Document b57ZXpkOqja5ZdqY1DBd09J6k

NEICVP1493E01 NEIC CIVIL INVESTIGATION REPORT Clean Harbors Environmental Services, Inc. 51 Broderick Road Bristol, Connecticut 06010 Investigation Dates: December 6 - 13, 2022 Weaver Digitally signed by Weaver, Megan , Me ga n Date: 2023.07.17 12:26:41 -06'00' Megan Weaver, P.E. Project Manager, NEIC RICHARD Digitally signed by RICHARD MARTINEZ MARTINEZ Date: 2023.07.17 14:25:24 -06'00' Richard Martinez Analytical Project Manager, NEIC Authorized for Release by: MICHAEL Digitally signed by MICHAEL ROACH ROACH Date: 2023.07.18 09:20:03 -06'00' Mike Roach, Acting Field Branch Manager, NEIC Report Prepared for: Mary Jane O'Donnell EPA Region 1 5 Post Office Square, Suite 100 Boston, Massachusetts 02109 NATIONAL ENFORCEMENT INVESTIGATIONS CENTER P.O. Box 25227 Building 25, Denver Federal Center Denver, Colorado 80225 Page 1 of 19 CONTENTS INVESTIGATION OVERVIEW ............................................................................................................ 3 PROJECT OBJECTIVE .................................................................................................................... 3 FACILITY CONTACT INFORMATION ............................................................................................. 3 FACILITY OVERVIEW .................................................................................................................... 3 RCRA Applicability ................................................................................................................... 4 FACILITY OPERATIONS SUMMARY .............................................................................................. 4 FIELD ACTIVITIES SUMMARY....................................................................................................... 8 Measurement and Sampling Activities ................................................................................... 9 LABORATORY ACTIVITIES SUMMARY........................................................................................ 10 ANALYTICAL RESULTS................................................................................................................ 13 INVESTIGATION OBSERVATIONS................................................................................................... 15 TABLES Table 1. PROJECT TEAM MEMBERS ................................................................................................ 3 Table 2. FACILITY CONTACT INFORMATION ................................................................................... 3 Table 3. INDUSTRY CLASSIFICATION ............................................................................................... 4 Table 4. FIELD MEASUREMENT AND FIELD SAMPLING ACTIVITIES .............................................. 10 Table 5. ANALYTICAL OBJECTIVE, TECHNIQUE, AND METHOD; ANALYST; AND DATE PERFORMED ....................................................................................................................................................... 11 Table 6. SUMMARY OF ANALYTICAL RESULTS .............................................................................. 14 FIGURES Figure 1. Waste Treatment Facility (Appendix A, page 88) ............................................................ 6 Figure 2. Truck Parking Areas and Truck to Truck Transfer Area (Appendix A, page 91)............... 7 APPENDICES (*NEIC-created document) A September 29, 2021, Clean Harbors Bristol RCRA Operating Permit No. DEEP/HWM-017-004 (612 pages) B Wastewater Treatment Flow Diagram (1 page) C Inspection Photographs* (25 pages) D NEIC Hardcopy Document Log* (1 page) E Sample Chain of Custody Record* (1 page) F Laboratory Photographs and Sample Physical Descriptions* (8 pages) G Eversource Waste Material Profile Sheet No. CH8387BWMA (5 pages) H Stabilization Batch No. 1798 Documentation (8 pages) I Select 2022 Stabilization Batch Sheets (12 pages) J Keymark Hazardous Waste eManifest 016377424FLE (1 page) K Keymark Waste Material Profile Sheet No. CH365148B (5 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. NEICVP1493E01 Page 2 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut INVESTIGATION OVERVIEW PROJECT OBJECTIVE U.S. Environmental Protection Agency (EPA) Region 1 (Region) requested EPA's National Enforcement Investigations Center (NEIC) to conduct a Resource Conservation and Recovery Act (RCRA) compliance investigation of the Clean Harbors Environmental Services, Inc. (Clean Harbors) facility located at 51 Broderick Road in Bristol, Connecticut. The investigation assessed Clean Harbors' compliance with federal environmental statutes and permit requirements. Table 1 lists the project team members. Team Member Megan Weaver Brian Kennedy Craig Lutz Zach Schlachter Richard Martinez Alexis Espino Erick Zacher James Carew Conor O'Brien Mary Jane O'Donnell Lisa Papetti Cheryl Wilkinson Table 1. PROJECT TEAM MEMBERS Organization NEIC NEIC NEIC NEIC NEIC NEIC NEIC REGIONAL AND OTHER CONTACTS EPA Region 1 EPA Region 1 EPA Region 1 EPA Region 1 EPA Region 1 Project Role Project manager Field team member Field team member Field Team Member Analytical project manager Laboratory team member Laboratory team member Regional field team member Regional field team member Primary regional contact Regional contact Regional field team member FACILITY CONTACT INFORMATION Table 2 lists the primary facility contacts. Table 2. FACILITY CONTACT INFORMATION Name, Title Phone No. Email Address Bryan Campbell, General Manager 860-384-2008 Campbell.Bryan@cleanharbors.com James Childress, VP Environmental Compliance Not Provided Childress.james@cleanharbors.com Don Smith, Environmental Compliance Manager 617-721-7315 Smith.Donald@cleanharbors.com FACILITY OVERVIEW Clean Harbors operates a licensed RCRA Part B treatment, storage and disposal facility (TSDF) offering treatment of inorganic non-hazardous and listed/characteristic hazardous waste. This may include lab packs as well as stabilization to make the wastes suitable for transport, off-site treatment, or disposal. NEICVP1493E01 Page 3 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The facility accepts hazardous wastes and polychlorinated biphenyls (PCBs) for storage, consolidation, and transfer to other facilities owned by the company or to external facilities for off-site treatment and disposal. Additional processes on-site include drum rinsing and crushing, disassembly and consolidation of lab packs, lab pack pour-off, and paint container processing. According to the EPA Envirofacts database, this facility has the following North American Industry Classification System (NAICS) codes (Table 3): NAICS Code 562 562112 562211 Table 3. INDUSTRY CLASSIFICATION Description Waste management and remediation services Hazardous waste collection Hazardous waste treatment and disposal RCRA Applicability Clean Harbors (EPA ID No. CTD000604488) is a TSDF and a large quantity generator (LQG) of hazardous waste. The facility has been permitted by the Connecticut Department of Energy and Environmental Protection (CTDEEP) to receive, store, consolidate, treat, and transfer a variety of hazardous and non-hazardous waste streams (permit No. DEEP/HWM-017-004). A RCRA permit renewal was issued in September 2021. According to EPA's Envirofacts database, four RCRA informal notices of violation and two formal enforcement actions were taken by CTDEEP in the last 5 years. EPA's RCRAInfo database shows a formal action in 2020 from CTDEEP related to land disposal restrictions, the contingency plan and emergency procedures, and other undefined permit conditions. The database also shows a formal action in 2019 from CTDEEP related to the contingency plan and emergency procedures. FACILITY OPERATIONS SUMMARY Clean Harbors' September 29, 2021, RCRA operating permit (Appendix A) summarizes the facility's waste management areas and operations as: (1) Container Storage Areas (Non-bulk containers and 30-day roll-off storage); a. 44,880 total gallons in the 9 container storage area. (2) Bulk Unloading and Loading Area (BULA); a. 13,200 gallons in vehicles (3) Five Day Container Staging Area ("M1", "M2", and "H"); a. 20,570 gallons b. Area "H" is used for sampling and staging waste or other materials in containers prior to: i. pumping such waste or other materials into the on-site wastewater treatment system; NEICVP1493E01 Page 4 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ii. pumping such waste into Tanks 11 or 14; iii. treating such waste in the mix-tub; iv. relocation to a designated container storage area or off-site shipment; and v. over-pack containers of waste or other materials whose integrity has been compromised. c. Area "M1," is used for sampling and staging of acidic waste or other material in containers prior to relocation to a designated container storage area and over-pack containers of waste or other material whose integrity has been compromised. d. Area "M2," is used for sampling and staging of alkaline waste or other material in containers prior to relocation to a container storage area and over-pack containers of waste or other material whose integrity has been compromised. e. The maximum storage time to stage containers in these areas is 5 consecutive days. (4) Area for Tank Systems 11 and 14 (storage and treatment of wastes with volatile organic concentrations (VOCs) of less than 500 parts per million by weight [ppmw]); a. Tank No. 11 - 4,116 gallons b. Tank No. 14 - 10,836 gallons (5) Mix-Tub (Solidification and Stabilization), Bulk Storage and Transfer Area (MBSTA); a. 460 cubic yards in roll-offs when no vacuum trucks are present in the MBSTA b. Mix tub - 27 cubic yards c. The Mix-Tub Area is used to: i. solidify hazardous and non-hazardous waste by means of mixing such wastes with a solidification agent (i.e., paper pulp, saw dust, corncob grit) to render such waste more amenable to off-site treatment or disposal; and ii. stabilize hazardous wastes in a mix tub by means of mixing such wastes with a stabilization reagent (i.e., cement kiln dust, lime, or fly ash). (6) Miscellaneous Processing Areas (MPA) (Drum Rinsing and Crushing; and Lab Pack Pour-off Station); a. Located in the Operation Process building. The MPA has one area to rinse 55gallons drums, one area to crush 55-gallons drums, and one as a lab-pack pour-off area. (7) Truck-to-Truck Transfer Area (TTTA), including Loading/Unloading Dock a. 5,060 gallons NEICVP1493E01 Page 5 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut b. Used to transfer permitted wastes from one vehicle to another vehicle (specifically trailers) or to receive containerized wastes into the facility or load containerized wastes from the facility onto trailers. Trailers with containerized wastes cannot remain at the trailer staging area for longer than 3 consecutive days. (8) Truck (Trailer Staging) Parking Areas #1 and #3 for up to 10-days or less a. Parking Area #1 - 25,300 gallons b. Parking Area #3 - 5,060 gallons c. Store hazardous and non-hazardous wastes in trailers and roll-offs. These areas are not allowed to have trailers with containerized wastes for longer than 10 days. A facility overview diagram is available in Appendix A, page 86. The following figures show the permitted waste storage areas within the waste treatment facility (Figure 1), and the TTTA (Figure 2). Figure 1. Waste Treatment Facility (Appendix A, page 88) NEICVP1493E01 Page 6 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Figure 2. Truck Parking Areas and Truck to Truck Transfer Area (Appendix A, page 91) Truck-to-Truck Transfer (TTT) The majority of the incoming waste is transferred to other permitted RCRA facilities for treatment or disposal, through the TTTA. About 10% of the incoming waste is treated on site, while the rest is shipped out to another TSDF. The TTTA allows for trailers and shipping vehicles to be backed up directly to the loading dock. Clean Harbors personnel will then transfer the drums or containers of waste directly to another truck that is waiting to ship the waste off-site. Wastewater Treatment (WWT) When liquid waste is brought to Clean Harbors, it is classified into one of three categories and pumped into a designated treatment or "reactor" tank to prevent the mixing of incompatible wastes 1. Acidic 2. Alkaline 3. Special wastes or strong acid The liquid wastes are pumped from the BULA to the hydrocyclone. The hydrocyclone is the first separation of the liquids from the solids using high speed rotation. The solids are moved to the mix tub for treatment, as appropriate, or separately disposed according to the waste profile associated with the original liquid waste. The liquids are pumped from the hydrocyclone to one NEICVP1493E01 Page 7 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut of the treatment tanks (Tanks 4/5/6/7), also called the "reactors." The reactor tanks are the primary treatment vessels for liquid waste on-site. Treated waste from the reactors containing greater than 20% solids is pumped to the filter press to remove the remaining solids. Solids from the filter press are removed for disposal according to the original waste profile, and the liquid from the filter press is pumped to the effluent storage tanks (1A/1B/2A/2B/3B) prior to discharge to the publicly owned treatment works. At the time of NEIC's inspection, only effluent tanks 1B and 2B were in use. Treated wastewater containing less than 20% solids is pumped to a centrifuge to remove fine solids, which are also disposed according to the original waste profile. The liquid is then pumped to effluent tanks 1B or 2B for discharge or re-treatment though the centrifuge as needed. Tanks 1 (caustic storage tank), 10, 11, 14 (waste oil storage tank), and 15 (alkaline storage tank) can be filled directly from the BULA if storage of waste is needed prior to treatment in the reactors. Tanks 1 (caustic storage tank), 22 (carbon/lime slurry), 27 (sulfuric acid), 28 (bleach), and 30 (ferric chloride) are utilized as storage tanks for treatment chemicals necessary to treat the waste in the reactors. A detailed diagram of the wastewater treatment system is in Appendix B. FIELD ACTIVITIES SUMMARY The NEIC field team was joined by James Carew, Conor O'Brien, and Cheryl Wilkinson of EPA Region 1 during the on-site inspection. On December 6, 2022, NEIC inspectors conducted an opening meeting and presented credentials to David Berggren, Clean Harbors' maintenance manager. NEIC performed the following activities to accomplish the investigation objectives: Discussed with facility personnel Clean Harbors' waste screening, acceptance, and tracking procedures, and on-site treatment and storage practices. Conducted tours of the facility to observe process operations, waste acceptance activities, waste treatment operations, and sampling procedures. Conducted a tour of the on-site laboratory to evaluate the screening and analysis of incoming wastes. NEICVP1493E01 Page 8 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  Conducted volatile organic compound (VOC) screening using a forward-looking infrared (FLIR) camera and a photoionization detector (PID). Reviewed and copied facility documents including standard operating procedures, the facility operating permit and appendices, waste profiles, treatment packets for hazardous wastes that were treated on-site, analytical data of incoming and treated waste, and correspondence between Clean Harbors and CTDEEP. Collected samples of stabilized waste certified for disposal to determine