolations you must do the following and send me the required information within 30 days of yourreceipt of this letter:

OAC Rule 3745-52-11, Waste Evaluation: Any person who generates a waste mustevaluate the waste to determine if the waste is a hazardous waste in accordance with thecriteria set forth in OAC Chapter 3745-51.

CoBSD has failed to determine if the waste solvent containing xylene generated from thecleaning of its oil based street paint spray gun/line is a hazardous waste. Based on OhioEPA's review of information about the solvent that is used, this waste is a listed hazardouswaste (F003, see attached OAC rule 3745-51-31), and CoBSD stores it in 5 gallon bucketsin the garage on the east side of the property.

CoBSD must confirm that the waste generated is a listed hazardous waste (F003) and mustimmediately evaluate this waste to determine if it is also a characteristic hazardous waste asrequired by OAC 3745-52-11. Once CoBSD has made this determination, you must sendme the documentation. I'm sending you a list of permitted hazardous Waste treatment,storage and disposal facilities (TSDFs) for your reference.

2. Ohio Revised Code 3734.02(F)-Generator must ensure delivery of a hazardous wasteto a permitted TSDF: A person shall store, treat, ordispose of hazardous wasteregardless of whether generated on or off the premises where the waste is stored, treated,or disposed of, or transport or cause to be transported any hazardous waste... to any otherpremies, except .... to a hazardous waste facility operating under a permit.

Prthrnd on ReWYCISPRDBT Ohio EPA is an Equal Ooportunity Employer Printed in-house

.

is

Mr. Jamie AldoCity of Bellefontaine Street DepartmentJune 10, 2008Page 2

CoSBD transported the listed hazardous waste described above at Logan County SolidWaste Management District (LCSWMD). LCSWMD is not a permitted TSDF.

CoSBD must immediately cease transporting their hazardous waste at LCSWMD. Pleaserefer to the list of permitted TSDFs enclosed and transferldispose of your hazardous wasteat the TSDF(s) of your choice. CoSBD must describe its plans for sending its waste to apermitted TSDF in the future. Also, CoSBD must provide information regarding frequencyand quantities of your listed hazardous waste that you transported to LCSWMD.

As we discussed during the inspection, you may be able to eliminate the hazardous waste CoSBDroutinely generates from traffic paint by switching to water-based paint. I'm including informationregarding case studies and paint vendors for you to review. I'm encouraging you make this switchas soon as possible given the severity of the violations identified above. Please respond regardingyour research into this information to me within 30 days of your receipt of this letter along with theinformation requested associated with the two violations identified above.

If you would like more information about pollution prevention or have any questions, please contactme at (937)285-6091. Ohio EPA has helpful information about this at the following web address:http://wwwepa.state.oh.us/oca pp/oca pp/. Additionally, you can find copies of the rules and otherinformation on the division's web page at: http://www.epa.state.oh.us/dhwm/.

Sincerely,

Pam HullDistrict RepresentativeDivision of Hazardous Waste Management

Enclosures

cc: fileSWDO-file: City of Bellefontaine, Logan County, OHR0000I 5305

PH/plh

NOTICE:

Ohio EPA's failure to list specific deficiencies or violations in this letter does notrelieve your company from having to comply with all applicable regulations.

Industry andEPA hazardouswaste Hazardous waste

Hazardcode

ACTION: Final

DATE: 09/07/2004 8:04 AM

3745-51-31 Hazardous waste from non-specific sources.

(A) The following table lists hazardous wastes from non-specific sources, along with industryand EPA hazardous waste numbers and hazard codes for these hazardous wastes:

(T)The following spent halogenated solvents used in degreasing:tetrachloroethylene, trichioroethylene, methylene chloride,1,1,1 -trichloroethañe, carbon tetrachloride, and chlorinatedfluorocarbons; all spent solvent mixtures/blends used indegreasing containing, before use, a total of ten per cent ormore (by volume) of one or more of the above halogenatedsolvents or those solvents listed in P002, P004, and P005; andstill bottoms from the recovery of these spent solvents andspent solvent mixtures.

