Facility Audit: Coffeyville, KS - Clean Harbors

Facility Audit: Coffeyville, KS

Table of Contents1.0 General Company Information ......................................................................................................................... 1Introduction......................................................................................................................................................... 1Network of Services............................................................................................................................................ 12.0 Facility Information .......................................................................................................................................... 3Facility Overview................................................................................................................................................ 3Facility Site Plan................................................................................................................................................. 4Facility History ................................................................................................................................................... 5Site Characterization........................................................................................................................................... 5Security ............................................................................................................................................................... 5Directions to Facility........................................................................................................................................... 63.0 Operating Licenses and Permits........................................................................................................................ 7Permit Summary ................................................................................................................................................. 7Principal Operating Licenses/Permits................................................................................................................. 7Principal Contacts/Agencies ............................................................................................................................... 8Compliance ......................................................................................................................................................... 84.0 Process Description........................................................................................................................................... 9General Description ............................................................................................................................................ 9Transformer Decommissioning .......................................................................................................................... 9Chemical Detoxification ................................................................................................................................... 10Storage/Transfer................................................................................................................................................ 115.0 Closure Plan.................................................................................................................................................... 116.0 Insurance......................................................................................................................................................... 117.0 Financial Information...................................................................................................................................... 138.0 Appendix......................................................................................................................................................... 13

1.0 General Company InformationIntroductionClean Harbors is a publicly traded company who maintains a vast network of service centers andwaste management, treatment and disposal facilities, providing a broad range of environmentalservices. Services include hazardous and non-hazardous waste transportation and disposal,laboratory chemical packing, emergency response, and field services and industrial maintenance.Since its inception in 1980, Clean Harbors has grown to become the leading provider ofenvironmental services in the country in North America and its locations span the United Statesand Canada, and include locations in Mexico and Puerto Rico.Network of ServicesStrategically located across North America, Clean Harbors’ service centers are the primaryinterface with customers and the focal point for providing waste management activities,laboratory chemical packing services, and emergency response, field services and industrialmaintenance. From the service center Site Service crews and equipment are dispatched toperform various planned work on customers’ sites, as well as emergency response. CleanPackteams are also based at the service centers and provide customers with laboratory chemicalpacking services.Technical Services – Technical Services provides the pick up and transportation ofcontainerized and bulk wastes, as well as the categorizing, packaging and removal of laboratorychemicals for disposal. Through a network of Technical Service Centers, trucks are typicallydispatched on predetermined schedules to pick up waste from customer locations for delivery toa Clean Harbors Transfer, Storage and Disposal Facility. The Technical Service Centers alsodispatch CleanPack ® chemists who go to customer locations to categorize, package and removevarious sized laboratory chemicals for disposal.Transportation & Disposal - Clean Harbors’ network of company owned waste treatment,storage and disposal facilities are located across North America and offer a broad range ofdisposal, recycling and treatment technologies for hazardous and non-hazardous materials.Technologies include:• Incineration• Water Treatment• Landfill• Recycling and Reuse• Fuel Blending• Lab Chemical Disposal• Used Oil and OilProducts Recycling• PCB Disposal• Explosives Management1

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 – The 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.Industrial Services - Industrial Services teams use advanced industrial cleaning technologiesincluding sodium bicarbonate blasting, hydroblasting, and steam-cleaning along with vacuum1

services to accomplish fast turnaround during time-critical plant shutdowns. The teams alsoperform onsite material processing services, and dewatering and pressing, and containermanagement services.2

2.0 Facility InformationFacility OverviewClean Harbors PPM, LLC, a subsidiary of Clean Harbors, Inc. headquartered in Norwell,Massachusetts, owns and operates a PCB commercial storage and disposal facility in Coffeyville,KS. The facility also has a RCRA storage permit. This facility is a fully permitted facility bythe U.S. Department of Environmental Protection Agency to receive, store, treat and transfer avariety of waste streams. The treatment methods utilized at this facility reduce the volume andtoxicity of waste materials.Facility NameLocationClean Harbors PPM, LLC2474 Hwy 169 NorthCoffeyville, KS 67337CountyMontgomeryFacility OwnerClean Harbors PPM, LLC2474 Hwy 169 NorthCoffeyville, KS 67337Property OwnerClean Harbors PPM, LLC2474 Hwy 169 NorthCoffeyville, KS 67337Facility I.D. No.KSD981506025Permit TypePCB Commercial Storage, PCB Disposal, RCRA StorageWaste DescriptionServices ProvidedPCBsChemical Detoxification of PCB oilTSCA Commercial Storage, RCRA Storage CapabilitiesTransformer DecommissioningLoading/Unloading capability for all trucks & railNELAC certified laboratory3