compliance with land disposal restriction (LDR) treatment standards. Samples were split with Clean Harbors. Analyzed collected samples at the NEIC laboratory. Photographs taken during the inspection are included in Appendix C. A log of the hardcopy documents NEIC copied during the inspection is in Appendix D. Electronic documents received during the inspection are maintained in the project file. Measurement and Sampling Activities The NEIC field team provided support to this investigation by collecting samples of stabilized waste for LDR treatment verification purposes. The NEIC field team also conducted VOC screening of process equipment using a FLIR camera, operated by Brian Kennedy and a PID. Table 4 summarizes field measurement and field sampling activities. Additional information can be found in the project file. A copy of the chain of custody record is provided in Appendix E. NEIC collected and analyzed samples of treated hazardous wastes. NEIC collected five grab samples from one roll-off container, designated CHRT26905 (S01-S05; Appendix C, photos 2345). Container CHRT26905 held four batches of treated waste that had been consolidated. The waste batch Nos. were 1791, 1793, 1795, and 1795a. The five grab samples were split with Clean Harbors. All environmental measurement activities were performed in accordance with the NEIC quality system. All field sampling, field measurements/monitoring, and laboratory measurements described in this report are within the scope of NEIC's ISO/IEC 17025 accreditation issued by the ANSI National Accreditation Board (certificate No. FT-0303). NEICVP1493E01 Page 9 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Table 4. FIELD MEASUREMENT AND FIELD SAMPLING ACTIVITIES Location Identifier Dates Method, and/or Procedure1, and Equipment MEASUREMENTS Outdoor roll-off container CHRT26905, tanks 10 and 14 December 7 and 8, 2022 NEIC procedure: Safety and Sample Screening Instruments, NEICPROC/17-002 Instrument guides: MSA Altair 5X Multi-Gas Monitoring Equipment RadEye B20-ER - Radiation Detection Equipment Equipment: MSA Altair 5X multiple gas meter, SN2624 RadEye survey meter, SN 33863 SAMPLING Station No. Sample Location Appendix C Photo Nos. Date and Time Sampling Technique Method, and/or Procedure, and Equipment Mix tub December S01 pad, roll-off 23, 24, 36, and 37 7, 2022 container 9:47 a.m. CHRT26905 Mix tub December S02 pad, roll-off 7, 2022 container 25, 26, 38, and 39 9:56 a.m. CHRT26905 Mix tub December Method: ASTM D5633: Standard Practice for Sampling with a Scoop NEIC procedure: S03 cpoandt,arionlel-roff 27, 28, 40, and 41 71, 02:00262, Gsarmabple SSoamil apnlidngS/oSlcidoops, CHRT26905 a.m. Mix tub December S04 pad, roll-off 29, 30, 42, and 43 7, 2022, container 10:16 NEICPROC/00-052 Equipment: Precleaned single-use plastic disposable scoops, CHRT26905 a.m. appropriately sized Mix tub December S05 pad, roll-off 31, 32, 44, and 45 7, 2022, container 10:24 CHRT26905 a.m. 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Brian Kennedy, Zach Schlachter Sampler Name Zach Schlachter Site activities were documented in field records. Samples collected during the field activities were shipped via FedEx to the NEIC laboratory in Denver, Colorado, for analysis. LABORATORY ACTIVITIES SUMMARY Five samples were received at the NEIC Laboratory in Denver, Colorado on December 14, 2022. On December 20, 2022, Analytical Project Manager Richard Martinez (APM Martinez) retrieved the samples and assumed custody. APM Martinez verified and signed the chain of custody. Analytical methods were selected to achieve data quality objectives for determining the concentration of inorganic metal constituents identified in the 40 Code of Federal Regulations NEICVP1493E01 Page 10 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (CFR) 268.48(a) universal treatment standards (UTS) table for non-wastewaters. Table 5 summarizes analytical objectives, techniques, and methods utilized to achieve the data quality objectives. Based on the UTS table and the analytical request, the concentration of the following metals were determined: antimony (Sb), arsenic (As), barium (Ba), beryllium (Be), chromium (Cr), cadmium (Cd), lead (Pb), mercury (Hg), nickel (Ni), selenium (Se), silver (Ag), thallium (Tl), vanadium (V), and zinc (Zn). The units reported are as milligrams per liter TCLP (mg/L TCLP) according to the UTS table for non-wastewaters. Physical sample description was performed by APM Martinez following NEIC operating procedure Physical Description/Phase Separation, NEICPROC/00-045R5. APM Martinez prepared approximately 100-gram subsamples for extraction by performing EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846) Method 1311: Toxicity Characteristic Leaching Procedure (TCLP). The TCLP extracts were digested following EPA Method 3015A: Microwave Assisted Acid Digestion of Aqueous Samples and Extracts. Following digestion, metals concentrations, except mercury, were determined following SW-846 Test Method 6010D: Inductively Coupled PlasmaOptical Emission Spectrometry (ICP-OES). Mercury in the TCLP extracts, was digested and analyzed following EPA Method 245.1: Determination of Mercury in Water by Cold Vapor Atomic Absorption Spectrometry (CVAA). Quality control for these preparations and analyses are captured, and available, in the associated laboratory data packages. Uncertainty calculations are available in the associated data packages. Laboratory observations, method modifications, and other project information are documented in the project file. A copy of the chain of custody record is provided in Appendix E. Pertinent photographs from the laboratory activities are provided in Appendix F. Table 5. ANALYTICAL OBJECTIVE, TECHNIQUE, AND METHOD; ANALYST; AND DATE PERFORMED Samples Analytical Objective, Technique, and Method NEIC Analyst Analyzed by Method (Station Dates Performed Nos.) Analytical Objective: Determine the mobility of inorganic analytes present in stabilized solid waste: EPA Test Methods for Evaluating Solid Waste: Physical/Chemical Methods Richard Martinez S01-S05 February 1317, 2023 (SW-846) Method 1311: Toxicity Characteristic Leaching Procedure (TCLP) NEICVP1493E01 Page 11 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Table 5. ANALYTICAL OBJECTIVE, TECHNIQUE, AND METHOD; ANALYST; AND DATE PERFORMED Samples Analytical Objective, Technique, and Method NEIC Analyst Analyzed by Method (Station Dates Performed Nos.) Analytical Objective: Measure the concentration of metals (except mercury) in stabilized solid waste extracts. Technique: Inductively Coupled Plasma Optical Emission Spectrometry (ICP-OES). Preparatory method: TCLP extracts were digested following EPA Method 3015A: Microwave Assisted Acid Digestion of Aqueous Samples and Extracts; from Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA publication SW-846 Analysis Method: EPA Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (SW-846) Test Method 6010D: Inductively Coupled Plasma-Optical Emission Spectrometry (ICP-OES), used as guidance, Revision 5, July 2018, Update VI to the Third Edition, EPA publication SW-846 Elemental Analyses - ICP-OES Instrument Guide, NEICGUID/18-001 as guidance Analytical Objective: Measure the concentration of mercury in extracts. Alexis Espino S01-S05 March 624,2023 Technique: Cold vapor atomic absorption spectrometry Analysis Methods: EPA. 1994. "Method 245.1: Determination of Mercury in Water by Cold Vapor Atomic Absorption Erick Zacher S01-S05 March 10-22, 2023 Spectrometry." Revision 3.0. Cincinnati, OH, and Elemental Analyses - Hg Analysis by CVAA Instrument Guide or Hg Analysis by CVAF Instrument Guide, NEICGUID/18-001 Data quality summaries, including uncertainty measurements, for all laboratory measurements are maintained in the project file. NEICVP1493E01 Page 12 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ANALYTICAL RESULTS The TCLP extract metals results and the 40 CFR 268.48 UTS for non-wastewater samples are reported in Table 6. Zinc concentrations are higher than the UTS in samples S02, S03, and S04; however, zinc is not an underlying hazardous constituent in the waste that was sampled by NEIC, as specified in footnote 5 of 40 CFR 268.48, Table UTS--Universal Treatment Standards. Underlying hazardous constituent means any constituent listed in 40 CFR 268.48, Table UTS-- Universal Treatment Standards, except fluoride, selenium, sulfides, vanadium, and zinc, which can reasonably be expected to be present at the point of generation of the hazardous waste at a concentration above the constituent-specific UTS treatment standards. NEICVP1493E01 Page 13 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Table 6. SUMMARY OF ANALYTICAL RESULTS TCLP ELEMENTAL RESULTS AND 40 CFR 268.48 UNIVERSAL TREATMENT STANDARDS FOR NONWASTEWATER SAMPLES (milligrams per liter [mg/L]) Station No. Silver Arsenic Barium Berylium Cadmium Chromium Nickel Lead Antimony Selenium Thallium Vanadium Zinc5 Mercury S01 <0.024 0.486 0.078 2.90 S021 S03 Org2 S03 Dup2 S03 Trip2 <0.009 <0.597 <2 <0.003 <0.021 0.029 0.039 0.037 0.044 0.116 0.126 0.124 0.130 <0.135 <0.105 <0.078 <0.078 0.090 <0.078 <0.069 <0.012 8.00 6.23 4.82 <0.005 5.68 S04 0.027 0.104 <0.078 6.23 S053 0.035 0.101 <0.078 2.73 Universal Treatment 0.14 5 21 1.22 0.11 0.6 11 0.75 1.15 5.7 0.2 1.6 4.3 0.025 Standards4 1 Results from sample S02 are the average of three analytical replicates. 2 S03 was prepared and measured in triplicate for TCLP extractions. Each replicate TCLP extraction is reported separately. 3 Results from sample S05 are the average of four replicate digestions. 4 For determining compliance with treatment standards for underlying hazardous constituents as defined in 40 CFR 268.2(i), these treatment standards may not be exceeded. Compliance with these treatment standards is measured by an analysis of grab samples, unless otherwise noted in the following Table UTS. 5 As specified in footnote 5 of 40 CFR 248.48, Table UTS, zinc is not an underlying hazardous constituent in characteristic wastes, according to the definition at 40 CFR 268.2(i). NEICVP1493E01 Page 14 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut INVESTIGATION OBSERVATIONS NEIC made the following observations during the RCRA compliance inspection. NEIC field team members discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description below. These observations are not final compliance determinations. EPA Region 1 will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. Observation 1 Observation Summary: Clean Harbors adds significant quantities of paper pulp to hazardous waste during the stabilization process. Supporting Information: Appendix G - Eversource Waste Material Profile Sheet No. CH8387BWMA Appendix H - Stabilization Batch No. 1798 Documentation Appendix C - Inspection Photographs Appendix I - Select 2022 Stabilization Batch Sheets Description of Observation: On December 8, 2022, the NEIC field team observed Clean Harbors personnel perform stabilization of hazardous waste batch No. 1798 in its mix tub unit. The hazardous waste to be stabilized was generated during manhole cleanout operations at Eversource Energy in Stamford, Connecticut. Clean Harbors had previously profiled the waste stream in waste material profile sheet No. CH8387BWMA (Appendix G). The profile sheet states the material exhibits the hazardous waste toxicity characteristic for lead, as represented by EPA hazardous waste No. D008. The initial quantity of D008 hazardous waste added to the mix tub was 3,220 pounds, as reflected in both the incoming manifest and Clean Harbors' mix tub batch sheet (Appendix H). The waste observed in the mix tub prior to treatment appeared to be a black sludge with gravel and water (Appendix C, photo 46). After the waste was added to the mix tub, Clean Harbors used a hose to remove free liquid from the mix tub. The removed liquid was pumped inside the main building for solids separation in the hydrocyclone. The mix tub batch sheet (Appendix H, page 8) indicates that approximately 224 gallons, or 1,869 pounds, of liquid was removed from the mix tub. The batch sheet indicates that after the liquid was removed, 1,351 pounds of waste remained within the mix tub. The mix tub operator then calculated the quantity of reagents necessary to treat the waste based on the waste remaining in the tub. The calculation is based on a treatment recipe that had been determined for the waste profile during bench-scale testing at the on-site laboratory. The NEIC field team observed Clean Harbors personnel stabilize the hazardous waste remaining in the mix tub. The operator first added four 94-pound bags of portland cement to the mix tub (Appendix C, photo 47). Two 50-pound bags of ferrous sulfate and two 50-pound bags of lime were also added to the tub (Appendix C, photo 48). An excavator stationed at the mix tub mixed the reagents with the waste for approximately 1 hour (Appendix C, photo 49). After mixing, the waste in the mix tub resembled a homogenous brown sludge NEICVP1493E01 Page 15 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Observation 1 (Appendix C, photo 50). The operator then added five excavator buckets of dry paper pulp to absorb the remaining liquid in the mix tub. Photo 51 in Appendix C displays the addition of the first of five excavator buckets of paper pulp to the mix tub. The final batch sheet indicates that the five excavator buckets contained approximately 4,000 pounds of paper pulp (Appendix H, page 8). After mixing in the paper pulp with the excavator, the waste (now referred to as treatment residue) within the mix tub resembled a dry, dark brown sludge (Appendix C, photo 52). The NEIC field team observed the mix tub operator collect a sample of the treatment residue. The operator collected four increments from the surface of the treatment residue to fill a 250milliliter (mL) plastic cup. The cup was taken to the on-site laboratory, and the sample was transferred to a 250-mL amber jar (Appendix C, photo 53). The amber jar was later shipped to ACT Laboratories for analysis; the analytical results would be compared to the LDR treatment standards. Based on the information above, Clean Harbors added approximately 4,000 pounds of paper pulp to 1,351 pounds of hazardous waste during the stabilization of batch No. 1798, or roughly a 3 to 1 ratio of paper pulp to waste. Additionally, the treatment residue was sampled for LDR verification analysis only after the paper pulp was added to the mix tub. The NEIC field team reviewed example stabilization batch sheets from 2022 of the same waste stream observed during the inspection (Appendix I). The table below provides stabilization batches where the ratio of paper pulp to hazardous waste was greater than one (i.e., when the mass of added paper pulp was greater than the mass of waste): Stabilization Batch Completion Date Mix Tub Batch Number Pounds of waste added to mix tub 2/18/2022 1447 12,960 3/29/2022 1503 2,300 4/28/2022 1540 7,020 7/29/2022 1652 2,340 8/31/2022 1699 6,860 11/23/2022 12/8/2022 1790 17981 260 3,220 12/13/2022 1801 5,220 1Observed by the NEIC field team. Pounds of liquid removed from mix tub 11,616 0 3,988 0 5,607 0 1,869 4,906 Pounds of waste remaining in mix tub 1,344 2,300 2,840 2,340 1,247 260 1,351 314 Pounds of paper pulp added to mix tub 5,000 4,000 4,000 3,500 2,000 1,000 4,000 2,500 Ratio of paper pulp to waste 3.7 1.7 1.4 1.5 1.6 3.8 3.0 8.0 Observation 2 Observation Summary: Clean Harbors was not accumulating hazardous waste