The following spent halogenated solvents:tetrachloroethylene, meth ylene chloride, trichloroethylene,1,1,1 -trichloroethane, chlorobenzene, 1,1 ,2-trichloro- 1,2,2-trifluoroethane, orthodichlorobenzene,trichlorofluoromethane, and 1,1,2-trichioroethane; all spentsolvent mixtures/blends containing, before use, a total oftenper cent or more (by volume) of one or more of the abovehalogenated solvents or those listed in FOOl, F004, or P005;and still bottoms from the recovery of these spent solventsand spent solvent mixtures.

The following spent non-halogenated solvents: xylene,acetone, ethyl acetate, ethyl benzene, ethyl ether, methylisobutyl ketone, n-butyl alcohol, cyclohexanone, andmethanol; all spent solvent mixtures/blends containing,befbre use, only the above spent non-halogenated solvents;and all spent solvent mixtures/blends containing, before use,one or more of the above non-halogenated solvents, and, atotal often per cent or more (by volume) of one or more ofthose solvents listed in FOOl, P002, P004, and F005; and stillbottoms from the recovery of these spent solvents and spentsolvent mixtures.

Generic:

P001

P002

P003

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(I)

(T)P004 The following spent non-halogenated solvents: cresols andcresylic acid, and nitrobenzene; all spent solventmixtures/blends containing, before use, a total of ten per centor more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in FOOl, P002,and P005; and still bottoms from the recovery of these spent

- solvents and spent solvent mixtures.

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Ohio Commercial Facilities Accepting Hazardous Wasteupdated August 2006

_________________ Address . Jelephone/lax Managernent Aity,,

Agmet Metals, Inc. 7800 Medusa Street (440) 439-7400 Metals Recovery

OF-1D986976348 Oakwood Village, Ohio44146 (440) 439-7446www.agmetnietals.com

BizMat Center 1085 Sweitzer Road (330) 535-6677 Storage/Transfer

OHR000128108 Akron, Ohio 44301 / ONLY accepts waste

www.bizmatcenter.org (330) 535-2577 from CESQGs inSummit, Stark, Medina,Portage, and Trumbullcounties

Chemical Solvents 1010 Old Denison Avenue (216) 741-9310 Solvent Recycling, Fuel

0HD980897656 Cleveland, Ohio 44109 / Blending

www.chemicalsoIvents.com (216) 741-4080

Chemtron Corporation 35850 Schneider Court (440) 937-6348 Solvent Recycling, Fuel

OHD066060609 Avon, Ohio 44011 / Blending, Mercury

www.chemtron-corp.com (440) 937-6845 Recovery

Clean Harbors of 2900 Rockefeller Avenue (216) 429-2402 Chemical Reduction,

Cleveland Cleveland, OH 44115 / Chemical Precipitation

OH0000724153 www.cleanharbors.com (216) 883-1918

Envirite Corporation 2050 Central Avenue SE (330) 456-6238 Chemical Precipitation,

0H0980568992 Canton, Ohio 44707 / Chemical Treatment

www.envirite.com (330) 456-2801

Environmental 4650 Spring Grove Avenue (513) 541-1823 Fuel Blending,

Enterprises Inc. Cincinnati, Ohio 45232 / Aqueous Organic &

OHD083377010 www.eeienv.com (513)541-1638. Inorganic Treatment,Stabilization

Envirosafe Services of 876 Otter Creek Road (800) 537-0426 Landfill

Ohio Oregon, Ohio 43616OHD045243706 www.enso.net/esoi.html (419) 698-8663

General Environmental 2727 Transport Road (866) 436-2677 Aqueous Organic &

Management Cleveland, Ohio 44115 / Inorganic Treatment

0HD00417861 2 www.qemenv.cc (216) 9023361

Hukill Chemical 7013 Krick Road (440) 232-9400 Fuel Blending, Solvent

Corporation Bedford, Ohio 44146 / Recycling

0HD001926740 www,hukiIt.com (440) 232-9477

Klor Kleen Inc. 3118 Spring Grove Avenue (513) 681-9990 Storage/Transfer

0HD980821862 Cincinnati, Ohio 45225www. midwestenvironmental (513) 681-1185services.conl

k' 4 '' •••j•._

P!!PYu,.t 6* Wtts#g,&Onyx Environmental 4301 Infirmary Road (937) 859-6101 Fuel Blending, Solvent

