Facility Audit: Baltimore, MD - Clean Harbors

Facility Audit: Baltimore, MD

Table of Contents1.0 General Company Information ......................................................................................................................... 1Introduction ......................................................................................................................................................... 12.0 Facility Information .......................................................................................................................................... 2Facility Overview................................................................................................................................................ 2Facility Site Plan ................................................................................................................................................. 3Facility History ................................................................................................................................................... 4Site Characterization ........................................................................................................................................... 4Security ............................................................................................................................................................... 4Directions to Facility........................................................................................................................................... 53.0 Operating Licenses and Permits........................................................................................................................ 7Permit Summary ................................................................................................................................................. 7Principal Operating Licenses/Permits ................................................................................................................. 7Principal Contacts/Agencies ............................................................................................................................... 84.0 Process Description ........................................................................................................................................... 9Organic Aqueous Waste Treatment .................................................................................................................... 9Inorganic Aqueous Waste Treatment .................................................................................................................. 9Storage and Transfer of Waste Oils .................................................................................................................. 10Container/Tank Storage/Transfer...................................................................................................................... 10Railcar Storage/Transfer ................................................................................................................................... 10Stabilization/Solidification of Characteristic Waste ......................................................................................... 10Container Management ..................................................................................................................................... 10Waste Analysis.................................................................................................................................................. 115.0 Closure Plan .................................................................................................................................................... 116.0 Insurance ......................................................................................................................................................... 117.0 Financial Information...................................................................................................................................... 138.0 Appendix ......................................................................................................................................................... 13

1.0 General Company InformationIntroductionClean Harbors is North America’s leading provider of environmental, energy and industrialservices serving over 50,000 customers, including a majority of the Fortune 500 companies,thousands of smaller private entities and numerous federal, state, provincial and localgovernmental agencies.Within Clean Harbors Environmental Services, the company offers Technical Services and FieldServices. Technical Services provide a broad range of hazardous material management anddisposal services including the collection, packaging, recycling, treatment and disposal ofhazardous and non-hazardous waste. Field Services provide a wide variety of environmentalcleanup services on customer sites or other locations on a scheduled or emergency responsebasis.Within Clean Harbors Energy & Industrial Services, the company offers Industrial Services andExploration Services. Industrial Services provide industrial and specialty services, such as highpressureand chemical cleaning, catalyst handling, decoking, material processing and industriallodging services to refineries, chemical plants, pulp and paper mills, and other industrialfacilities. Exploration Services provide exploration, rental, oil and gas field services, anddirectional boring services to the energy sector serving oil and gas exploration, production, andpower generation.Headquartered in Norwell, Massachusetts, Clean Harbors has more than 175 locations, includingover 50 waste management facilities, throughout North America in 38 U.S. states, sevenCanadian provinces, Mexico and Puerto Rico. The Company also operates internationallocations in Bulgaria, China, Sweden, Singapore, Thailand and the United Kingdom. For moreinformation, visit www.cleanharbors.com.1

2.0 Facility InformationFacility OverviewClean Harbors of Baltimore, Inc., a subsidiary of Clean Harbors, Inc. headquartered in Norwell,Massachusetts, owns and operates a hazardous waste storage, treatment and disposal facilitylocated in Baltimore, Maryland. This facility has been permitted by the Maryland Department ofthe Environment to receive, store, treat and transfer a variety of waste streams. The treatmentmethods utilized at this facility reduce the volume and or toxicity of waste materials or make itsuitable for further treatment, reuse, or disposal.Facility Name:Location:County:Facility Owner:Property Owner:Facility I.D. No.:Clean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230Baltimore CityClean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230Clean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230MDD980555189Permit Type RCRA Part B Permit No. A-151, Issued 09/10/08 Expires 09/09/18.Waste Description:Services Provided:Industrial pretreatment aqueous organic and inorganic wastes.Inorganic aqueous waste treatmentChemical precipitationPhase separationOrganic aqueous waste treatmentLiquefied carbon dioxide extractionActivated carbon adsorptionOil recoverContainer storage/transferTransportation and disposal2

Facility Site Plan3

Facility HistoryAccording to information contained in the RCRA facility assessment performed by A.T. Kearneyfor the USEPA in 1991, a 1896 topographical map shows the site was once a marsh.Documented ownership dates back to 1932. Sun Oil owned and operated the site as an oilstorage and transfer facility until 1972. Skyline Terminals operated the site a paint transferfacility from 1972 till 1979. The City of Baltimore owned the property from October 1979 tillApril 1986. During this time, ChemClear conducted an aqueous waste treatment operation at thesite. Ownership of the property was transferred to ChemClear in May 1986 and in January of1989 Clean Harbors purchased ChemClear and this property.Site CharacterizationClean Harbors of Baltimore, Inc. is located in an area zoned heavy industrial.SecurityA chain link fence topped with barbwire secures the premises of this site. Access is restrictedthrough locked gates. Security and fire systems are monitored twenty-four hours a day and sevendays a week.4