Facility Site Plan4

Facility HistoryBeginning in World War II, the site was part of an Army Air Force Base that was used to trainpilots. Prior to that time, the site had been used for agricultural purposes. Following the war inthe 1940’s, the site went through a number of changes in ownership with the use mainly directedat aircraft parts manufacturing or similar activities.The initial waste-related activity at the site started in 1984, when National Electric Inc. initiated atransformer drain-and-flush business. This basic activity has continued over the years with someadditions under various owners and joint ventures. Incineration was started in 1985; and wasclosed in 2001. Chemical detoxification and solvent recovery were started in 1986. Aptusowned the facility in 1987, Rollins in 1995, Laidlaw in 1997, and Safety-Kleen in 1998. CleanHarbors purchased the Chemical Services Division, 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, chemical detoxification, and storage/transfer.This facility is an EPA-approved storage facility with a TSCA storage capacity of 8,700,000pounds and a RCRA storage capacity of 107,800 gallons. The chemical detoxification andtransformer decommissioning processes were successfully demonstrated with EPA Region VIIrepresentatives in attendance. The facility is authorized to handle all PCB materials for disposal.The appropriate disposal/destruction/recycling processes are always selected to ensurecompliance with the regulations 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. The detoxification equipment is blanketed with nitrogento avoid reaction side products and to eliminate fire hazards.SecurityThe facility meets the requirements of 40 CFR 264.14 Security. The facility is completelysurrounded by an 8’ chain link fence with three strands of barbwire along the top of the fence.There are gates at specific locations throughout the facility that are designated as entrance/exitways used by employees or visitors requiring access to the facility. Frequently used gates are setup with remote controls so that they can be opened or closed from the Security Office or theMain Office. All other gates are secured by lock and chain and are only used in cases ofemergency or maintenance. Remote cameras are used to monitor the most active gate from theMain Office. Exterior lights are located throughout the facility and are set up to automaticallylight at dusk. Daily inspections of the perimeter of the active area are performed to ensure thatfences and gates are intact and secure. All buildings are individually secured with locks whenthey are not occupied. A security service performs security inspections during off-hours onweekends and holidays. Only key employees are issued keys so that they have access to thefacility.5

Directions to FacilityThe facility is located in an industrial park in Montgomery County, near Coffeyville, Kansas.Coffeyville is located in southeast Kansas approximately 5 miles north of the Oklahoma border.The facility is located 3.5 miles north of Coffeyville on US Highway 169. The property ownedby the facility consists of 406 acres. The area designated as the active portion of the facility isequal to 66 acres; surrounding land use is agricultural and light industrial.Site address: 2474 Highway 169 NorthCoffeyville, KS 67337(620) 251-6380From the North:1. Take US Hwy 169 South from Chanute. The facility is on the left side.From the South:2. Take US Hwy 169 North from Coffeyville. The facility is on the right side.6

3.0 Operating Licenses and PermitsPermit SummaryClean Harbors PPM, LLC, is currently permitted by the U.S. Environmental Protection Agencyand the Kansas Department of Environmental Protection for the collection, storage, analysis,treatment, and storage of hazardous waste with subsequent transfer off-site.Permit Type/Governing Agency Permit No. Expiration DateRCRA (Storage) KSD 981 506 025 4/12/2020HWSA (Storage) / USEPA Region 7 KSD 981 506 025 4/12/2020TSCA (Commercial Storage) / USEPARegion 7KSD 981 506 025 04/08/2012TSCA (Oil Detoxification)/ USEPARegion 7KSD 981 506 025 11/24/2018TSCA (Transformer Decommissioning)/USEPA Region 7KSD 981 506 025 04/08/2012Title V Air Permit/ KDHE 1250049 10/24/2014NPDES-StormwaterG-VE09-0006,KSR000308IndefinitePrincipal 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 areattached at the end of this audit in Section 8.0.7

Principal Contacts/AgenciesThe list of contacts below can provide additional information regarding Clean HarborsCoffeyville facility operations or compliance:OperationsComplianceRCRA (Storage)HWSA(RCRA Part II)TSCA(Commercial Storage)(Oil Detoxification)(TransformerDecommissioning)Title V (Air Permit)StormwaterRich Bevans, Facility General ManagerClean Harbors PPM, LLC2474 Highway 169 NorthCoffeyville, KS 67337(620) 252-1297Bonnie Martin, Sr. Compliance ManagerClean Harbors13733 West 108 th StreetLenexa, KS 66215(913) 491-4051Mostafa KamalKansas Department of Health & Environment1000 SW Jackson, Suite 320Topeka, KS 66612(785) 296-1609Ken HerstowskiUSEPA Region 7901 North 5 th StreetKansas City, KS 66101(913) 551-7631Mazzie TalleyUSEPA Region 7901 North 5 th StreetKansas City, KS 66101(913) 551-7518Vick CooperKansas Department of Health & Environment1000 SW Jackson, Suite 310Topeka, KS 66612(785) 296-1561Eric StaabKansas Department of Health & Environment1000 SW Jackson, Suite 420Topeka, KS 66612(785) 296-43478

