Facility Audit: Ashtabula, OH - Clean Harbors

All of our disposal facilities uphold rigorous quality assurance programs to meet the higheststandards of both internal and external audits.Waste streams handled by Clean Harbors can be in any form from gas to liquids, solids andsludge. Clean Harbors can dispose of virtually any type of waste, hazardous or non-hazardousfrom exotic water reactive wastes to typical paint or oil wastes.Our transportation services handle everything from small one-time shipments to multiple largeshipments, and include drum, bulk and rail capabilities. Once you place your order and beforethe picked up is even made, Clean Harbors begins the process of managing your waste. Yourorder enters our Logistics center where your waste is designated for disposal via the least costrouting. Company owned and operated trucks are assigned based on the most efficient route oron pre-established schedules. Satellite tracking and communications allows trucks to bedispatched on the fly from anywhere in the country. The disposal facility is determined based onthe most appropriate, yet lowest cost disposal method.Furthermore, plant inventories are centrally monitored real-time and our facilities know inadvance and begin load planning for efficient processing of incoming waste. All this upfrontwork is managed centrally and electronically to provide the most cost effective and efficienthandling of orders, and waste transportation and disposal, in the industry.CleanPack® Laboratory Chemical Packing Services - Clean Harbors’ staff of professionallytrained CleanPack chemists work on customers’ sites to collect, label and package unwantedlaboratory quantities of chemicals and wastes for disposal in compliance with local, state, andfederal regulations. Additionally, CleanPack teams provide reactive material handling servicesand cylinder and compressed gas management for the proper handling and disposal of highlyreactive and dangerous chemicals, laboratory move services. The teams also manage the movingof entire laboratories, as well as assist in facility closures. Our household hazardous wastecollection program offers a cost effective and safe manner for States, Provinces, Cities andTowns to keep their resident’s free of unwanted old and obsolete pesticides, paints, fertilizersand other potentially harmful materials.Site Services –Site Services is responsible for providing trained, skilled labor and specialtyequipment to perform various services on a customer’s site or other location. Field Servicecrews and equipment are dispatched on a planned or emergency basis to manage routine cleaningin hazardous environments or emergencies such as a chemical or oil spill clean up. IndustrialService crews focus on industrial cleaning and maintenance projects that typically require fastturnaround, as well as large-scale cleaning project requiring specialty onsite processingequipment.Field Services - Working in hazardous and non-hazardous environments, Field Service crewsand equipment are dispatched on a planned or emergency basis to perform services such asemergency response, vacuum services, tank cleaning, site decontamination, product recovery andtransfer, demolition services, marine services, used oil and oil products recycling, PCBmanagement and disposal, and remediation and environmental construction.1

Facility Site Plan4

Facility HistoryThe property was vacant until the mid-60’s when McGraw-Hill built the first building and beganoperating an engine re-build/repair business. McGraw-Hill discontinued operations in the mid-70’s. The property was sold to the current owner, K B Two Ltd in the early 80’s. The buildingwas vacant until 1985 when G&L Recovery Systems moved in.The initial waste-related activity at the site started in 1985 when G&L Recovery Systems beganPCB Transformer decommissioning R&D operations under approval from US EPA Region V in1985. G&L Recovery worked under a R&D permit from 1985 to February 1989 when ouroperating permit was issued. In April 1989, Unison bought the process. This same operation hascontinued over the years with some space additions under various owners. Unison Transformerbought the facility in 1989, Trans-End Technology in 1994, PPM, Inc of Georgia in 1997,Laidlaw in 1998, also Safety-Kleen in 1998. Clean Harbors purchased the Chemical ServicesDivision, which included this facility from Safety-Kleen in 2002.Site CharacterizationThe facility receives PCB contaminated waste in a variety of forms including: whole electricaltransformers, capacitors, switches, regulators, bushings, and ballasts; bulk and drummed oils andwastewaters; and bulk and drummed solid waste such as soil, rocks, and debris.Operations conducted in the facility consist of three PCB treatment/handling operations, whichinclude: transformer decommissioning, cable decommissioning, and storage/transfer.This facility is an EPA-approved storage facility with a TSCA storage capacity of 237,600 gallonequivalency. The facility is authorized to store all PCB materials for disposal. The appropriatedisposal/destruction/recycling processes are always selected to ensure compliance with theregulations and satisfaction for the customer.The PPM processes are designed for worker and environmental safety. The processes operate atambient temperature and pressure. Equipment construction conforms to industrial safety codes,and equipment hazards are minimized.SecurityThe facility meets the requirements of 40 CFR 264.14 Security. The facility is completelysurrounded by a 6’ chain link fence with two strands of barbwire along the top of the fence.There are two (s) gated entrances, two (2) entrance doors outside of the gated area. Both gatesare secured by lock and chain. Exterior lights are located throughout the facility and are set up toautomatically light at dusk. Daily inspections of the perimeter are performed to ensure thatfences and gates are intact and secure. The facility has a motion detection system in the officeand lab areas that are monitored 24-hours a day by a third party security firm. Only keyemployees are issued keys so that they have access to the facility. All doors are locked andalarms are set when the facility is closed.5