Directions to FacilityFacility AddressClean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230410.244.8200From the NorthFrom the South1. Take 1-95 South through the Fort McHenry Tunnel to I-3952. Take Exit 53 following signs to Martin Luther King Blvd.3. Take the Russell Street exit.4. At the end of the ramp turn left.5. At the light, turn left onto Russell Street.6. Continue on Russell Street and take Monroe Street/Route 1 Exit on the right.7. The facility is located on the right (look for the large gray tanks). Parking isavailable in the front of the office building.1. Take I-95 North to Exit 52, Russell Street.2. After the light, turn right onto Haines Street3. Take a left onto Warner Street.4. Turn Left onto Bayard Street.5. At the light, turn left onto Russell Street and stay to the right.6. Go through the first light; veer off to the Route 1, Monroe Street exit.7. The facility will be on the right.5

From the BWI Airport1. Take 295 North (Baltimore Washington Expressway) to the first light.2. Turn right onto Haines Street.3. Take a left onto Warner Street.4. Turn left onto Bayard Street.5. At the light, turn left onto Russell Street and stay to the right.6. Go through the first light; veer off to the Route 1, Monroe Street exit.7. The facility will be on the right.NOTE: As a point of reference, we are directly across from the "Baltimore" Resco trashincinerator which has a large smoke stack with blinking white strobe lights.6

3.0 Operating Licenses and PermitsPermit SummaryClean Harbors of Baltimore, Inc. is currently permitted by the Maryland Department of theEnvironment and the City of Baltimore Bureau of Water and Wastewater for the collection,storage, analysis, treatment of wastewaters and for container storage of a variety of hazardouswaste for consolidation and subsequent transfer off-site.Permit Type/Governing Agency Permit No. Expiration. DateHazardous Waste Operating (TSDF)Department of the EnvironmentState of MarylandA-151 09/09/18Industrial PretreatmentDepartment of Public WorksBureau of Water and WastewaterCity of BaltimoreAir QualityAir Management AdministrationDepartment of the EnvironmentState of MarylandFlammable Storage PermitFire Department, City of BaltimoreOil OperationsDepartment of Environment1-01818 05/31/14510-2260 7/31/201498742 12/14/112000-0PT-3063 06/03/10Oil OperationsDepartment of Environment 2010-OPT-3063 5/18/2015Principal 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 found 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 ofBaltimore's facility operations or compliance:Operations:Regulatory:RCRA Compliance &Permitting:RCRA Enforcement:Water QualityPOTW:Air Pollution:Ed Romeo, General ManagerClean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230410.244.8200Susan Richardson, Facility Compliance ManagerClean Harbors of Baltimore, Inc.1910 Russell StreetBaltimore, MD 21230410.244.8200Amin YazdanianPermittingMaryland Department of the Environment1800 Washington BoulevardBaltimore, MD 21230410.537.3345Olga PatovRCRA EnforcementMaryland Department of the Environment1800 Washington BoulevardBaltimore, MD 21230410.537.3345Mark Courtney, Pollution Control AnalystDepartment of Public WorksCity of Baltimore8201 Eastern AvenueBaltimore, MD 212247410.396.9695Gregory Franzoni, Sr. Public Health EngineerAir management AdministrationMaryland Department of the Environment1800 Washington BoulevardBaltimore, MD 21230410.537.32318

4.0 Process DescriptionOrganic Aqueous Waste TreatmentThe facility utilizes highly refined processes that remove heavy metals, suspended solids andorganics from liquid wastes and render the effluents safe for discharge into municipal sewersystems.Clean Extraction System - Aqueous waste streams containing upwards of 30 percent organicsare detoxified with the Clean Extraction System (CES) process. CES extracts organic chemicalsfrom aqueous streams utilizing high pressure liquefied Carbon Dioxide in a counter currentextraction column. Organics, which are soluble in liquefied Carbon Dioxide, are separated fromthe water phase resulting in a clean effluent and a liquid CO2/organic extract. The extract isslightly reduced in pressure and heated, vaporizing the CO2 and leaving an extremelyconcentrated organic stream that can be recycled as a hazardous waste fuel or incinerated offsite.The vaporized Carbon Dioxide is recompressed and recycled through the process. Theaqueous effluent of the process is polished as necessary to remove any residual organics andmetals with granular activated carbon and filters and subsequently discharged into the POTWsewer system.Inorganic Aqueous Waste TreatmentThe facility utilizes highly refined, multi-stage, chemical precipitation processes that removeheavy metals, suspended solids and residual organics from liquid wastes and render the effluentssafe for discharge into municipal sewer systems. Resulting precipitated residues are dewateredwith a filter press, and then disposed of in an approved landfill.Chemical Precipitation - All aqueous wastes are eventually mixed together and processed on acontinuous flow basis through a multi-compartmental specially designed treatment unit, wherepredetermined amounts of treatment chemicals are added and thoroughly mixed to effectprecipitation of heavy metals and coagulation of suspended particles. Coagulated solids areremoved in the form of sludge by gravity separation through high efficiency clarifiers.Clarified effluent is stored in effluent storage tanks and is discharged into the City of BaltimoreSewer System upon confirmation of discharge permit parameters from independent certifiedlaboratory analysis. Additionally, the City of Baltimore Sewer District continuously monitorsdischarge.Chemical Oxidation/Reduction - Waste needing pretreatment to remove specific contaminantsprior to its mixing with other wastes, is batch processed into a specially designed reactor vesselfitted with dual scrubbing towers. Adding chemical reagents specific to the batch as determinedby the laboratory simulation as achieves the desired reaction. Upon completion of the reaction,each batch is tested to confirm the end result of the treatment, prior to its transfer into storagetanks for final precipitation treatment. Types of reactions carried out are: oxidation of cyanidesand phenols, ammonia removal, chelating agent removal from wastes such as boiler cleaningsolutions, reduction of hexavalent chromium to trivalent chromium, acid/base neutralization, etc.9