at or near the point of waste generation. Hazardous waste generated and accumulated in satellite containers in the on-site laboratory are later moved and consolidated into a separate container in the facility's wastewater treatment area. Clean Harbors does not consider the container in the wastewater treatment area to be in a 90-day accumulation area. Supporting Information Appendix C - Inspection Photographs NEICVP1493E01 Page 16 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Observation 2 Description of Observation: Clean Harbors moves accumulated hazardous waste from one satellite accumulation area (SAA) to a separate waste container away from the point of generation. During NEIC's inspection, Clean Harbors accumulated hazardous wastes in SAAs located in the on-site laboratory and later moved the wastes to a second container located outside of the laboratory. Once the SAA containers in the laboratory were full (Appendix C, photos 55 and 58), the hazardous waste was moved to and consolidated in a second container (Appendix C, photo 59) near tank 2 in the wastewater treatment area before it is pumped into tank 2 for treatment. The point of hazardous waste generation, in the laboratory, is not near the second container at tank 2, and the second container is also not under the control of the operator. Once hazardous waste leaves a SAA, it must be destined for a 90-day accumulation area, a permitted or interim status container storage area or unit, or off-site. Clean Harbors does not consider the second waste accumulation container near tank 2 to be a 90-day accumulation area. The second container was not labeled with a date of when the waste accumulation period began. Observation 3 Observation Summary: Clean Harbors improperly labelled containers of hazardous waste on-site. Supporting Information Appendix C - Inspection Photographs Appendix G - Eversource Waste Material Profile Sheet No. CH8387BWMA Description of Observation: At the time of NEIC's inspection, hazardous waste containers in Clean Harbors' container storage area K6 had discrepant Department of Transportation (DOT) markings. Several plastic totes in the area had hazardous waste labels that indicated they contained EPA hazardous waste No. F006, wastewater treatment sludges from electroplating operations. The hazardous waste labels were also marked with a DOT United Nations (UN) number UN1760, which represents corrosive liquids, not otherwise specified. However, additional DOT placards on the containers indicated they contained a corrosive UN1791 material, which represents hypochlorite solutions. At least eight totes were marked with UN1791 indicators, but with UN1760 and the F006 waste number on the label (Appendix C, photos 7, 8, and 9). During the inspection, Clean Harbors representatives were made aware of the discrepant labeling on the totes and removed the UN1791 placards from each container. Additionally, on December 6, 2022, NEIC inspectors observed a roll-off container of stabilized hazardous waste that was pending analysis after treatment. The container, numbered CHRT26905 and later sampled by NEIC on December 7, 2022, contained treated waste that had previously been characterized with EPA hazardous waste No. D008 in material profile sheet No. CH8387BWMA (Appendix G). The profile sheet describes the waste as manhole sludge from cleanout operations at Eversource Energy in Connecticut. Although the material in the roll-off container had been characterized as D008 hazardous waste, the container's hazardous waste label described the material as "Listed Solids for Stabilization" (Appendix C, photos 22, 34, and 35). The description on the label implied the container held listed hazardous waste when in fact the container only held characteristic hazardous waste. On December 8, 2022, the NEIC field team observed Clean Harbors personnel perform stabilization of hazardous waste batch No. 1798 in its mix tub unit. The hazardous waste to NEICVP1493E01 Page 17 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Observation 3 be stabilized was another batch of the same waste stream seen in the roll-off container on December 6, 2022 (D008 hazardous waste manhole cleanout sludge) (Appendix G). At the time of treatment, the mix tub's hazardous waste label described the material as "Listed Solids for Stabilization" (Appendix C, photo 52). The description on the label implied the mix tub held listed hazardous waste when in fact it only held characteristic hazardous waste. Observation 4 Observation Summary: Clean Harbors operates a filter press as part of their wastewater treatment system. The filter press is open on the bottom and drops filter cake and wastewater into a roll-off box below and onto the floor. At times, the wastewater treatment system is processing listed hazardous waste (EPA hazardous waste Nos. F006 and F019). Supporting Information: Appendix C - Inspection Photographs Description of Observation: Clean Harbors operates a wastewater treatment system under pretreatment permit identification No. SP0000109 issued by CTDEEP on October 4, 2021. Clean Harbors accepts listed hazardous wastewaters and wastewaters that generate F006 and F019 listed sludges after treatment. One of the units that is in the wastewater treatment system is a plate filter press (Appendix C, photos 61-64). The filter press is constructed with an opening in the bottom (Appendix C, photo 63) to drop the filter cake directly into containers below (Appendix C, photo 61). NEIC inspectors observed filter cake and wastewater on the floor beneath the filter press (Appendix C, photo 61). Observation 5 Observation Summary: Clean Harbors' representatives stated the acceptance limit for VOC screening with a PID is 1,400 ppm for incoming wastes. The facility's RCRA operating permit has a screening acceptance limit of 400 ppm VOCs. Supporting Information: Inspector observations Description of Observation: According to facility personnel and as observed and documented by the NEIC field team, Clean Harbors currently collects a small sample of incoming bulk loads in a jar and screens the headspace in the jar with a PID in the on-site laboratory. NEIC observed the laboratory personnel performing this measurement. David Berggren, Clean Harbors' maintenance manager stated that their acceptance limit for VOC screening with the PID is 1,400 ppm. Observation 6 Observation Summary: Clean Harbors stored a D002 corrosive hazardous waste received from off-site, containing 50-60% sodium hydroxide, in Tank 10. Tank 10 is part of the wastewater treatment system. Clean Harbors claimed a wastewater treatment unit exemption for storing the material before it is used for pH adjustment in the wastewater system. Supporting Information: Appendix B - Wastewater Treatment Flow Diagram Appendix J - Keymark Hazardous Waste eManifest 016377424FLE NEICVP1493E01 Page 18 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Observation 6 Appendix K - Keymark Waste Material Profile Sheet No. CH365148B Description of Observation: Tank 10 is part of the wastewater treatment system (Appendix B). Tank 10 stores sodium hydroxide solution used to adjust the pH in the wastewater treatment system. The wastewater treatment system has a pretreatment permit issued by CTDEEP. The sodium hydroxide solution is shipped to Clean Harbors on a hazardous waste manifest as a corrosive hazardous waste with EPA hazardous waste No. D002 (Appendix J). According to section D of the waste material profile sheet for the sodium hydroxide solution (Appendix K), the chemical composition of the waste is listed as 15% dissolved aluminum, 50-60% sodium hydroxide, and 40-50% water. Clean Harbors representatives stated that storing the sodium hydroxide solution in Tank 10 was exempt from the hazardous waste management requirements under the wastewater treatment unit exemption. Observation 7 Observation Summary: Clean Harbors operates the mix-tub without side panels and does not utilize a cover on top during non-operational times as required by the permit. Supporting Information: Appendix A - September 29, 2021, Clean Harbors Bristol RCRA Operating Permit No. DEEP/HWM-017-004 Appendix C - Inspection Photographs Description of Observation: Clean Harbors' current RCRA permit requires the mix-tub to be covered with a tarp or plastic liner when not in use and to have attached side panels to prevent waste from leaving the tub during treatment (Appendix A, page 144). The mix-tub at Clean Harbors does not have a physical cover and was not covered with any tarp or plastic liner when not in use (Appendix C, photos 17-18). The unit also does not have sides or side panels, and no panels are present while waste is in the mix-tub or during treatment operations (Appendix C, photos 49, 51, and 52). On December 8, 2022, the NEIC field team observed no side panels on the mix-tub when hazardous waste was being stabilized in the unit, as described in Observation 1, above. James Childress, VP of Environmental Compliance, stated during the inspection that the company is pursuing replacing the mix-tub and does not want to install a cover or side panels before the unit is replaced. NEICVP1493E01 Page 19 of 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix A September 29, 2021, Clean Harbors Bristol RCRA Operating Permit No. DEEP/HWM-017-004 (612 pages) NEICVP1493E01 NEICVP1493E01 Appendix A Page 1 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 2 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut FACT SHEET COMMERCIAL RCRA1 HAZARDOUS WASTES AND CONNECTICUT 22a-454 WASTES FACILITY RENEWAL PERMIT (A) FACILITY: Clean Harbors of Connecticut, Inc. 51 Broderick Road, Bristol, CT 06010 Contact Person: Bryan J. Campbell, Facility General Manager Telephone Number: (860) 583-8917 Email: campbell.bryan@cleanharbors.com (B) FACILITY TYPE. Clean Harbors of Connecticut, Inc., (hereinafter, "the Permittee" or "CHC") seeks authorization to continue the transfer, storage, treatment, recycling, and management of wastes accepted from off-site locations as well as wastes generated from on-site activities. Such wastes are identified as (1) listed and exhibits the characteristics of hazardous wastes under the Resource Conservation and Recovery Act (RCRA) in accordance with Connecticut's Hazardous Waste Management Regulations, Section 22a449(c)-104; (2) Universal Wastes in accordance with Connecticut's Hazardous Waste Management Regulations, Section 22a-449(c)-113; (3) Used Oil in accordance with Connecticut's Hazardous Waste Management Regulations, Section 22a-449(c)-119, and (4) Non-RCRA hazardous wastes (hereinafter "Non-RCRA Wastes"). CHC typical operating hours for receipt of wastes are from 7:00 am to 7:00 pm, Monday through Friday, Saturday and Sunday hours as needed. The activities are located at 51 Broderick Road, Bristol, Connecticut. (C) WASTE MANAGEMENT AREAS/UNITS. The waste management areas are: (1) Container Storage Areas (Non-bulk containers and 30-Day roll-off Storage); (2) Bulk Unloading and Loading Area (BULA); (3) Areas to Stage Container for up to Five (5) days ("M1", "M2", and "H"); (4) Area for Tank Systems 11 and 14; (5) Mix-Tub (Solidification and Stabilization), Bulk Storage and Transfer Area (MBSTA); (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing; and Lab Pack Pour-off Station); (7) Truck-to-Truck Transfer Area (TTTA), including Loading/Unloading Dock (Containers) (Trailer Staging Area for up to three (3) consecutive Days); and (8) Truck (Trailer Staging) Parking Areas #1 and #3 for up to 10-Days or less. 1 Note: RCRA means the Resource Conservation and Recovery Act (RCRA). RCRA is a federal law that focuses on the recovery and recycling of wastes. It defines what wastes are hazardous, requires generators of hazardous waste to track the transportation of the waste from point of generation to its final disposal; operate treatment and disposal facilities in accordance with established standards; and manage hazardous waste properly. NEICVP1493E01 Appendix A Page 3 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The Facility is designed to manage on-site the following volumetric quantities of wastes: (1) Container Storage Area capacity is 44,880 gallons; (2) Tank No. 14 (storage and treatment of wastes with Volatile organic concentration of less than 500 ppmw) capacity is 10,836 gallons; and Tank No. 11 (storage and treatment with Volatile organic concentration of less than 500 ppmw) capacity is 4,116 gallons; (3) A maximum of 460 cubic yards in roll-offs only if there are no Vacuum Trucks in the MBSTA (for up to 30days); (4) 25,300 gallons in Trailer Parking Area 1 for up to 10 Days and 5,060 gallons in Trailer Parking Area 3 for up to 10-Days; (5) 20,570 gallons in the Container Staging Areas for up to five (5) days; (6) 13,200 gallons in Transportation Vehicles in the Bulk Unloading/Loading Area (BULA); (6) stabilization and solidification is conducted in a Mix-Tub with a capacity of 27 cubic yards; and (7) 5,060 gallons in the Truck to Truck Loading/Unloading Dock. All wastes are stored and shipped off-site in containers or vehicles that have been approved by the U.S Department of Transportation, for such use, to a permitted or approved disposal facility. No disposal occurs at the 51 Broderick Road Site. (1) Container Storage Areas. These areas are utilized to store hazardous and nonRCRA hazardous wastes received from off-site or generated on-site that either need further processing or are bound for off-site shipment and disposal. (2) Bulk Unloading and Loading Area (BULA). This area is utilized pump waste or other material in liquid form from a Transportation Vehicle or from containers to the On-Site Wastewater Treatment System; pump waste in liquid form from a Transportation Vehicle into Tanks 11 and 14; load in a Transportation Vehicle, waste in liquid form that is pumped from Tanks 11 and 14 for off-site shipment; pump waste in liquid form from one Transportation Vehicle into another Transportation Vehicle; pump waste or other material in liquid form from a Transportation vehicle into a container; and store flammable wase or diesel fuel for use at the facility in containers in Storage Area C (located at the BULA). (3) Tank Storage and Treatment Area. This area is used for the storage and treatment of wastes in Tank No. 14 and Tank No. 11. Tank Storage/Treatment of organic concentrations in excess of 500 ppmw are prohibited at the Facility because the tanks are not equipped with the appropriate air emission controls devices. D003 waste code is prohibited from storage and treatment in Tanks. (4) Five (5) Days Staging Areas, "H," "M1," and "M2" (As preparation for container storage, on-site treatment, or offsite shipment). The activities in these areas are: (i) In area "H," the Permittee can sample and stage waste or other materials in containers prior to: (a) pumping such waste or other materials into the OnSite Wastewater Treatment System; (b) pumping such waste into Tanks 11 or 14; (c) treating such waste in the Mixt-Tub; (d) relocation to a designated Container Storage Area or off-site Shipment; and (e) over-pack containers of waste or other materials whose integrity has been compromised; NEICVP1493E01 Appendix A Page 4 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (ii) In Area "M1," the Permittee can sample and stage acidic waste or other material in containers prior to relocation to a designated Container Storage Area and over-pack containers of waste or other material whose integrity has been compromised; and (iii) In Area "M2," the Permittee can sample and stage alkaline waste or other material in containers prior to relocation to a Container Storage Area; over-pack containers of waste or other material whose integrity has been compromised; sort and stage PaintCare Program Waste; and sample unlabeled PaintCare Non-Program Waste. The maximum storage time to stage containers in these areas is five (5) consecutive days. (5) Mix-Tub, Bulk Storage and Transfer Area (MBSTA). (a) The Mix-Tub Area is used to: (i) solidify RCRA metal bearing wastes and non-RCRA hazardous semisolid waste in a mix tub by means of mixing such wastes with a solidification agent (i.e., paper pulp, saw dust, corncob grit) to render such waste more amenable to off-site treatment or disposal; and (ii) stabilize some RCRA metal bearing wastes in a mix tub by means of mixing such wastes with a stabilization reagent (i.e., cement kiln dust, lime, or fly ash). (b) The Bulk Storage in the MBSTA is to store waste or other material in roll-off containers for up to 30-Days. (c) The MBSTA is also utilized for Vacuum Trucks to transfer/pump waste or other material in liquid form to the On-Site Wastewater Treatment Plan, into a container and into Tank Systems 11 or 14. (6) Miscellaneous Processing Areas (MPA). These areas are located in the Operation Process Building. The MPA has one area to rinse 55-gallons drums, one area to crush 55-gallons drums; and one as a Lab-Pack Pour-off area activity for approved waste codes. (7) Truck-to-Truck Transfer area (TTTA), including Loading/Unloading Dock (containers). This area is used to transfer permitted wastes from one vehicle to another vehicle (specifically trailers) or to receive containerized wastes into the facility or load containerized wastes from the facility onto trailers. The area shall not have, at any time, trailers with containerized wastes to remain at the Trailer Staging Area for longer than three (3) consecutive days. Also, the Loading/Unloading Dock shall be free of any containerized waste at the end of business day. Containerized waste shall not be left on the Loading/Unloading Dock overnight. Such vehicles will comply with the Regulations of Connecticut State Agencies (RCSA) Section 22a-449(c)-11 and RCSA Section 22a-449(c)-103 NEICVP1493E01 Appendix A Page 5 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut with transportation of hazardous wastes. (8) 10-Days or Less Trailer Storage Areas (Parking Areas 1 and 3). These areas are utilized to store hazardous and non-RCRA hazardous wastes in trailers and rolloffs. These areas are not allowed to have, at any, one time, trailers with containerized wastes and roll-offs that contain RCRA and non-RCRA wastes to remain at the 10-Day or Less Storage Area for longer than 10 days. These areas have secondary containment to accumulate any releases, spills, and accumulated precipitation. (D) PERMITTED WASTES. The following wastes may be stored and managed at CHC facility. (1) The following hazardous wastes codes identified by the waste codes in 40 CFR Part 261, Subparts C and D. (a) D-Wastes. Characteristic waste that is ignitable, corrosive, or toxic. The waste codes are the following: D001, D002, D003*, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 *D003 - This type of waste is limited in scope in the Permit (in containersonly). (b) F-Wastes. Hazardous wastes from non-specific sources. The waste codes are the following: F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 (c) K-Wastes. Hazardous wastes from specific sectors of industry and manufacturing, therefore known as wastes from specific sources or manufacturing process wastes. The wastes codes are the following: K001- Wood preservation, bottom sediment sludge from the treatment of wastewaters from wood preserving processes that use creosote and/or pentachlorophenol. K161- (Purification solids (including filtration, evaporation, and centrifugation solids), bag house dust and floor sweepings from the production of dithiocarbonate acids and their salts are allowed to be transferred and staged at the Truck-to-Truck Transfer Staging Area). (d) P-Wastes. Discarded commercial chemical products. The wastes codes NEICVP1493E01 Appendix A Page 6 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut are the following: P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 Note: *P075 - for nicotine and salts in lab pack quantities. (d) U-Wastes. Toxic hazardous wastes, which are commercial chemical products, including discarded products, off-specification products, container residues and spill residues. The waste codes are the following: U004, U026, U048, U066, U086, U102, U126, U152, U173, U186, U205, U223, U248, U394, U005, U027, U049, U067, U087, U105, U129, U155, U174, U187, U206, U225, U271, U395, U006, U028, U050, U068, U088, U106, U137, U157, U175, U191, U207, U226, U278, U409, U010, U030, U051, U071, U089, U107, U141, U158, U176, U192, U210, U227, U279, U410, U011, U014, U015, U016, U018, U021, U024, UO34, U035, U036, U038, U039, U042, U047, U058, U059, U060, U061, U062, U063, U064, U073, U074, U079, U080, U081, U082, U085, U090, U091, U093, U094, U095, U097, U101, U109, U111, U114, U116, U119, U120, U122, U142, U143, U145, U148, U149, U150, U151, U163, U164, U166, U167, U168, U170, U172, U177, U178, U179, U180, U181, U183, U185, U193, U197, U200, U201, U202, U203, U204, U214, U215, U217, U218, U219, U221, U222, U235, U236, U237, U238, U243, U244, U247, U280, U364, U367, U372, U373, U387, U389, U411 (2) Non-RCRA hazardous wastes (i.e., Connecticut Regulated Wastes) as defined under the Connecticut General Statutes, Section 22a-448. These wastes are: (i) Waste PCBs, waste code CR01. Any waste material containing or contaminated by polychlorinated biphenyls (PCBs) in concentrations at or above fifty (50) parts per million (ppm). These include, but are not limited to, PCB oils, items, and equipment. These wastes are only managed in containers. (ii) Waste oil, waste code CR02. Any oil or petroleum that is no longer suitable for the services for which it was manufactured due to the presence of impurities or loss of original properties and is not miscible in water. These include but are not limited to, crude oil, fuel oil, lubricating oil, kerosene, diesel fuel, motor oil, non-halogenated oil, and oils that are recovered from oil separators, oil spills or tank bottoms. NEICVP1493E01 Appendix A Page 7 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iii) Wastewater Soluble Oil, waste code CR03. Any oil or petroleum that is no longer suitable for the services for which it was manufactured due to the presence of impurities or loss of original properties and is miscible in water. These include, but are not limited to, cutting oil emulsions or coolants. (iv) Waste Chemical Liquids, waste code CR04. Any wastes that are liquid free flowing and/or contains free draining liquid and are toxic, hazardous to handle and/or may cause contamination of ground and/or surface water if improperly managed. These wastes may include, but are not limited to, latex paint wastes, grinding wastes, sludges, antifreeze wastes and glycol solutions. (v) Waste Chemical Solids (CR05). Any chemicals solids or semi-solids from a commercial, industrial, agricultural, or community activity. These wastes include, but are not limited to grinding dusts, tumbling sludges, scrap plastic and rubber flash, and other ground or chipped waste solid. (3) The storage of Universal Wastes in accordance with the Connecticut's Hazardous Waste Management Regulations, Section 22a-449(c)-113. These wastes are batteries, mercury-containing equipment, lamps, used electronics and certain pesticides. (4) The storage and management of Used Oil in accordance with the Connecticut's Hazardous Waste Management Regulations, Section 22a-449(c)-119. (5) Lab Pack wastes. Include materials or products that are expired, spent, and/or unused as well as laboratory wastes. The lab pack wastes that can be accepted at the Facility shall be limited to the waste codes that are specified in this Permit and comply with the limits stipulated in 49 CFR 173.112(b). (6) Other Materials (e.g., commercial chemicals from technical, analytical reagentgrade chemicals, chemical intermediates, products, non-hazardous wastes and any chemical mixture thereof), except where otherwise prohibited by this Permit (e.g., shock sensitive materials), may be treated, stored, processed and managed in the Waste Management Areas. (7) Asbestos-containing materials and biomedical wastes in accordance with RCSA Sections 22a-209-8 and 22a-209-15. (8) The disassembly and storage of scrap metal and scrap metal appliances containing chlorofluorocarbon liquid in accordance with Section 22a-208a of the CGS and RCSA Section 22a-209-4. (E) SPECIFIC HAZARDOUS WASTE PROHIBITIONS. CHCI is prohibited from storing, treating, or managing the following wastes types in the Waste Management Areas. NEICVP1493E01 Appendix A Page 8 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) Explosive materials, as defined in 49 CFR 173 (DOT Class 1); (b) Compressed gases, as defined in 49 CFR 173.115, except for containers which contain aerosol cans of 32 ounces or less and non-flammable compressed gases; (c) Any forbidden hazardous material identified in 49 CFR 173.21 and 173.5; (d) Materials that are poison by inhalation, as defined in 49 CFR 173.115, 173.132 and/or 173.133; (e) Infectious materials, as defined in 49 CFR 173.134 (DOT Class 6, Division 6.2); except for those generated onsite through first aid and other medical needs; (f) Cryogenic Liquids, as defined in 49 CFR 173.115(g); (g) Listed and Characteristic wastes with a Health Hazard rating of 4, as defined in the most recent edition of the National Fire Protection Association ("NFPA") 704, "Standard System for the Identification of the Fire Hazards of Materials"; (h) Wastes that exhibit the characteristic of reactivity as defined by 40 CFR 261.23 (Hazardous wastes with EPA waste number of D003); except for certain inclusions as specified in the Permit. (i) Shock sensitive materials, defined as materials that are readily capable of detonation or explosive decomposition or reaction at normal temperatures and pressures, and materials sensitive to mechanical or localized thermal shock at normal temperatures and pressures, including materials designated in the most recent edition of NFPA 704 as having a Reactivity Hazard Rating of 4; (j) Spontaneously Combustible Materials, as defined in 49 CFR 173.124(b) (Class 4, Division 4.2); (k) Dangerous When Wet Materials, as defined in 49 CFR 173.24(c) (Class 4, Division 4.3); (l) Gaseous Oxidizers, as defined in NFPA 55 (formerly NFPA 43C); (m) Radioactive materials, as defined in 49 CR 173.403 (DOT Class 7), and (n) Material containing polychlorinated biphenyls (PCBs) are not allowed to be stored or treated in Tanks at the facility. The Specific Prohibitions included in this Permit do not apply to the products or materials used by the Permittee in its laboratory for maintenance at its property, provided such products or materials are present in quantities no greater than that necessary for use by the Permittee. (F) RATIONALE FOR THE PROHIBITION OF HAZARDOUS WASTES. In determining which prohibitions to apply, the Department utilized the demonstration provided in the permit application for the Facility to manage each of the DOT and NFPA hazard classifications for such hazardous waste storage and management unit(s). (G) PERMIT BASIS. The conditions of this renewal permit are based upon the Regulations of the Connecticut State Agencies adopted pursuant to Section 22a-449(c) of the Connecticut General Statutes, and upon the provisions of Section 22a-6 and 22a-454 of the Connecticut General Statutes, as applicable. The Connecticut Hazardous Wastes Management Regulations have incorporated by reference the Federal (RCRA) Hazardous Waste Regulations. These Federal Regulations include the technical and administrative standards for hazardous waste facilities as identified by 40 CFR Parts 124, 264, 268 and 270, as modified by RCSA Sections 22a-449(c)-104(a)(2) and 22a-449(c)-110(a)(2). NEICVP1493E01 Appendix A Page 9 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (H) PERMIT DURATION. This Permit will be in effect for five (5) years unless revoked and reissued or terminated under 40 CFR 270.41 and 270.43 or continued in accordance with 40 CFR 270.51(a). (I) AVAILABLE MATERIALS. Materials available for inspection with respect to this Permit include: (1) The RCRA Part B and Connecticut 22a-454 Renewal Permit Applications (201701891 (RCRA) and 201701899 (22a-454)); (2) The Commercial RCRA Part B Hazardous Waste and 22a-454 Wastes Renewal Permit; (3) The Notice of Tentative Determination for the Draft Facility Renewal Permit; (4) The Fact Sheet; and (5) The Administrative Record of the RCRA Part B Permit Application review, approval, and supporting documents. The above items listed as (1) through (5) are available for inspection at the Department of Energy and Environmental Protection (DEEP), Bureau of Materials Management and Compliance Assurance, Waste Engineering and Enforcement Division, 79 Elm Street, Hartford, Connecticut 06106-5127, by appointment. Interested persons who wish to make an appointment can email the File Room at DEEP.RecordsCenter@ct.gov. Questions regarding this Commercial RCRA Part B Hazardous Waste and 22a-454 Wastes Renewal Permit may be direct to Carmen Holzman of the Hazardous Waste Permit Program, Permit Writer, Waste Engineering and Enforcement Division, Bureau of Materials Management and Compliance Assurance, CT DEEP, telephone number (860) 424-3569 or email carmen.holzman@ct.gov. NEICVP1493E01 Appendix A Page 10 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CONNECTICUT HAZARDOUS WASTE PERMIT RENEWAL TO OPERATE A COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL IN ACCORDANCE WITH THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AND 22a-454 NON-RCRA REGULATED WASTES FOR CLEAN HARBORS OF CONNETICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CTD000604488 Permit Number: DEEP/HWM-017-004 Prepared by: Bureau of Materials Management and Compliance Assurance Waste Engineering and Enforcement Division Department of Energy and Environmental Protection 79 Elm Street, Hartford, Connecticut 06106 NEICVP1493E01 Appendix A Page 11 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CONNECTICUT HAZARDOUS WASTE PERMIT RENEWAL COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. TABLE OF CONTENTS SECTION TITLE PAGE___ Section I STANDARD FACILITY CONDITIONS Section II PERMITTED ACTIVITIES (A) Waste Management Areas . . . . . . . . II-4 (1) Container Storage Areas . . . . . . . II-4 (2) Bulk Unloading and Loading Area (BULA) . . . . II-10 (3) Areas to Stage Containers ("M1," "M2," and "H") for Up to 5 Calendar Days . . . . . II-13 (4) Tank Systems 11 and 14 . . . . . . . . II-18 (5) Mix-Tub, Bulk Storage and Transfer Area . . . . II-20 (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing and Lab Pack Pour-Off Station) . . . . II-30 (7) Truck-To-Truck Transfer Area (TTTA), including Loading/Unloading Dock (containers) . . . . . II-33 (8) Truck Parking Areas #1 and #3 for Up to 10-Days or Less II-38 (B) General Prohibitions . . . . . . . . . . II-43 (1) General Prohibitions . . . . . . . . . II-43 (2) Exception to General Prohibitions . . . . . . II-44 Section III OPERATING CONDITIONS (A) Conditions Regarding the Facility and All Waste Management Areas . . . . . . . . . . III-3 (B) Certain Conditions Applicable to Containers, including Roll-Off Containers and Transportation Vehicles . . . . III-21 (C) Requirements Regarding PaintCare Program Waste . . . III-23 (D) Specific Waste Management Area Operating Conditions . . III-26 (1) Container Storage Areas and Areas to Stage Containers . III-26 (2) Bulk Unloading and Loading Area (BULA) . . . III-30 (3) Tank Systems 11 and 14 . . . . . . . . III-31 (4) Mix-Tub, Bulk Storage and Transfer Area (MBSTA) . . III-35 (5) Miscellaneous Processing Areas . . . . . . III-41 (6) Truck-to-Truck Transfer Area . . . . . . . III-43 (7) Truck Parking Areas 1 and 3 . . . . . . . III-45 NEICVP1493E01 Appendix A Page 12 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Section IV GENERAL CONDITIONS (A) Imminent Hazard Actions . . . . . . . . . IV-3 (B) Required Transfer Notice . . . . . . . . . IV-3 (C) Waste Analysis . . . . . . . . . . . IV-3 (D) Security . . . . . . . . . . . . . IV-4 (E) General Inspection Requirements . . . . . . . IV-5 (F) Personnel Training . . . . . . . . . . IV-5 (G) General Requirements for Ignitable, Reactive or Incompatible Wastes and/or Other Co-stored Materials . . IV-7 (H) Preparedness and Prevention . . . . . . . . IV-8 (I) Contingency Plan. . . . . . . . . . . IV-11 (J) Manifest System . . . . . . . . . . . IV-16 (K) Operating Record. . . . . . . . . . . IV-17 (L) Availability, Retention and Disposition of Records . . . IV-18 (M) Biennial Report . . . . . . . . . . . IV-18 (N) Closure . . . . . . . . . . . . . IV-18 (O) RCRA Corrective Action Requirements . . . . . . IV-23 (P) Financial Requirements . . . . . . . . . IV-33 (Q) Air Emission Requirements, Subpart CC . . . . . IV-35 (R) Universal Wastes . . . . . . . . . . . IV-40 (S) Used Oil . . . . . . . . . . . . IV-40 (T) Applicable Laws . . . . . . . . . . . IV-40 (U) Location Standards . . . . . . . . . . IV-40 Section V COMPLIANCE SCHEDULE NEICVP1493E01 Appendix A Page 13 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLES TITLE PAGE___ Section II Table II-1 Table II-2 Waste Management Areas Selected Information . . II-45 Laboratory and Maintenance Products/Materials . II-48 APPENDICES TITLE APPENDIX II-1 APPENDIX III-A APPENDIX III-B APPENDIX III-C EPA PCB Commercial Storage Exemption Letter - Dated December 11, 2018 Certain Items among Others to be Included in The Third-Party Audits . . . . . . . III-47 Decontamination Procedures . . . . . . III-49 Example of a Tank Cleaning Certificate . . . . III-51 DRAWINGS TITLE Drawing No. 62WC-7100-201 Drawing No. 62WC-7100-202 Drawing No. 62WC-7100-203 Drawing No. 62WC-7100-204 Drawing No. 62WC-7100-205 Drawing No. 62WC-7100-206 Drawing No. 62WC-7100-207 Drawing No. 62WC-7100-208 Drawing No. 62WC-7100-211 Drawing No. 62WC-7100-212 Drawing No. 62WC-7100-214 Drawing No. 62WC-7100-215 Permitted Storage Area C (In the BULA Area) Operations Building-Permitted Staging Area H Operations Building-Permitted Storage Area L Waste Management Areas-Site Plan (WMASP) Container Storage Building- Permitted Storage Areas - A, B, D, E, F, G and J Operations Building-Permitted Storage Area K Operations Building-Permitted Staging Area M1 Operations Building-Permitted Staging Area M2 Truck Parking Areas 1 and 3 - 10-Days or Less Truck-To-Truck Transfer Area (Loading/Unloading Operations Building-Permitted Storage Tank 11 Operations Building-Permitted Storage Tank 14 Dock) ATTACHMENTS A. B. C. D. E. TITLE Waste Analysis Plan Inspection Plan Personnel Training Plan Contingency Plan Closure Plan NEICVP1493E01 Appendix A Page 14 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION I STANDARD FACILITY CONDITIONS COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 15 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION (A) (B) (C) (D) (E) (F) SECTION I TABLE OF CONTENTS STANDARD FACILITY CONDITIONS TITLE PAGE Design and Operation . . . . . I-3 Effect of Permit . . . . . . I-3 Severability . . . . . . . I-3 Confidential Information . . . . . I-3 Duties and Requirements . . . . . I-4 (1) Duty to comply . . . . . I-4 (2) Duty to reapply . . . . . I-4 (3) Need to halt or reduce activity not a defense . . I-4 (4) Duty to mitigate . . . . . I-4 (5) Proper operation and maintenance . . . I-4 (6) Permit actions . . . . . . I-4 (7) Property rights. . . . . . I-5 (8) Duty to provide information . . . . I-5 (9) Inspection and entry . . . . . I-5 (10) Monitoring and records . . . . I-5 (11) Signatory requirements . . . . I-6 (12) Transfers . . . . . . I-6 (13) Reporting requirements . . . . I-6 (14) Computation of time . . . . . I-8 (15) Waste minimization . . . . . I-9 (16) Additional requirements . . . . I-9 (17) Federal and State Laws . . . . I-9 (18) Modification of the Compliance Schedule . . I-9 (19) Delegation of a Licensed Environmental Professional . . . . . . I-9 (20) Incorporation by Reference . . . . I-10 Definitions . . . . . . . I-10 NEICVP1493E01 Appendix A Page 16 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION I STANDARD FACILITY CONDITIONS (A) DESIGN AND OPERATION. The Permittee shall operate, maintain and repair the Facility to minimize the possibility of a fire, explosion, or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water, which could threaten human health or the environment. (B) EFFECT OF PERMIT (1) Except as is provided in the Regulations of Connecticut State Agencies (RCSA) Section 22a-449(c)-110(a)(2) and except for any federally enforceable requirement(s), compliance with this Permit during its term constitutes compliance, for purposes of enforcement, with Section 22a-449(c) of the Connecticut General Statutes (CGS). This Permit may be modified, revoked and reissued, or terminated by the Commissioner of the Department of Energy and Environmental Protection ("the Commissioner") during its term as set forth in RCSA Section 22a-449(c)-110(a) (1), which incorporates by reference Title 40 of the Code of Federal Regulations (40 CFR) Sections 124, 270.41, 270.42 and 270.43, as modified by RCSA Section 22a-449(c)-110(a) (2). (2) The issuance of this Permit does not authorize any injury to persons or property, invasion of other private rights, or any infringement of state or local law or regulations. (3) The Permittee shall construct, operate, maintain and repair the Facility in conformance with and as required by RCSA Section 22a-449(c)-100-119 inclusive and in compliance with the terms and conditions of Sections I to Section V of this Permit, regardless of any application or submittals made by the Permittee regarding: (a) the Facility, (b) this Permit or (c) the renewal of this Permit. (a) In the event of a conflict between any provision of RCSA Section 22a449(c)-100-119, inclusive and the terms and conditions of Sections I to Section V of this Permit, the more stringent provision shall prevail. (b) In the event of a conflict between any provision of RCSA Section 22a449(c)-100-119, inclusive or the terms or the conditions specified in Sections I to Section V of this Permit, the more stringent provision shall prevail over any schedule or plan incorporated herein or made part of this Permit. Any such regulation of term or condition shall be enforceable, notwithstanding the provisions of schedule or plan made a part of this Permit. (C) SEVERABILITY. The provisions of this Permit are severable, as specified in 40 CFR 124.16, and if any provisions of this Permit, or the application of any provisions of this Permit to any circumstances is held invalid, the application of such provision to other circumstances and the remainder of this Permit shall not be affected thereby. (D) CONFIDENTIAL INFORMATION. The Permittee may claim that any information required to be submitted by this Permit contains or constitutes a trade secret in accordance with Section 1-210(b) (5) of the CGS. NEICVP1493E01 Appendix A Page 17 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (E) DUTIES AND REQUIREMENTS (1) Duty to comply. The Permittee shall comply with all conditions of this Permit, except that the Permittee need not comply with the conditions of this Permit to the extent and for the duration, such noncompliance is authorized in an Emergency Permit that explicitly authorizes any such noncompliance. Noncompliance by the Permittee with the terms of this Permit, except under the terms of an Emergency Permit, shall constitute a violation of this Permit and any applicable laws or regulations and is grounds for enforcement action, for permit termination, revocation and reissuance or denial of a permit renewal. Emergency Permit as used herein shall mean Emergency Permit as identified in 40 CFR 270.61. Unless superseded by a more stringent provision in this Permit, in which case the more stringent provision of this permit shall apply, as a condition of this Permit, the Permittee shall comply with all applicable requirements of the state's hazardous waste regulations, RCSA Sections 22a-449(c)-100 et.seq., including any applicable portion of 40 CFR 260 through 279 incorporated by reference therein. (2) Duty to reapply. If the Permittee wishes to continue engaging in an activity regulated by this Permit after the expiration date of this Permit, the Permittee shall apply for a renewal permit at least one hundred eighty (180) calendar days before this permit expires, in accordance with RCSA Section 22a-3a-5 and any other applicable law. (3) Need to halt or reduce activity not a defense. It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce any activity authorized by this Permit in order to maintain compliance with the conditions of this Permit. (4) Duty to mitigate. In the event of noncompliance with this Permit, the Permittee shall take all reasonable steps to minimize releases to the environment and shall carry out such measures as are reasonable to prevent its noncompliance from having significant adverse impacts on human health or the environment. No action taken by the Permittee pursuant to this section of this permit shall affect or limit the Commissioner's authority under any other statute or regulation. (5) Proper operation and maintenance. The Permittee shall at all times properly operate and maintain the Facility and all systems of storage and control (and related appurtenances) installed or used by the Permittee to achieve compliance with this Permit. Proper operation and maintenance, at a minimum, includes effective performance, adequate funding, adequate operator staffing and training, and adequate analytical data, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this Permit. (6) Permit actions. This permit may be modified, revoked and reissued, or terminated as provided for in 40 CFR, Subpart D, Parts 270.40 through 270.43, as modified by Section 22a-449(c)-110(a)(2) of the RCSA, and in accordance with all applicable law, including but not limited to, Sections 22a-6g and 6h of the NEICVP1493E01 Appendix A Page 18 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CGS and the Section 22a-3a-5 of the RCSA. The filing of a request by the Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance, does not stay any condition of this Permit. (7) Property rights. This Permit does not convey any property rights of any sort, or any exclusive privilege to the Permittee. (8) Duty to provide information. The Permittee shall furnish to the Commissioner, within a reasonable time, any information that the Commissioner may request to determine whether cause exists for modifying, revoking, and reissuing, or terminating this Permit or to determine compliance with this Permit. The Permittee shall also furnish to the Commissioner, upon request, copies of records required to be kept by this Permit. (9) Inspection and entry. The Permittee shall allow the Commissioner, or an authorized representative, upon the presentation of credentials and other documents as may be required by law to: (a) Enter at reasonable times upon the Permittee's premises where a regulated Facility or activity is located or conducted, or where records shall be kept under the conditions of this Permit; (b) Have access to and copy at reasonable times, any records that shall be kept under the conditions of this Permit; (c) Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices or operations regulated or required under this Permit; and (d) Sample or monitor at reasonable times, for the purposes of assuring Permittee's compliance with this Permit or as otherwise authorized by RCRA, any applicable statute, any substances, or parameters at any location. (10) Monitoring and records (a) Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. (b) The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this Permit, the certification required by 40 CFR 264.73(b)(9), and records of all data used to complete the application for this Permit and comply with the requirements of this Permit, for a period of at least three (3) years from the date of the sample, measurement, certification, report or application. This period may be extended by request of the Commissioner at any time. The Permittee shall maintain records from all groundwater-monitoring wells and associated groundwater surface elevations, for the active life of the facility. NEICVP1493E01 Appendix A Page 19 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (c) Records for monitoring information shall include: (i) The date, exact place and time of sampling or measurements; (ii) The individual(s) who performed the sampling or measurements; (iii) The date(s) analyses were performed; (iv) The individual(s) who performed the analyses; (v) The analytical techniques or methods used; and (vi) The results of such analyses. (d) Each record or report required by this Permit, including, but not limited to, records in the Operating Record for the Facility and reports submitted to the Commissioner, shall be true, accurate and complete to the best of the knowledge and belief of the person responsible for generating or signing such record or report, based on personal examination and familiarity with the information contained in the record or report, including all attachments thereto, and reasonable investigation, including, as necessary, inquiry of those individuals responsible for obtaining the information contained in such record or report. (11) Signatory requirements. The Permittee's application and all reports or information submitted to the Commissioner by the Permittee pursuant to this Permit shall be signed by the person specified in and contain the certification prescribed by Section 22a-449(c)-110(a)(1) of the RCSA incorporating 40 CFR 270.11. (12) Transfers. This Permit is not transferable to any person without the advanced written authorization of the Commissioner, who may request whatever information the Commissioner deems necessary regarding the potential transferee. Before any such transfer, the Permittee and any proposed transferee shall fully comply with the requirements of Sections 22a-6o of the CGS and any applicable requirement of 40 CFR 260 et seq., relating to the transfer of the Facility or this Permit, including, but not limited to, 40 CFR 270.40. The Commissioner may require modification or revocation and reissuance of this Permit to change the name of the Permittee and as an incident to any such transfer incorporate such other requirements, as the Commissioner deems necessary. (13) Reporting requirements. (a) Anticipated non-compliance. The Permittee shall give as much advance written notice as possible to the Commissioner of any planned changes in the Facility or activity that