Services West Carrollton, Ohio I Recycling

0HD093945293 45449 (937) 859-6242

www.onyxes.com

Perma-Fix of Dayton 300 S West End Avenue (800) 543-3670 Storage/Transfer,

0HD004274031 Dayton, Ohio 45427 I Aqueous Treatment

www.perma-fix.com/dayton (937) 268-5734

Reserve Environmental 4633 Middle Road (440) 992-2162 Wastewater Treatment

0HD980793384 Ashtabula, Ohio 44004(440) 992-9262

Ross Incineration 36790 Giles Road (440) 728-2200 Incineration

Services Grafton, Ohio 44044 10RD048415665 www.rossenvironmental.com (440) 728-1339

Safety-Kleen Systems 581 Milliken Drive BE . (740) 929-3532 Solvent Recycling

Inc Hebron, Ohio 43025OHD980587364 .wwwsafety-kleen.com (740) 928-1347

Spring Grove Resource 479 Spring Grove Avenue (513) 681-6242 Fuel Blending,

Recovery Cincinnati, Ohio 44115 / Stabilization, Aqueous

01-40000816629 www.cIeanharbors.com (513) 681-6246 Treatment with CarbonAdsorption

Systech Environmental 11397 County Road 176 (419) 399-4835 Fuel Blending

Corporation Paulding, Ohio 45879OHD005048947 www.sysenv.com (419) 399-4676

Vickery Environmental 3956 State Route 412 (419) 547-7791 Underground Injection

01-10020273819 Vickery, Ohio 43464www.wm.com (419) 547-6144

Von Roll America, Inc. 1250 Saint George Street (330) 385-7336 Incineration

0HD980613541 East Liverpool, Ohio 43020www.vonrollwti.com (330) 386-2160

C->>>KPa,e Foulkes! 5/29/2008 11:32 AM >>>Pam,

Yes, here is some more information you can forward to them. If they need

ng elseor have questions, feel free to send them to 's

i-cc--- 2

Water-borne traffic paint resources

I know of two efforts nationally to identify environmental criteria for ready-mixed,waterborne acrylic traffic line paint that can be applied to either asphalt concrete orportland cement concrete pavements. One was a 1997 project by the Department ofDefense and U.S. EPA, the Environmentally Preferable Pilot Parking Lot Project.Another was a 2003 study by INFORM comparing state government specifications fortraffic paint. The environmental criteria from these two efforts basically pointed to thefollowing criteria:

-Water-based-Lead free-Chromate free-125-150 gIL VOC Content (max)-Complying with State air quality laws at the time

Sample Specifications for Traffic PaintIn 2004, the Alameda County General Services Agency used the following language intheir specifications for the Public Works Agency's Paint/Traffic Stripes Request forQuote.

Paints shall conform to all applicable Federal, State and local regulations for air pollutioncontrol, including but not limited to the South Coast Air Quality Management District Rule1113 regarding The Architectural Coatings and State Implementation Plan for Californiawhich contains rules limiting the content of VOC in traffic coatings to one hundredtwenty-five (125) grams per liter.

All ready-borne, rapid dry paint, white, yellow, red, green and black shall be chromiumfree and shall not contain any hazardous materials at levels that would cause the paint(when dry) to be classified as hazardous waste under Title 22, Division 4, Section6621.20 of the California Code of Regulations (CCR).

Paving the Road to Success - The Department of Defense's Parking Lot Repair andMaintenance Contract: An Environmentally Preferable Purchasing Case Studyhttp://www.epa.gov/oppt/epp/pubs/case/epr)dodl,pdf

Cincinnati's Conversion to Waterborne Paint

Beginning in 1994, as part of the City's pollution prevention efforts, the Department ofPublic works' Highway Maintenance Division converted from solvent- based paints towaterborne paints for highway line striping. To accomplish this, the city conductedresearch, converted equipment, purchased new equipment, and trained managers andpainting crew employees.