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, chemical detoxification, and storage/transfer.Approximately 6 million pounds of transformers are decommissioned at this facility per year.An additional 11 million pounds of liquid and solid materials in bulk or drums are detoxifiedand/or stored onsite annually until transferred offsite for recycling or final disposal.All waste generated from our processes is only disposed of at other Clean Harbors facilities.Primarily, these facilities include the Clean Harbors incinerator in Deer Park, TX and the CleanHarbors landfill in Grassy Mountain, UT. Should a need arise to utilize a non-Clean Harborsfacility, company policy dictates that the outside facility must be audited and approved by aninternal audit team prior to any shipments.Transformer DecommissioningThe Transformer Decommissioning Process is basically a two-step process: a) draining andflushing, followed by b) dismantling and degreasing. All operations are conducted indoors in themain process building. When transformers are decommissioned, most of the internal parts arerecycled, along with the empty transformer housing units or “carcasses.” Roughly 80% of atypical transformer’s weight consists of steel, copper, and/or aluminum, and most parts arerecyclable.Transformers containing oil with PCB concentrations greater than 50 ppm are decommissionedusing the Hi-Part process. Transformers containing oil with PCB concentrations less than 50 ppmare decommissioned using the Lo-Part process.The Hi-Part transformer decommissioning area consists of five major components: Receiving,Tip and Drain, Dismantling, Degreasing, and Clean Metal Staging. Transformers are unloadedin the receiving areas utilizing overhead cranes and/or forklifts. The transformers are checkedinto inventory and placed into a designated area of the warehouse to wait for processing. TheTip and Drain Area consists of a process table and storage tanks. This area is used to drain oilfrom the transformers. The Dismantling Area consists of two buildings where the transformercomponents are dismantled prior to the final degreasing operation. The Degreasing operationconsists of a vapor degreaser where transformer carcasses are cleaned and a tumbler wheretransformer components are cleaned. The Clean Metal Staging Area is used to temporarily storeclean metals awaiting sample analysis verification prior to shipment off site for recycling.The operators begin the Hi-Part decommissioning process by transferring a transformer usingcranes, forklifts, or other appropriate equipment onto one of the two work platforms located onthe Tip and Drain Station. Oil from the transformer is drained into a sump and then pumped intoa storage tank. The oil is either detoxified onsite or incinerated offsite at our Clean Harbors DeerPark, TX facility.9

The drained transformer is transferred to the Dismantling Area. The Dismantling Area consistsof two small, insulated buildings. The transformer enters a cutting station where welded tops arecut open along the top welding line using an abrasive blade. The transformer is then moved tothe Hi-Part Disassembly building. The transformer cores are removed and dismantled. Thetransformer carcass and metal support bars are sent to the vapor degreaser where they areimmersed in a n-propyl bromide vapor, which thoroughly removes all remaining oils and PCBs.The dismantled cores are sent through the Granulator. The granulated metals are then sent to thetumbler where they are washed with n-propyl bromide solvent. The cleaned metals are staged inthe Clean Metals area to await sample verification prior to being sent offsite to a secondarysmelter. The spent solvent is recovered onsite through the use of a distillation column and areclaimer. The still bottoms, which result from this solvent recovery process, are incinerated atour Clean Harbors Deer Park, TX facility.The Lo-Part decommissioning area consists of the Lo-Part Aqueous Washer. A transformerclassified as Lo-Part is placed on a roller conveyor and the oil is decanted off into a storage tank.The oil is either detoxified onsite or incinerated offsite at our Clean Harbors Deer Park, TXfacility.The transformer is then cleaned utilizing the Lo-Part Aqueous Washer. The Lo-Part AqueousWasher utilizes a hot aqueous/soap solution, which is sprayed through nozzles inside anenclosure. The water collects in the bottom of the enclosure. The solution is filtered, the pH isadjusted, and metals precipitated out of solution. The solid residues are incinerated at our CleanHarbors Deer Park, TX facility. The remaining solution is recycled for re-use. The resultingclean transformer will be transferred to the Clean Metals area to await sample verification priorto shipment offsite to a secondary smelter.Chemical DetoxificationThe dielectric fluid (oil) drained from transformers with PCB concentrations amenable fordetoxification (

Another tank is used to hold the detoxified oil while the excess sodium reagent is neutralized bythe addition of water. The reaction produces two separate streams: clean oil (PCB concentration

Clean Harbors Casualty Insurance Program SummaryPolicyWorkers Compensation & Employer’sLiabilityBusiness Automobile Liability(Includes MCS-90 Endorsement)Comprehensive General LiabilityExcess (Umbrella) Liability(Follow Form)Wharfingers LiabilityContractor’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 activitiesLimits 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 Aggregate$30,000,000 LimitFor more detail concerning Clean Harbors’ coverage, please contact the Clean Harbors RiskManagement Department at (781) 792-5000.Facility Closure Certificateshttp://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=112

7.0 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.2474 Hwy 169 • Coffeeville, KS 67337 • 1-800-248-0442 • www.cleanharbors.com13