may result in noncompliance with any requirement of this Permit. (b) Compliance. Except where otherwise provided for in this Permit, reports of compliance and non-compliance with, or any progress reports on, interim and final requirements contained in any compliance schedule (Section V) of this Permit shall be submitted no later than fourteen (l4) calendar days following each schedule date. (c) Twenty-four (24) hour reporting: NEICVP1493E01 Appendix A Page 20 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (i) The Permittee or his designee shall orally report to the Commissioner any waste related activity at its Facility, irrespective of whether such activity is in compliance with the requirements of this Permit, which does or may pose an imminent and substantial endangerment to human health or the environment, immediately but not later than twenty-four (24) hours from the time the Permittee becomes aware or should be aware of the circumstances causing such endangerment. The report to the Commissioner shall include: (A) Name, address, and telephone number of the Permittee; (B) Name, address, and telephone number of the Facility; (C) Date, time, and type of incident; (D) Description of the occurrence and its cause; (E) Name and quantity of waste(s) or constituents thereof involved; (F) The extent of injuries, if any; (G) An assessment of actual or potential hazards to human health and the environment; (H) Estimated quantity and disposition of recovered waste that resulted from the incident; (I) All information concerning the release of any waste or constituents thereof that may cause an endangerment to public drinking water supplies; and/or (J) All information concerning a release or discharge of waste or constituents thereof or of a fire or explosion from the Facility, which could threaten human health or the environment. (ii) A written submission shall also be provided within five (5) calendar days of the time the Permittee becomes aware of the circumstances described in subdivision (i) above. The written submission shall contain a description of the endangerment and its cause; the period of endangerment including exact dates and times, if the endangerment has been abated, and if not, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the endangerment. The Permittee shall maintain in the operating record of its Facility a copy of all such written reports. The Commissioner may waive the five (5) calendar day written notice requirement in favor of a written report within fifteen (15) calendar days of any incident requiring reporting. (iii) Nothing in this section shall affect or relieve the Permittee of its obligations under Section 22a-450 of the CGS. (d) Manifest discrepancy report. The Permittee shall report manifest discrepancies in accordance with 40 CFR 264.72, which is hereby incorporated by reference herein. The information shall be provided in a format acceptable to the Commissioner. (e) Unmanifested waste report. The Permittee shall report unmanifested NEICVP1493E01 Appendix A Page 21 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut waste in accordance with 40 CFR 264.76, which is hereby incorporated by reference herein. (f) Biennial report. The Permittee shall fully and accurately complete and submit to the Commissioner by March 1st of each even numbered year a biennial report regarding waste activities at the Facility for the previous calendar year, on a form or electronic method prescribed by the Commissioner. In addition, the Permittee shall provide any other information, which the Commissioner specifies relating to the activities at the Permittee's Facility. (g) Other Noncompliance. The Permittee shall report all instances of noncompliance with this Permit not otherwise required to be reported by this Permit to the Commissioner along with any other required monitoring report, but no later than thirty (30) calendar days of the date the Permittee is aware, or reasonably should have been aware of any such noncompliance. Any such report shall contain the information listed in Section I (E) (13) (c) (ii) of this Permit as well as all steps taken to correct any such noncompliance. (h) Other information. When the Permittee becomes aware that it failed to submit any relevant facts or incorrect information in a permit application, or submitted incorrect information in a permit application, report or other document provided to the Commissioner regarding this Permit, the Permittee shall promptly submit such relevant facts or correct information to the Commissioner. (i) Requirements Incorporated. Different sections of this Permit contain requirements for the Facility. Compliance with all of the provisions in each Section of this Permit is required, even if one section or provision of this Permit does not specifically refer to or incorporate requirements from another section or provision of this Permit. (14) Computation of time (a) Computation of time. Except as is expressly provided for in this Permit, the computation of time periods set forth in this Permit shall be as follows: (i) Any time-period scheduled to begin on the occurrence of an act or event shall begin on the day after the act or event. (ii) Any time-period scheduled to begin before the occurrence of an act or event shall be computed so that the period ends on the day before the act or event. (iii) If the final day of any time period falls on a federally or state recognized legal holiday, the time period shall be extended to the next working day. If the final day ends on a Saturday or Sunday, the time period shall not be extended to the next working day. (b) Submission of reports. Where this Permit requires the submission of a written report, a notification or other information or documentation to the NEICVP1493E01 Appendix A Page 22 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Commissioner, such report, notification or other information or documentation shall be deemed submitted, including, but not limited to, submissions made by electronic mail, on the date such report, notification or other information is received by the Department of Energy and Environmental Protection ("the Department"). (15) Waste minimization. The Permittee shall have a program in place to reduce the volume and toxicity of hazardous waste that the Facility generates to the degree determined by the Permittee to be economically practicable; and the method of treatment, storage or disposal currently available to the Permittee that minimizes the present and future threat to human health and the environment. (16) Additional requirements. Requirements not included in this Permit, which become effective by statute or regulation, and not made specifically inapplicable to facilities with a Permit, shall apply to the Permittee's Facility. In the event of any conflict between this Permit and any such requirement, the Permittee shall comply with the more stringent requirement, provided that if the Permittee does not fully comply with the more stringent requirement, the Department may enforce either requirement. (17) Federal and state laws. Nothing in this Permit shall be construed to prohibit any federal, state, or political subdivision thereof from imposing any requirements to the extent authorized by law, which are more stringent than those imposed by this Permit. In addition, nothing in this Permit shall relieve the Permittee of its obligation to comply with any other applicable federal, state, or local statute, regulation, or ordinance. (18) Modification of the Compliance Schedule Submittals (a) The Permittee may request to modify the submittal due dates of the Compliance Schedule (Section V) of this Permit at any time. Such requests shall be submitted for the Commissioner's review and written approval and shall include sufficient justification for such request(s). (b) The Commissioner may grant extensions of submittal due dates based on the Permittee's demonstration that sufficient justification for the extension exists. Extensions to due dates, which this Permit explicitly defines as being due by a certain time or during a certain time interval, may be granted by the Commissioner if the Permittee demonstrates sufficient justification for the extension. (19) Delegation of a Licensed Environmental Professional (a) Pursuant to RCSA Section 22a-133v, a licensed environmental professional ("LEP") may verify that site-wide environmental investigation at the Facility has been performed in accordance with prevailing standards and guidelines and remediation activities have addressed any and all requirements of the Commissioner and have achieved compliance with the RSRs. (b) The LEP shall submit the Final Report for site-wide corrective action for the Commissioner's review and written approval in conjunction with the NEICVP1493E01 Appendix A Page 23 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut submission of the verification. (c) In the event the Commissioner revokes the delegation of site-wide investigation and oversight of site-wide corrective action, the Permittee shall ensure all reports and documents required by this Permit are submitted for the Commissioner's review and written approval within the timeframes specified. (d) The Permittee shall notify the Commissioner in writing of the identity of any LEP other than the one previously approved by the Commissioner, within ten (10) calendar days after assigning or retaining any LEP for the purpose of addressing the actions required by this Permit. The Permittee shall submit to the Commissioner a description of the assigned LEP's education, experience and training which is relevant to the work required by this Permit within ten (10) calendar days after a request for such a description has been made. Nothing in this paragraph shall preclude the Commissioner from finding a previously acceptable LEP unacceptable. (20) Incorporation by Reference (a) Unless specifically excluded by the state hazardous waste management regulations, when a provision of the Code of Federal Regulations (CFR) is used in this Permit, such reference shall mean the corresponding provision of the state hazardous waste management regulations, incorporated by reference at 22a-449(c)-100 to 119, inclusive, including all modifications made to any such provision by the state hazardous waste management regulations. Unless specifically excluded by the state hazardous waste management regulations, if there are no corresponding provisions of the state hazardous waste management regulations, the provisions of the federal CRF cited shall apply. (b) When a provision of the CFR is used in this Permit, such reference as all notes, comments, appendices, diagrams, tables, and figures referred to or cited in such provision shall also be included in such reference. (c) When a provision of the CFR is used in this Permit, unless otherwise noted, all internal references contained therein shall also be included by such reference. In addition, each such internal reference to the CFR is intended to include any modifications to such internal reference made by the state hazardous waste management regulations. (d) In the event of any inconsistency or duplication in the requirements of the provisions incorporated by reference from 40 CFR 260 et seq., the state hazardous waste management regulations, and the provisions of this Permit, the provision that is more inclusive or more stringent shall prevail and shall be enforceable. (F) DEFINITIONS. The following terms shall be defined as follows for the purposes of this Permit. Any term not otherwise defined herein shall be defined as that term is defined in RCSA Sections 22a-449(c)-100(b) and (c). (1) "Alkaline Waste or Other Material" shall mean a waste or other material with a pH NEICVP1493E01 Appendix A Page 24 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut of 7 or greater. (2) "Acidic Waste or Other Material" shall mean a waste or other material with a pH less than 7. (3) "Acute Hazardous Wastes" shall mean the hazardous wastes with the Hazard Code H in 40 CFR 261.31(a) and the hazardous waste identified as acute hazardous waste in 40 CFR 261.33(e). (4) "Area of Concern" or "AOC" shall mean any area at the Facility where hazardous waste or hazardous constituents have or may have been released. (5) "Alkyd Paint" shall mean paint with synthetic resin modified with oil, commonly referred to as "oil-based paint." These paints often exhibit the hazardous waste characteristic of ignitability. (6) "Architectural Paint" means interior and exterior architectural coatings sold in containers of five gallons or less. Architectural paint does not include industrial, original equipment or specialty coatings. (7) "Area for Tank Systems 11 and 14" shall mean the area identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (4) of this Permit may be conducted. (8) "Area to Stage Containers" shall mean the area identified on Drawing No. 62WC7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (3) of this Permit may be conducted. (9) "Asbestos-containing material" shall mean actinolie, amosite, antnophyllite, chrysotile, crocidolite, tremolite, or any material, which contains the above, all or part of which is in a friable state. (10) "Biomedical Waste" shall mean untreated solid waste, generated during the administration of medical care or the performance of medical research involving humans or animals, including infectious waste, pathological waste, chemotherapy waste and any disposable container holding such waste and any reusable container holding such waste which has not been decontaminated, but shall not include: (a) any solid waste which is hazardous waste or a radioactive material regulated pursuant to Section 22a-148 of the CGS; (b) untreated solid waste generated during the administration of medical care in a single or multiple family residence by a resident thereof; (c) discarded materials used for personal hygiene, such as diapers, facial tissues, and sanitary napkins, unless such materials are isolation waste; (d) syringes, hypodermic needles and other medical equipment used by farmers for the treatment of their livestock in the course of conducting farming, provided such equipment is not excluded when used by a veterinarian or at the direction of a veterinarian; and (e) samples of biomedical waste collected and transported by Department personnel for enforcement purposes. (11) "Bulking" shall mean the act of adding, consolidating, or combining like wastes. (12) "Bulk Unloading and Loading Area" or "BULA" shall mean the area identified on NEICVP1493E01 Appendix A Page 25 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (2) of this Permit may be conducted. (13) "Code of Federal Regulations" or "CFR", in reference to all or any portion of 40 CFR 124 and 260 to 279, inclusive, shall mean the Code of Federal Regulations revised as of July 1, 2000. All other references to the Code of Federal Regulations (i.e., references to provisions other than 40 CFR 124 and 40 CFR 260 to 279, inclusive) shall mean the Code of Federal Regulations, in effect on the date that this Permit is issued by the Commissioner. (14) "CHC" or "CHCI" shall mean Clean Harbors of Connecticut, Inc., or the Permittee. (15) "Commissioner" shall mean the Commissioner of Energy and Environmental Protection of the state of Connecticut, or the Commissioner's duly authorized designee. (16) "Container" shall mean any portable device, not including a roll-off container, a separate type of container defined below, in which a waste