Lehigh Valley cement plant seeks rail delivery of its hazmat fuel. Public hearing is set.

A cement manufacturer in Northampton County seeks state approval to begin shipments by rail rather than truck of the hazardous waste it burns as fuel in its kiln.

The Pennsylvania Department of Environmental Protection is holding a public hearing later this month in Bethlehem to accept comment on the hazardous waste permit renewal application and draft permit associated with the proposal at Keystone Cement Co., 6507 Nor Bath Blvd. in East Allen Township.

"Keystone Cement Company is an existing permitted hazardous waste storage facility, located at Routes 329 and 987, Bath, PA, that specializes in the storage of approved liquid wastes prior to the beneficial use of the liquid waste as a fuel in the site cement kiln," the DEP's notice of the hearing states. "The renewal permit will include a hazardous waste fuel mixing system that will be used with the tank farm, rail car unloading, and direct fuel transfer system. The renewed permit will allow the existing facility to remain in operation for another ten (10) years."

Formed in 1928, Keystone has maintained a hazardous waste management permit for the treatment, storage and disposal of hazardous waste since December 1991 at its facility spanning 840 acres. The railcar unloading area has been considered since that time, but has not been built due to capital costs and marketing conditions, Keystone told lehighvalleylive.com .

"The railcar facility is meant to add flexibility to Keystone's ability to receive hazardous waste derived fuels," the company said in a response to questions about the proposal. "Once the railcar facility is fully operational, Keystone will receive hazardous waste-derived fuel more efficiently by railcar, with truck deliveries remaining available as needed."

The company's timeline calls for construction to begin in the second quarter of 2025 for a new six-tank farm for storing the hazardous waste derived fuel, with operation of some of the new tanks and the railroad unloading facility commencing in the first quarter of 2026.

Hazardous waste derived fuel approved by the state DEP is used to supplement pulverized coal, fuel oil, natural gas and other fuels deemed non-hazardous to heat the cement kiln, according to the company's 2,281-page permit application; reaching 3,000 degrees or so Fahrenheit, the process destroys the organic components in the waste derived fuel, leaving carbon dioxide and water.

"It is important to note that all hazardous materials are destroyed in the kiln, and the resulting non-hazardous ashes are retained in the kiln process as a zero-waste system," Keystone told lehighvalleylive.com , adding that the plant is subject to the most stringent air regulations under the Maximum Achievable Control Technology Standards of the U.S. Clean Air Act. Located near the Monocacy Creek, Keystone also is subject to stringent National Pollution Discharge Elimination System water regulations and routinely monitors the Lehigh River tributary.

The Keystone facility is permitted to burn up to 57,600 gallons per day of the hazardous waste derived fuels, the application states.

According to the application, materials that may be included in a typical mix of the hazardous waste derived fuel are chlorinated solvents; alcohols; ketones; aldehydes; acetates; petroleum oils, sludges and distillates; aromatic compounds; aliphatic compounds; resins and catalysts; mineral spirits; paint, ink pigments; and spent solvents.

The application details the plant's storage system's carbon steel tanks supported by reinforced concrete floors, which with surrounding walls form secondary containment area, as well as leak detection and feed systems, foam fire suppression and fire hydrant system, safety and security systems, and comprehensive spill recovery and response plan.

Keystone currently receives its waste derived fuels transported in U.S. Department of Transportation-approved bulk tanker trailers; the fuel is then sampled and tested prior to acceptance and unloading via pumps with grinders to storage tanks. Vapors during unloading may be vapor-balanced to the tanker trucks, vented to the kiln via a vent line or vented to a carbon absorption system, the application states.

Entering from Route 512, the hazardous waste deliveries come in an average of 10 to 15 tanker trucks per day, Keystone's application states.

"By transporting the hazardous wastes to site by the existing regional and local rail line track system, it would reduce the number of tanker trucks on the local roadways, reducing wear on local roadways," the application states. "This would minimize the amount of maintenance on the road system through re-pavement, expansions, etc. The main track system, railroad schedules, etc. are existing parameters that Keystone will have minimal effect on overall."

Keystone is working with Norfolk Southern Corp. on the rail proposal. Norfolk Southern told lehighvalleylive.com that it operates under a common carrier obligation, meaning railroads are required to transport any freight that has been properly tendered on reasonable terms and conditions, including hazardous materials.

Fewer than six trains per day travel the tracks adjoining the Keystone plant, the application states: "It is expected that these deliveries would be added to existing trains."

According to the information Keystone provided to lehighvalleylive.com : "Rail transport is statistically safer than road transport by a significant margin and rail transport is the safest way to move goods over land. Between 1975 and 2021, trucks carrying hazardous material were involved in 16 times more crashes involving fatalities than trains.

"More than 99.99% of all hazardous materials moved by rail reaches its destination without a release. Switching to rail transport removes approximately four trucks from the roads for every one railcar, reducing road traffic and associated risks."

The American Association of Railroads adds that: "Coupled with the rail industry's ongoing commitment to infrastructure investment, technology deployment and rigorous employee training, the hazmat accident rate is down 75% since 2000 to its lowest ever rate. While freight rail is the safest way to move goods over land, and more than 99.9% of all hazmat moved by rail reaches its destination without a release caused by a train accident, recent derailments remind us that such incidents can profoundly affect a community."

The American Association of Railroads on its website states that railroad operators have been taking action to "further enhance rail safety, from installing more inspection technologies to training more first responders."

"Freight rail is dedicated to protecting the health and safety of our workers, our communities and the environment," the association states.

Keystone notes in its application that it is not requesting to increase the amount of hazardous waste derived fuel that it burns.

"The overall project results in the retention of long term jobs for approximately 140 existing employees including approximately 20 employees who directly support the hazardous waste derived fuels operations," the application states.

Public hearing details The DEP public hearing is scheduled 6 to 9:30 p.m. Monday, Oct. 28 at Nitschmann Middle School, 1002 W. Union Blvd. in West Bethlehem.

According to the hearing notice:

Anyone wishing to testify at the hearing is asked to submit a written notice of intent to Colleen Connolly, Community Relations Coordinator, Keystone Cement Company Public Hearing, PA DEP, 2 Public Square, Wilkes-Barre, PA 18701-1915, or by email at .

The department will accept notices up to the day of the hearing. The written notice should include the person's name, address, telephone number and a brief statement as to the nature of their presentation. The department requests that individuals limit their testimony to five minutes so that all individuals have the opportunity to testify.

Written copies of oral testimony are requested. Relinquishing of time to others will not be allowed. Individuals attending the hearing will have the opportunity to testify if they so desire; however, individuals who pre-register to testify will be given priority on the agenda. Anyone unable to attend the hearing may submit written statements/comments to the department on or before Oct. 28.

Anyone with a disability who wishes to testify and requires an auxiliary aid, service or other accommodation should contact Colleen Connolly at 570-826-2511 or through the Pennsylvania Hamilton Relay Service at 800-654-5984 (TDD) to discuss how the department can meet their needs.

To request to view the application or draft permit, contact Roger Bellas at 570-826-2511 or .

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