Acid/Base Neutralization - Although this can be a final treatment method, neutralization isoften used in conjunction with other treatment processes such as chemical precipitation, phaseseparation and oxidation/reduction treatment processes.Neutralization involves the addition of an acid or a base to a solution to adjust the pH, usually toa level between 6 and 9. Alkaline neutralization usually involves the addition of SodiumHydroxide, Potassium Hydroxide or slaked lime to an acidic wastewater to adjust the pH.Likewise, acidic neutralization involves the addition of a concentrated acid (such as SulfuricHydrochloric or Nitric) to an alkaline wastewater.Storage and Transfer of Waste OilsWaste industrial lubricating and fuel oils are stored on-site.accumulated, the waste oil is shipped off-site for reclamation.Once a sufficient quantity isContainer/Tank Storage/TransferA wide variety of wastes not acceptable for on-site treatment can be received for consolidationand transfer to other Clean Harbors' sites or select audited and approved non company-ownedsites. The facility includes storage areas for tanks and containers meeting all RCRArequirements.Railcar Storage/TransferThe facility has the ability to receive, store and ship railcars of hazardous waste. The storagearea meets all RCRA requirements.Stabilization/Solidification of Characteristic WasteThe facility is authorized to solidify non hazardous waste and stabilize D004 - D011 wastes. Theresulting de-characterized waste is then subject to management in accordance with subtitle D ofRCRA. The physical absorption method of solidification utilizes clay based absorbents and/orsynthetic polymers to absorb liquids. Cement type stabilization is the process of blending highcalcium-oxide limes with liquids/ solids to generate a gypsum-like solid. The process enablesthe hazardous waste to be contained in the gypsum-like matrix. These processes are performedin drums and other bulk containers.Container ManagementMethods of treatment in containers may include neutralization, solidification, productadulteration, carbon adsorption and blending compatible wastes. RCRA regulated liquids areconsolidated and shipped off-site for incineration. Container treatment and storage occurs inseveral permitted areas throughout the facility.10

Waste AnalysisThe Waste Analysis Plan for the facility outlines pre-qualification and on-site acceptanceanalysis requirements.Pre-QualificationPrior to acceptance and treatment of a specific waste, Waste Material Profile Sheet must besubmitted to and approved by Clean Harbors prior to any waste shipment. Waste profile can becompleted and submitted online on Clean Harbors’ website at www.cleanharbors.com. Once thewaste material is accepted for treatment/disposal, this information becomes part of the permanentrecord in the generator's file and the waste may be scheduled for shipment.On-Site Analysis/AcceptanceWith each delivery of approved waste, a sample is taken from the load and tested to determinewhether the waste is the same as the previously submitted sample. If this analysis differssignificantly from the advance sample, the waste will be deemed non-conforming. All nonconformingwastes are further analyzed to determine the best treatment alternatives, whether onsitehandling at an adjusted price or transshipment to an alternative treatment facility. Thecustomer is contacted regarding any non-conforming waste and given the option for alternatehandling or return of their waste. On specification shipments are processed with one or more ofthe storage or treatment operations previously identified.5.0 Closure PlanA comprehensive facility closure plan has been developed in accordance with RCRArequirements and is available at the site for inspection upon request. A Certificate of Insuranceguarantees financial assurance for closure.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.Clean Harbors purchases an insurance program for Closure (Post-Closure and Corrective Actionwhere so required) in amounts that meet regulatory requirements.11

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 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=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.1910 Russell Street, Baltimore, MD 21230 410.244.8200 www.cleanharbors.com13