or other material is stored, transported, treated, or otherwise managed. (17) "Container Storage Areas" or "CSA" shall mean the areas identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (1) of this Permit may be conducted. (18) "Containment Pallet" shall mean a pallet on which containers are placed equipped with a self-contained secondary containment system sufficient to contain 10 percent of the volume of all containers or 100 percent of the volume of the largest container, whichever is greater, on the pallet. (19) "CR01" shall mean any waste material containing or contaminated by PCBs (Polychlorinated Biphenyls) in concentrations at or above 50 ppm (parts per million). These include, but are not limited to, PCB oils, items, and equipment. (20) "CR02" shall mean oil or petroleum waste that is not a hazardous waste and is no longer suitable for the services for which it was manufactured due to the presence of impurities or loss or original properties and is not miscible in water. The term includes, but is not limited to, crude oil, fuel oil, lubricating oil, kerosene, diesel fuel, motor oil, non-halogenated oil, and oils that are recovered from oil separators, oil spills, or tank bottoms; (21) "CR03" shall mean oil or petroleum waste that is not a hazardous waste and is no longer suitable for the services for which it was manufactured due to the presence of impurities or loss of original properties and is miscible in water. The term includes, but is not limited to, cutting oil emulsions and coolants; (22) "CR04" shall mean any wastes that are not a hazardous waste and are liquid, free flowing or contain free draining liquids and are toxic, hazardous to handle and/or may cause contamination of ground and/or surface water if improperly managed. The term includes, but is not limited to, grinding wastes, waste sludge, antifreeze wastes and glycol solutions, but does not include PaintCare Program Wastes; NEICVP1493E01 Appendix A Page 26 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (23) "CR05" shall mean any chemical solid or semi-solid waste, excluding a hazardous waste, from a commercial, industrial, agricultural, or community activity. The term includes, but is not limited to, grinding dusts, tumbling sludges, scrap plastic and rubber flash and other ground or chipped waste solid; (24) "Daily" or "Day" shall mean a twenty-four (24) consecutive hour period beginning at midnight. (25) "Department" or "DEEP" shall mean the Connecticut Department of Energy and Environmental Protection. (26) "Department of Transportation" or "DOT" shall mean the U.S. Department of Transportation. (27) "Empty" shall mean empty as prescribed in 40 CFR 261.7(b) and shall apply to containers of non-hazardous waste or other materials. (28) "Facility" shall mean the contiguous land and structures, other appurtenances, and improvements on land within the boundaries/perimeter of the property shown on Diagram No. 62WC-7100-204, titled Waste Management Areas, Site Plan. Facility includes, but is not limited to, the following waste management areas: (1) Container Storage Areas; (2) Bulk Unloading and Loading Area (BULA); (3) Areas to Stage Containers (M1, M2, and H); (4) Tank Systems 11 and 14; (5) Mix-Tub, Bulk Storage and Transfer Area (MBSTA); (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing Stations, Lab Pack Pour-Off Area); (7) Truck-to-Truck Transfer Area (TTTA), including the Loading/Unloading Dock (containers); and (8) Truck Parking Areas #1 and #3 for Up to 10-Days or Less. In addition, for purposes of implementing corrective action, Facility includes all contiguous property under the control of the Permittee. (29) "Final Closure" shall mean the completion of the closure of all waste management areas at the Permittee's Facility in accordance with the requirements of this Permit. (30) "Hazardous Waste" or "Hazardous Wastes" shall mean any waste material which may pose a present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed, including, but not limited to, hazardous wastes specified in 40 CFR Part 261 and RCSA Section 22a-449(c)-101. The term "hazardous waste" shall include: a) hazardous wastes that are included in the federal hazardous waste program, even if such wastes have not been added to the State's hazardous waste program; and b) all hazardous waste included in the state's hazardous waste program, even if such waste is not included in the federal hazardous waste program. (31) "Inner Container(s)" shall mean individual containers, five gallons or less, of PaintCare Program Wastes that are placed within an outer container. (32) "Lab Pack Container" or "Lab Pack" shall mean a container that meets the requirements of 49 CFR 173.12, including inner, outer packaging and other requirements. NEICVP1493E01 Appendix A Page 27 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (33) "Latex Waste Paint" shall mean PaintCare Program Wastes that are water-based emulsion paints made with synthetic binders such as 100% acrylic, vinyl acrylic, terpolymer or styrene acrylic, constituting a stable emulsion of polymers and pigment in water. (34) "Liquid" or "In Liquid Form" shall mean visibly free flowing, a nearly incompressible fluid that conforms to the shape of its container but retains a (nearly) constant volume independent of pressure. As one of the fundamental states of matter (the others being solid, gas, and plasma), it is the only state with a definite volume but no fixed shape. (35) "Loading Dock Area" or "Loading Dock" shall mean that portion of the Truck-toTruck Transfer Area identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan. (36) "Mix-Tub, Bulk Storage and Transfer Area" or "MBSTA" shall mean the area identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (5) of this Permit may be conducted. (37) "Mix-Tub" shall mean the miscellaneous unit authorized to conduct activities, not including storage, specified in Section II (A) (5) of this Permit. The Mix-Tub is not a container. (38) "Miscellaneous Processing Areas" shall mean the area identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (6) of this Permit may be conducted. (39) "NIOSH" shall mean the federal National Institute of Occupational Safety and Health. (40) "NFPA 704" shall mean the latest edition of the National Fire Protection Association 704: Standard System for the Identification of the Hazards of Materials for Emergency Response. (41) "Non-Hazardous Waste" shall mean any waste material, which may pose a present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of or otherwise managed, excluding hazardous waste. (42) "Non-Latex Waste Paint" shall mean all PaintCare Program Waste Paints that are not Latex Waste Paint. (43) "Non-Paint Wastes" shall mean PaintCare Program Wastes received at the Facility that do not qualify as or are not PaintCare Waste Paints. The following list, which is not and is not intended to be exhaustive, contains examples of wastes that are not PaintCare Waste Paints: Paint thinners, mineral spirits, and solvents Aerosol paints (spray cans) NEICVP1493E01 Appendix A Page 28 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Auto and marine paints Art and craft paints Caulking compounds, epoxies, glues, adhesives Paint additives, colorants, tints, resins Wood preservatives (containing pesticides) Roof patch and repair Asphalt, tar, and bitumen--based products Two-part coatings Deck cleaners Traffic and road marking paints Industrial Maintenance coatings Original Equipment Manufacturer (shop application) paints and finishes (44) "OSHA'' shall mean the federal Occupational Safety and Health Administration. (45) "Other Material" or "Other Materials" shall mean (a) The following commercial chemicals provided the Permittee at its Facility use such commercial chemicals: (i) New, unused, or virgin commercial chemicals, including chemical intermediates and mixtures; (ii) Off-specification commercial chemical product; and (iii) Commercial chemicals reused without processing of any kind. (46) "On-Site Wastewater Treatment Plant" shall mean the wastewater treatment plant on the same property as the Facility and whose operation is authorized by a permit issued by the Commissioner; (47) "Operations Building" shall mean the area identified on Drawing No. 62WC-7100204, titled Waste Management Areas, Site Plan. (48) "Outer Container" shall mean the flex bin, cubic yard box or other container into which are placed inner containers, five gallons or less, of PaintCare Program Wastes. (49) "PaintCare" shall mean the nonprofit organization created by producers to implement the paint stewardship program described in section 22a-904a of the CGS. (50) "PaintCare Program Wastes" shall mean wastes in containers five gallons or less received at the Facility through the PaintCare Program implemented by PaintCare. PaintCare Program Waste includes PaintCare Waste Paints and Non-Waste Paints. (51) "PaintCare Waste Paint" shall mean Latex Waste Paint and Non-Latex Waste Paint provided such wastes are in their original containers, the original label is still on the container and is legible and the container is not leaking: (a) Interior and exterior architectural paints: latex, acrylic, water based, alkyd, oil based, enamel (including textured coatings) NEICVP1493E01 Appendix A Page 29 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) Deck coatings, floor paints (including elastomeric) (c) Primers, sealers, and under coaters (d) Stains (e) Shellacs, lacquers, varnishes, urethanes (single component, No Part A and B) (f) Waterproofing concrete/masonry/wood sealers and repellents (not tar or bitumen-based) (g) Metal coatings, rust preventatives; and (h) Field and lawn paints (52) "PCB or PCBs" shall mean any chemical substance that is limited to the biphenyl molecule that has been chlorinated to varying degrees or any combination of substances, which contains such substances. (53) "PCB Item" shall mean any PCB Article, PCB Article Container, PCB Container, PCB Equipment, as those terms are defined in 40 CFR 761.3, or anything that deliberately or unintentionally contains or has as a part of it any PCB or PCBs. (54) "Permittee" shall mean Clean Harbors of Connecticut, Inc. (CHCI). (55) "PID" shall mean a Photo-Ionization Detector or Photo-Ionization sensor with a 10.6 eV UV lamp, with a measuring accuracy, calibrated or Isobutylene, from 02000 parts per million of +/- 2 parts per million or no greater than 10 per cent of a reading or another sensor approved in writing by the Commissioner. (56) "Release" or "Spill" shall mean spilling, leaking, pouring, emitting, emptying, discharging, pumping, escaping, leaching, dumping, discharging or disposing of wastes or other materials, or constituents thereof, from any tank and associated equipment, container, Mix-Tub, transportation vehicle, and any other article or device used to contain, convey, or transport waste or other materials into or onto anything or anywhere, including, but not limited to an area used for secondary containment, except as an authorized activity under Section II of this Permit (57) "Remediation Standard Regulations" or "RSRs" shall mean Regulations of Connecticut State Agencies, Sections 22a-133k-1 through 22a-133k-3. (58) "Roll-off Container" shall mean a container that meets the criteria specified by the U.S. Department of Transportation that is a minimum of ten (10) cubic yards to a maximum of seventy (70) cubic yards in size and into which is placed waste or other material that is solid or semi-solid, but not liquid. Roll-off containers are designed to be transported on vehicles specifically designed to load and off-load the container. (59) "Scrap Metal" shall mean crushed metal drums, scrap metal appliances from which any refrigerant or chlorofluorocarbons have been removed and any other waste or other material that the Commissioner has approved, in writing, for NEICVP1493E01 Appendix A Page 30 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut management at the Facility as a scrap metal. (60) "Seventy-Two (72) Hour Truck-to-Truck Transfer" shall mean the transfer of containers of waste or other materials at the Facility from one vehicle to another vehicle while in Transit to another Facility, as authorized by Section II (A) (7) of this Permit, that occurs not later than Seventy-Two (72) consecutive hours after an individual container of waste or other material arrives at the Facility and until it is no longer present at the Facility. A container of waste or other material shall be determined to have arrived at the Facility when it enters the property constituting the Facility and/or any adjacent or abutting property such as 761 Middle Street Property used by the Permittee, for the first time. Notwithstanding, any other provisions of this Permit, the Seventy-Two (72) consecutive hours shall include hours outside of normal working hours, Saturdays, Sundays, Federal holidays, and State holidays. (61) "Storage" shall mean the holding or accumulating of waste or other materials for a temporary period of time in accordance with this Permit. (62) "Sufficiently impervious" shall mean: (a) Free of gaps, cracks, and areas of bare earth; (b) Capable of containing any waste or other material that may be accidentally or otherwise released such that any such waste or other material released does not migrate or seep from or through the secondary containment system into the environment; (c) Compatible with any waste or other material that may be accidentally or otherwise released into the secondary containment system; (d) If necessary, coated with a material resistant to weathering or damage such that any waste or other material that may be accidentally or otherwise released into the secondary containment system does not migrate or seep from or through the secondary containment system into the environment; and (e) Free of floor or other drains; catch basins or similar structures that would allow any waste or other materials to be released into the environment. (63) "Tank" shall mean a stationary device, designed to contain an accumulation of waste or other material, which is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, and plastic) which provide structural support. (64) "Tank Systems" shall mean Tanks 11, 14, and the ancillary equipment, including, but not limited to, any equipment that conveys waste to and from the tank, containment system, etc. (65) "Transportation Vehicle" means a vehicle, including a trailer connected or disconnected from a power unit, used to transport waste or other materials to or from the Facility or to temporarily store waste or other materials at the Truck-to Truck Transfer Area or Truck Parking Area. The term "Transportation Vehicle" includes all containers, roll-off containers in, on or part of a vehicle or trailer that NEICVP1493E01 Appendix A Page 31 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut is connected or is disconnected from a power unit. Examples of "Transportation Vehicles" include, but are not limited to: (a) A vehicle with a container or roll-off container on such vehicle; (b) A trailer, whether or not connected to a vehicle or power unit; (c) A vehicle, a portion of which is comprised of a container or roll-off container; or (d) A vehicle that can itself be considered a container. "Transportation Vehicle" does not include a forklift, hand truck or similar device use to move waste or other material from one portion to another portion of the Facility. (66) "Truck-to-Truck Transfer Area" shall mean