Directions to FacilityThe facility is located in the City of Ashtabula which is in northeast Ohio mid-way betweenCleveland, Ohio and Erie, Pennsylvania. The facility is in an old industrial area that sill hassome residence nearby. The facility consists of approximately 4.7 acres; surrounding land useis residential and light industrial.Site Address: 1302 West 38 th StreetAshtabula, Ohio 44004(440)992-8665East from Cleveland:1. Take I-90 East to Ohio Hwy. 452. North on Ohio Hwy 45 to Ohio Hwy 203. East on Ohio Hwy 20 approx. 4 miles to West Avenue4. North on West. Ave. (1 ¼ mile) to 1 st traffic light,5. Turn left onto West 8 th Street.6. Facility is on the left side of the road.West from Erie, PA:1. Take I-90 West to Ohio Hwy 112. North on Ohio Hwy 11 approximately 2.5 miles to Ohio Hwy 203. West on Ohio Hwy 20 approximately 3 miles to West Avenue4. North on West. Ave. (1 ¼ mile) to 1 st traffic light,5. Turn left onto West 8 th Street.6. Facility is on the left side of the road.North from Youngstown:1. Take Ohio Hwy 11 North for approximately 55 miles to Ohio Hwy 202. North on Ohio Hwy 11 approximately 2.5 miles to Ohio Hwy 203. West on Ohio Hwy 20 approximately 3 miles to West Avenue4. North on West. Ave. (1 ¼ mile) to 1 st traffic light,5. Turn left onto West 8 th Street.6. Facility is on the left side of the road.6

3.0 Operating Licenses and PermitsPermit SummaryClean Harbors PPM, LLC is currently permitted by the U.S. Environmental Protection Agencyfor the collection, storage, analysis, treatment, and storage of PCB contaminated waste withsubsequent transfer off-site. Clean Harbors PPM, LLV also currently holds a Title V Air Permitissued by the Ohio Environmental Protection Agency.Permit Type/Governing Agency Permit No. Expiration DateTSCA (Approval to Process fully drainedPCB and PCB contaminated electricalequipment and other PCB items)UESPA Region 5TSCA (Commercial Storage)USEPA Region 5D-08JOriginal applicationsubmitted 8/1/90, Periodicupdates submitted asnecessaryIndefiniteIndefiniteTitle V Air PermitOhio EPA* Renewal application submitted.02-04-01-0288 5/15/07*Principal Operating Licenses/PermitsCopies of existing permits which detail types of waste management licensed capacities and wastetypes accepted are available for inspection upon request at the site. Selected permit pages maybe attached at the end of this audit under Appendix 8.0.7

Principal Contacts/AgenciesThe list of contacts below can provide additional information regarding Clean Harbors of PPM,LLC’s facility operations and compliance.OperationsRegulatoryTSCA(CommercialStorage,TransformerDecommissioning)Title V Air PermitKevin Gozzard, Facility General ManagerClean Harbors PPM, LLC1302 West 38 th StreetAshtabula, OH 44004(440) 992-8665 – ext 203Bonnie Martin, Sr. Compliance ManagerClean Harbors13733 West 108 th St.Lenexa, KS 66215(913)491-4051Tony MartigU.S. EPA Region 577 West Jackson Blvd.Chicago, IL 60604(312) 353-2291Bridget Byrne, Ohio EPANortheast District Office2110 East Aurora RoadTwinsburg, Ohio 44087(330)963-12168