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The waterborne paints have significant environmental advantages. This projecteliminated the harmful cleaning solvents and resulting hazardous waste generated fromthe cleaning process. Hazardous waste disposal resulting from the paint residues andempty paint drums was eliminated. The paints no longer contained Jead, cadmium andother heavy metals. Lastly, this process produced significantly lower emissions of VOCsfrom both yellow and white paints (well below the levels U.S. EPA indicated to be theanticipated new standard).

The use of toxic materials and hazardous waste has been eliminated totally by thisconversion. Based on an estimated annual use of 22,000 gallons of line stripe paints,approximately 33,000 pounds of lead and approximately 36,000 pounds of V005 havebeen eliminated from Cincinnati's environment annually.http://wwepa. state. oh. usfopp/fact39.pdf

Water-Borne Traffic Paint Vendor Information*The mention of any company names, products or services does not constituteendorsement or recommendation for use by Ohio EPA.

Franklin Paint Company, Inc.259 Cottage StreetFranklin, MA 02038800-486-0304http:/fwww.franklinpaint.com/category/traffic/waterborne/waterborne.html

Ennis Paint Inc.1509 S. Kaufman St.Ennis, TX 75119214-874-7200http://www.ennispaint.com/Products/product.asp?ID=l

*Ennis Paint's has a White Paper on water-borne traffic paint titled, Durable Water-BorneAcrylic Pavement Markings. It's available at http://w.roadtraffic-technology.com/downloads/whitepapersfroad-marking/fiIeS3/

Allstates Coatings CoP.O. Box 1633100 Lee StreetGladewater, TX 75647800-358-3020Fast-Dry Acrylic Waterborne Traffic Painthttp://v,nm,v.alistatescoatings.com/main.htmi

Sherwin-WilliamsSetfast® Waterborne Traffic Painthttp://www2.sherwin-williams.com/apps/PickPros/SWDisplay.asp?ProdlD=42http://www2.sherwin-williams.com/im/bridciehighway/default.asp

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Selecting a Treatment/Storage/DisposalMay 2007 Facility (TSDF) to Handle Your

Hazardous WastesIntroduction

Many business owners think thatonce their hazardous waste ishauled away, they have no furtherresponsibility for it. This is not so.Under the RCRA 1 regulations, you(the "generator") are responsible foryour hazardous wastes from 'cradleto grave." This means that yourbusiness can be held responsible fora cleanup or pursued in an enforce-ment action if your hazardous wasteis mismanaged by a company, evenafter it leaves your oropertv.

Therefore, it is important you selecta qualified treatment, storage and/ordisposal facility (TSDF) to acceptyour company's hazardous wastes.This fact sheet provides somegeneral guidelines in selecting aTSDF and the resources availablethrough Ohio EPA to help you inmaking this important decision.

Permitting Activities andCompliance Record

Any facility that accepts hazardouswaste for treatment, storage ordisposal must have an Ohio EPApermit for these activities. Thepermit authorizes the types of waste

1 Resource Conservation and RecoveryAct (RCRA) of 1976- provides theframework for EPA's hazardous wastemanagement program and regulations.

the TSDF can accept and thetreatment, storage and/or disposalactivities that can be conducted. Thepermit also outlines the operatingconditions and record keepingprocedures the TSDF must follow toensure that wastes will be handledaccording to EPA regulations. InOhio, TSDFs are permitted throughthe Ohio EPA' s Division of Hazard-ous Waste Management (DHWM).

TSDFs within the state are in-spected by Ohio EPA. Commercialfacilities (those that receive andprocess wastes from off-site gen-erators) generally are inspectedtwice per year. A few larger hazard-ous waste disposal sites have on-site Ohio EPA inspectors whomonitor the daily activities of thefacility.

You can access compliance-relatedinformation for facilities throughseveral national tracking systemsmaintained by U.S. EPA:

Envirofacts:This is a single point of access toseveral U.S. EPA databases avail-able at www.epa.gov/enviro.