4.0 Process DescriptionGeneral DescriptionThe facility receives PCB contaminated waste in a variety of forms including: whole electricaltransformers, capacitors, switches, regulators, bushings, and ballasts; bulk and drummed oils andwastewaters; and bulk and drummed solid waste such as soil, rocks, and debris.Operations conducted in the facility consist of three PCB treatment/handling operations, whichinclude: transformer decommissioning, cable decommissioning, and storage/transfer.Approximately 4.5 million pounds of transformers and 1.7 million pounds of cable aredecommissioned at this facility per year. An additional 6.6 million pounds of liquid and solidmaterials in bulk or drums are stored onsite annually until transferred offsite for recycling orfinal disposal.Waste generated from our processes is mainly disposed at other Clean Harbors facilities.Primarily, these facilities include the Clean Harbors incinerator in Deer Park, TX and the CleanHarbors oil dechlorination facility in Coffeyville, KS. PCB Debris is currently being landfilledat CWM Chemical Services, LLC in Model City, NY. Non-Clean Harbors facilities, pursuant tocompany policy, must be audited and approved by an internal audit team prior to any shipments.Re-audits are conducted every 3 years.Transformer DecommissioningThe Transformer Decommissioning Process is basically a four-step process: 1) drain all fluids,2) an initial degreasing of the entire unit, 3) separation of the core from the carcass, and then 4)final degreasing. All operations are conducted indoors. When transformers aredecommissioned, most of the internal parts are recycled, along with the empty transformerhousing units or “carcasses.” Roughly 90% of a typical transformer’s weight consists of steel,copper, and/or aluminum, so most parts are recyclable.The operators begin the decommissioning process by transferring a transformer using cranes,forklifts, or other appropriate equipment to a cutting station where welded tops are cut openalong the top welding line using an abrasive blade. All fluids are then removed from thetransformer. The fluid (typically oil) is either detoxified offsite at our Clean HarborsCoffeyville, KS facility or incinerated offsite at our Clean Harbors Deer Park, TX facility.Drained >500ppm PCB transformers are then sent to the primary tank for an initial cleaningwhere the carcass is washed with solvent. After the initial cleaning, a transformer has itscoil/core removed. The resulting transformer carcass and metal support bars are sent back to theprimary tank where it is again washed with solvent, which thoroughly removes all remaining oilsand PCBs. The dismantled cores are sent through the granulator. Granulated metals are thensent to a tumbler where they are washed with solvent. Both the cleaned carcass and the cleanedgranulated metals are staged in the Clean Metals area to await sample verification prior to beingsent offsite to a secondary smelter. The spent solvent is recovered onsite through the use of a9

distillation column and a reclaimer. The still bottoms, which result from this solvent recoveryprocess, are incinerated at our Clean Harbors Deer Park, TX facility.A transformer classified as

6.0 InsuranceClean Harbors and its subsidiaries maintain General Liability and Automobile Liabilityinsurance with aggregate limits of $30,000,000. The Company purchases EnvironmentalImpairment Liability insurance for its’ waste facilities with limits of $30,000,000 insuring theCompany against liability for sudden and accidental occurrences from the time waste is pickedup from a customer, while being handled at the Company’s treatment and transfer facilities,through its delivery to a disposal site. See attached copy of Certificate of Liability Insurance.In addition, Clean Harbors purchases an insurance program for Closure (Post-Closure andCorrective Action where so required) in amounts that meet regulatory requirements.Clean Harbors’ Casualty Insurance Program SummaryPolicyWorkers Compensation & Employer’sLiabilityBusiness Automobile Liability(Includes MCS-90 Endorsement)Comprehensive General LiabilityExcess (Umbrella) Liability(Follow Form)Wharfingers LiabilityLimits of LiabilityStatutory$1,000,000 Each Accident$1,000,000 Each Occurrence$5,000,000 MCS-90$1,000,000 Each Occurrence$3,000,000 Aggregate$30,000,000 Each Occurrence$30,000,000 Aggregate$10,000,000 Any one Vessel/Any one Accident$10,000,000 Each Occurrence$10,000,000 Aggregate$1,000,000 Each Occurrence/Any one Vessel$3,000,000 Each Occurrence$6,000,000 Aggregate$30,000,000 Each Occurrence$30,000,000 AggregateContractor’s Pollution Liability (Off-Site)Protection and IndemnityEnvironmental Impairment Liability(Coverage for Clean Harbors Facilities)Excess Pollution Liability(Sudden and Accidental Occurrences)Total coverage for Pollution incidences thatoccur during transportation related activities $30,000,000 LimitFor more detail concerning Clean Harbors’ coverage, please contact the Clean Harbors RiskManagement Department at (781) 792-5000.Facility Closure Certificatehttp://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=640&ft=1Certificate of Liability Insurancehttp://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=98&ft=111

PStreet7.0 Financial InformationFinancial information on Clean Harbors and its subsidiaries are available from the Clean Harborswebsite in the Investor Relations section.http://www.cleanharbors.com/investor_relations/investment_materials.html8.0 AppendixIf applicable, supporting facility documentation will follow.1302 West 38Pth• Ashtabula, Ohio 44004 • 440.992.8665 • www.cleanharbors.com12