Enforcement and ComplianceHistory Online (ECHO):ECHO provides integrated compli-ance and enforcement informationfor approximately 800,000 regulatedfacilities nationwide. The site allowsyou to find facility level inspection,violation, enforcement action and

penalty information for the past twoyears. Facilities regulated under theClean AirAct (CM) StationarySource Program, Clean Water Act(CWA), National Pollutant DischargeElimination System (NPDES), andResource Conservation and Recov-ery Act (RCRA) are included.

ECHO reports provide a snapshot ofa facility's environmental record,showing dates and types of viola-tions and the state or federalgovernment's response. ECHOreports also contain demographicinformation from the national cen-sus. You can access ECHO on-lineat www.epa.gov/echo.

You can also contact the local OhioEPA district office for informationabout a company's permits andcompliance record. The first step isto locate the Ohio EPA district officethat oversees the county where theTSDF is located (see map). Then,contact the Division of HazardousWaste Management in that districtoffice and ask to talk with the personresponsible for inspecting the facility.

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Office of compliance Assistance & Pollution Prevention, SOW Town St, Suite 700, Columbus, Ohio 43215 (800) 329-7518— www.epa.state.oh.us/ocapp

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Selecting a Treatment/Storage/Disposal Facility (TSDF) toHandle Your Hazardous Wastes

Ask your Ohio EPA contact:

Does the facility have a hazard-ous waste permit?

• What types of hazardous wastetreatment, storage and/ordisposal activities are authorizedby the permit?

Is the facility permitted to handlethe specific wastes that yourbusiness will be sending tothem?

• When was the facility lastinspected by Ohio EPA?

• What types of problems orviolations were found? Has thefacility been operating in compli-ance with its permit conditions?

If problems or violations werefound during past inspections,has the facility corrected these?

• Are there any current enforce-ment actions against the facilityfor violations?

• Has the facility recently beenpenalized for violations?

Does the facility have financialassurance in accordance withthe regulations to ensure that itcan properly close or clean up itshazardous waste units?

Because there are many regulationsthat apply to a TSDF, it is commonfor these companies to have hadsome past violations. Paperworkviolations and some operatingviolations may have been found atthe company during past inspections

(for example, open drums, incorrectinformation on inspection logs,manifests, training records). How-ever, a long history of violations maysignal poor waste managementpractices (for example, many spills,emergency incidents, unauthorizedtreatment/storage/ disposal activi-ties).

Waste Handling Practices

To ensure your hazardous waste willbe managed properly, it is importantfor you to know how the waste willbe handled once it gets to the TSDFYour waste may be handled by morethan one facility. For example, yourwaste may be treated at one locationand then shipped off to another sitefor disposal. If so, you should look atthe compliance and operating statusof both sites.

Ask the TSDF:

• Can the facility accept the wasteyou are sending (by EPA wastecode)?

• How will the waste be trans-ported to the facility? If this will bearranged by the TSDF, is alicensed hazardous wastetransporter used?

• How will the hazardous waste bemanaged once it gets on site:stored? treated? fuel blended?incinerated? landfilled?

• Will hazardous wastes behandled only in those areasauthorized under the facility'spermit?

If wastes are treated, how willany residues from the treatment(for example, incinerator ash, stillbottoms, etc.) be handled?

• Will the waste or treatmentresidues be shipped off toanother facility for handling ordisposal? If so, how are thesewastes managed by the secondfacility?

How will you be notified of finaldisposal of the waste? Will youget something in writing?

How much time will it take fromwhen the wastes are received atthe TSDF until final disposal?

• Does the facility have an environ-mental compliance manager oran internal auditing program tohelp monitor its compliance withthe regulations?

2

Selecting a Treatment/Storage/Disposal Facility (TSDF) toHandle Your Hazardous Wastes

Is there a list of TSDFs inOhio that take hazardouswaste?

Yes, Ohio EPA's Division of Hazard-ous Waste Management (DHWM)has a list of the facilities in Ohiopermitted to treat, store and/ordispose of hazardous wastes. Thislist is available through Ohio EPA'sWeb site at www.epa.state.oh.us/dhwm/pdf/accepting.pdf.

Are there any otherconsiderations inchoosing a TSDF?

Information from Ohio EPA's Divisionof Hazardous Waste Management isrelated to compliance with thehazardous waste regulations only.This means that you may need tomake additional contacts within OhioEPA to get complete record of thefacility's compliance status. Otherareas to consider are compliancewith wastewater, air pollution andright-to-know regulations. The OhioEPA Resource Guide can help you inmaking contacts in other programareas. It is available on-line atwww.epa.state.oh.us/ocapp/sb/publications/resguide.pdf.

Some businesses sending wastesto a TSDF have completed their ownon-site audits of the facility before-hand to make sure their wastes willbe properly handled. This isn'talways feasible though, particularlyfor small business owners. Onealternative is to ask the TSDF for areference list of other businesscustomers. This will allow you to talk

directly with other businesses aboutthe service received and can helpyou identify potential problem areas.

What if I'm consideringusing a TSDF that isn't inOhio?

If you are considering using a TSDFoutside Ohio, that state's environ-mental agency should have compli-ance and permitting informationavailable. There is no single contactlist for all other state environmentalagencies, however, you can start atU.S. EPA's Regional Office Web siteto find contact information for otherstates at www.epa.gov/epahome/locate2.htm.

Where can I get morehelp?

If you have questions or need help inunderstanding Ohio EPA's regula-tions, you can also contact OhioEPA's Office of Compliance Assis-tance and Pollution Prevention(OCAPP) for help. OCAPP is a non-regulatory office of Ohio EPA with agoal of helping small businessescomply with environmental regula-tions and permitting requirements. Ifyou are operating a small businesswith fewer than 100 employees, wecan help you! For more information,contact OCAPP at (800) 329-7518,or visit our Web site atwww.epa.state.oh.us/ocapp/sb.

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Selecting a Treatment/Storage/Disposal Facility (TSDF)to Handle Your Hazardous Wastes

District Offices

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Toll-free numbers are for citizens withquestions or concerns about environmentalissues. The regulated community shoulduse the business line for routine business.Spills and emergencies should be reportedto (800) 282-9378.

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CDO Central District Office NWDO Northwest District Office SEDO Southeast District OfficeSOW. Town St. Suite 700 347 N. Dunbridge Rd. 2195 Front St.Columbus, OH 43215 Bowling Green, OH 43402 Logan, OH 43138(614) 728-3778 (419) 352-8461 (740) 385-8501(614) 728-3898 Fax (419) 352-8468 Fax (740) 3856490 Fax(800) 686-2330 (800) 686-6930 (800) 686-7330www.epa.state.oh.us/cdo www.epa.state.oh.us/nwdo www.epa.state.oh.us/sedo

NEDO Northeast District Office SWDO Southwest District Office2110 E. Auroa Rd. 401 E. Fifth St.

Twinsburg, OH 44087 Dayton, OH 45402-6357

(330) 963-1200 (937) 285-6357

330 487-0769 Fax(937) 285-6249 Fax(800) 686-6357

686-6330 http:/swdoweb.epa.state.oh.uswww.epa.state.oh.u s/ned o

4 ChidEPA Ohio EPA is an Equal Opportunity Employer

RECEIVEDOHIO EPA

JUL 10 2008CITY OF BEIIEFONTAINE, OHIO

STREET DEPARTMENT413 WEST CHILLICOTHE AVE.BELLEFONTAINE, OHIO 43311

937-592-1736

July 9, 2008

Ms. Pam HullDivisionof Hazardous Waste ManagementOhio EPA401 East Fifth StreetDayton, Ohio 45402-2911

Dear Ms. Hull:

Please accept the following in response to your letter of June 13, 2008:

1) Resource One has disposed of the used solvent as provided to you through the Manifest dated5-31-06.

2) Logan County Solid Waste picked up all used paint for proper disposal.

3) Resource One will again be disposing of the used products for this year.

4) Effective 2009, we will be using water-based paint.

If you need any additional information or have any questions, please don't hesitate to contact me.

2o^Street Superintendent

. .