the area identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, including the Loading Dock, where the activities specified in Section II (A) (7) of this Permit may be conducted. (67) "Truck Parking Areas" or "Truck Parking Areas #1 and #3" shall mean the areas identified on Drawing No. 62WC-7100-204, titled Waste Management Areas, Site Plan, where the activities specified in Section II (A) (8) of this Permit may be conducted. (68) "Universal Waste" shall mean the wastes (batteries, certain pesticides, mercurycontaining equipment, and lamps) covered under 40 CFR Part 273, and used electronics specified in RSCA 22a-449(c)-113(b) (4). (69) "Used Oil" shall mean any oil refined from crude oil or synthetic oil, that: (a) has been used and as a result of such use is contaminated by physical or chemical impurities; or (b) is no longer suitable for the services for which it was manufactured due to the presence of impurities or a loss of original properties. (70) "Vacuum Truck" shall mean a Transportation Vehicle, such as a Cusco and Vactor, with a heavy duty vacuum designed to pneumatically load solids, liquids, sludge or slurry, with a maximum capacity of no greater than 4,000 gallons, specifically designed to transport the aforementioned materials. (71) "VO Concentration" shall mean the fraction by weight of the volatile organic compounds contained in a hazardous waste expressed in terms of parts per million (ppmw) as determined by direct measurement using Method 25D in 40 CFR Part 60, Appendix A or another method approved in writing by the Commissioner. For the purpose of determining the VO concentration of a hazardous waste, organic compounds with a Henry's law constant value of at least 0.1 mole-fraction-in-the-gas-phase/mole-fraction-in the liquid-phase (0.1 Y/X) (which can also be expressed as 1.810-6 atmospheres/gram-mole/m3) at 25 degrees Celsius must be included. (72) "Wastes" shall mean "hazardous waste", "CR01", "CR02", "CR03", "CR04", and "CR05" waste, "Non-Hazardous Waste", "Used Oil", "Biomedical Waste", NEICVP1493E01 Appendix A Page 32 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut "Asbestos-Containing Material", "Scrap Metal", "Universal Waste", and "PaintCare Program Waste" and all waste which after treatment at the Facility, no longer exhibits the characteristic of a hazardous waste and can be land disposed under 40 CFR Part 268. (73) "Waste Management Units" or "Waste Management Areas" unless specifically limited by this Permit or unless the context unequivocally indicates otherwise (e.g., that reference is being made to only one and not all areas), shall mean all of the waste management units at the Permittee's Facility, including the: : (1) Container Storage Areas; (2) Bulk Unloading and Loading Area (BULA); (3) Areas to Stage Containers (M1, M2, and H); (4) Tank Systems 11 and 14; (5) Mix-Tub, Bulk Storage and Transfer Area (MBSTA); (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing Stations, and Lab Pack Pour-Off Area); (7) Truck-to-Truck Transfer Area (TTTA), including the Loading/Unloading Dock (containers); and (8) Truck Parking Areas #1 and #3 for Up to 10-Days or Less. Waste Management Areas shall include all land used for, and any structures, other appurtenances, secondary containment area(s) on the property such as a road or path that is used for the transportation, movement, or temporary storage/staging of hazardous wastes on the property of the facility, and improvements in such areas. NEICVP1493E01 Appendix A Page 33 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION II PERMITTED ACTIVITIES COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 34 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION (A) SECTION II TABLE OF CONTENTS - PERMITTED ACTIVITIES TITLE Waste Management Areas . . . . . . (1) Container Storage Areas . . . . . (a) Authorized Activity . . . . . (b) Other . . . . . . . (c) Permitted Capacity . . . . . (d) Permitted Wastes and Other Materials . . (e) Prohibited Wastes and Other Materials - All Container Storage Areas . . . (f) Prohibited Wastes and Other Materials - Specific To Container Storage Areas . . . (2) Bulk Unloading and Loading Area (BULA) . . . (a) Authorized Activity . . . . . (b) Other . . . . . . . (c) Permitted Capacity . . . . . (d) Permitted Wastes and Other Materials . . (e) Prohibited Wastes and Other Materials . . (f) Other . . . . . . . (3) Areas to Stage Containers ("M1," "M2," and "H") For Up to five (5) Calendar Days . . . (a) Authorized Activity . . . . . (b) Time Limit . . . . . (c) Permitted Capacity . . . . . (d) Permitted Wastes and Other Materials . . (e) Prohibited Wastes and Other Materials . . (f) Other . . . . . . . (4) Tank Systems 11 and 14 . . . . . (a) Authorized Activity . . . . . (b) Permitted Capacity . . . . . (c) Permitted Wastes . . . . . (d) Prohibited Wastes and Other Materials. . . (e) Other . . . . . . (5) Mix-Tub, Bulk Storage and Transfer Area . . . (a) Authorized Activity . . . . . (b) Permitted Capacity . . . . . (c) Permitted Wastes . . . . . (d) Prohibited Wastes and Other Materials . . (e) Other . . . . . . . (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing Stations and Lab Pack Pour-Off Area) . . (a) Authorized Activity . . . . . PAGE II-4 II-4 II-4 II-5 II-5 II-6 II-7 II-8 II-10 II-10 II-10 II-10 II-11 II-12 II-13 II-13 II-13 II-15 II-15 II-15 II-17 II-18 II-18 II-18 II-18 II-18 II-19 II-20 II-20 II-20 II-23 II-24 II-29 II-30 II-30 II-30 NEICVP1493E01 Appendix A Page 35 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) Other . . . . . . . (c) Permitted Capacity . . . . . (d) Prohibited Wastes and Other Materials . (e) Prohibited Wastes and Other Materials - Specific . (f) Other . . . . . . . (7) Truck-To-Truck Transfer Area (TTTA), including Loading/Unloading Dock (containers) . . . (a) Authorized Activity . . . . . (b) Time Limit . . . . . . (c) Other . . . . . . . (d) Specific Prohibition . . . . . (e) Permitted Capacity . . . . . (f) Permitted Wastes and Other Materials . . . (g) Prohibited Wastes and Other Materials . . . (8) Truck Parking Areas #1 and #3 for Up to 10-Days or Less . (a) Authorized Activity . . . . . (b) Time Limit . . . . . . (c) Other . . . . . . . (d) Permitted Capacity . . . . . (e) Permitted Wastes and Other Materials . . . (f) Prohibited Wastes and Other Materials . . . II-31 II-31 II-31 II-33 II-33 II-33 II-33 II-34 II-35 II-35 II-35 II-35 II-38 II-38 II-38 II-39 II-39 II-39 II-39 II-42 (B) General Prohibitions . . . . . . . . II-43 (1) General Prohibitions . . . . . II-43 (2) Exception to General Prohibitions . . . . II-44 TABLES TITLE Table II-1 Waste Management Areas Selected Information . . II-45 Table II-2 Laboratory and Maintenance Products and Materials . II-48 DRAWINGS Drawing No. 62WC-7100-201 Drawing No. 62WC-7100-202 Drawing No. 62WC-7100-203 Drawing No. 62WC-7100-204 Drawing No, 62WC-7100-205 Drawing No. 62WC-7100-206 Drawing No. 62WC-7100-207 Drawing No. 62WC-7100-208 Drawing No. 62WC-7100-211 Drawing No. 62WC-7100-212 Drawing No. 62WC-7100-214 Drawing No. 62WC-7100-215 TITLE Permitted Storage Area C (In the BULA Area) Operations Building-Permitted Staging Area H Operations Building-Permitted Storage Area L Waste Management Areas-Site Plan (WMASP) Container Storage Building- Permitted Storage Areas - A, B, D, E, F, G and J Operations Building-Permitted Storage Area K Operations Building-Permitted Staging Area M1 Operations Building-Permitted Staging Area M2 Truck Parking Areas 1 and 3 - 10-Days or Less Truck-To-Truck Transfer Area (Loading/Unloading Operations Building-Permitted Storage Tank 11 Operations Building-Permitted Storage Tank 14 Dock) APPENDIX II-1 EPA PCB Commercial Storage Exemption Letter - December 11, 2018 NEICVP1493E01 Appendix A Page 36 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION II PERMITTED ACTIVITIES This Permit authorizes only those activities that are explicitly provided for in this Permit. As used in this Permit, the terms "management," "treatment," "process," or "storage" shall not be construed to authorize any activity that is not explicitly authorized by this Permit. (A) WASTE MANAGEMENT AREAS. The only Waste Management Areas in which the Permittee can engage in the activities authorized by this Permit are as follows: (1) Container Storage Areas; (2) Bulk Unloading and Loading Area (BULA); (3) Areas to Stage Containers ("M1," "M2," and "H"); (4) Area for Tank Systems 11 and 14; (5) MixTub, Bulk Storage and Transfer Area (MBSTA); (6) Miscellaneous Processing Areas (Drum Rinsing and Crushing Stations and Lab Pack Pour-off Area); (7) Truck-to-Truck Transfer Area (TTTA), including Unloading and Loading Dock (containers); and (8) Truck Parking Areas #1 and #3 for Up to 10-Days or Less. The location of these Waste Management Areas are shown on a February 14, 2019 drawing titled "Clean Harbors of Connecticut, Inc., Waste Management Areas Site Plan" referred to as "the WMASP." (Note: On the WMASP there is an area labeled as "Proposed Concrete Truck Staging Pad" since the Permittee has not submitted documentation on how this area is managed it cannot be authorized until all the plans are submitted in accordance with Section V, Compliance Schedule of this Permit). Certain summary information about each Waste Management Areas is presented in Table II-1, titled Waste Management Areas Selected Information. The Permittee shall not manage wastes or conduct any waste management activity in any other area of the Facility not listed above. The Permittee shall comply with the following requirements for each waste management area. (1) CONTAINER STORAGE AREAS (a) Authorized Activity. The Permittee is authorized to store containers, not including roll-off containers, of wastes or other materials in the Container Storage Areas. The Container Storage Areas at the Facility are located in the following areas which locations are shown on the referenced drawings: (i) In the Container Storage Building, Areas A, B#1 wastes, B#2 solids wastes only, D, E, F, G, and J shown on the WMASP and a February 13, 2019 drawing titled "Clean Harbors of Connecticut, Inc., Permitted Storage Areas A, B, D, E, F, G & J." Drawing No. 62WC-7100-205; (ii) In the Bulk Unloading and Loading Area (BULA), Area C, shown on the WMASP and a February 13, 2019 drawing titled "Clean Harbors of Connecticut, Inc., Permitted Storage Area C." Drawing No. 62WC-7100-201; and NEICVP1493E01 Appendix A Page 37 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iii) In the Operations Building, Areas K and L. Area L is shown on the WMASP and a drawing last revised on February 13, 2019, titled "Clean Harbors of Connecticut, Inc., Permitted Storage Area L." Drawing No. 62WC-7100-203; Area K is shown on the WMASP and a drawing last revised on February 13, 2019, titled "Clean Harbors of Connecticut, Inc., Permitted Storage Area K." Drawing No. 62WC-7100-206. (Note: While the designations B#1 and B#2 do not appear on the drawings noted above, the locations of such areas are discernible from the waste type restrictions noted on the drawing). The Permittee shall not use any other area of the Facility as part of a Container Storage Area or for the activities authorized in this section of the Permit. (b) Other than the collection of waste personal protective equipment for less than ninety (90) days, regulated under 40 CFR 262.34, the Permittee shall not bring to, place within, process, store, treat, mix, dispose of, or otherwise manage waste or other material in the Container Storage Areas in any way that is not authorized by this Permit. (c) Permitted Capacity. The Permittee shall ensure that at no time does the total volume or amount of waste or other material in each CSA exceed the following: AREA MAXIMUM CAPACITY IN GALLONS 1 A 2,750 2 B #1 (Rows 1-7) 18,480 (Wastes that are not Solid) 3 C 2,310 4 D 2,640 5 E 6,600 6 F 2,750 7 G 2,970 8 K 5,390 9 L 990 Total Volume in Gallons 44,880 MAXIMUM CAPACITY IN CUBIC YARDS 1 B #2 (Rows 8-10) 18 pallets equivalent to 42 (Wastes that are Solids-Only) cubic yards 2 J - Solid wastes only 40 cubic yards For purposes of determining compliance with the maximum storage capacity limit of each container storage area, each container in any such area shall be assumed to be full. NEICVP1493E01 Appendix A Page 38 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (d) Permitted Wastes and Other Materials. (i) Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials are permitted in Container Storage Areas B, D, E, F, G, K, L or J, (any Container Storage Area, except Container Storage Areas A and C): (I) The hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U018, U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U005, U021, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U006, U024, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U010, U026, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U011, U027, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U014, U028, U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U015, U030, U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U016, UO34, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, NEICVP1493E01 Appendix A Page 39 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411; (II) CR01, CR02, CR03, CR04 and CR05 wastes; (III) Universal wastes; (IV) Used oil; (V) Other materials; (VI) Waste or other materials containing PCBs. This includes any PCB Item. PCB wastes should be stored in accordance with the EPA approval letter requirements issued on December 11, 2018, and (VII) PaintCare Program Waste and PaintCare Non-Program Waste. (ii) Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials are permitted in Container Storage Area C: (I) Wastes, in liquid form only, with a flash point of 200 degrees Fahrenheit or less; (II) Wastes, that are solid, semi-solid or compressed gas, that exhibit the characteristic of ignitability specified in 40 CFR 261.21(a)(2) or (3); and (III) Diesel fuel for use at the facility. (e) Prohibited Waste and Other Materials - All Container Storage Areas. The Permittee shall not bring to, place within, or allow in any Container Storage Area: (i) Any waste or other material specified in Section II (B)(1) of this Permit; (ii) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for oxidizers in lab packs containers; NEICVP1493E01 Appendix A Page 40 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iii) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for waste or other materials in Lab Packs 1 liter or less for liquids or 2.85 kilograms or less for solids. (f) Prohibited Waste and Other Materials - Specific to Container Storage Areas. (i) The Permittee shall not bring to, place within or allow in Container Storage Areas B, C, D, E, F, G, K, L, or J, any waste or other material that is not specified in Section II(A)(1)(d) of this Permit, (ii) The Permittee shall not bring to, place within or allow in Container Storage Area A (CSA-A), any waste or other material, other than the following, provided such wastes or materials are specified in Section II (A)(1)(d)(i) of this Permit: (I) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(2) or 40 CFR 261.23(a)(4), provided: (A) The waste is in lab packs only and not in any other container; and (B) The Permittee complies with all DOT packaging standards regarding such waste. (II) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(5), provided: (A) Such waste must be in containers no larger than fifty-five (55) gallons, although such containers may be placed inside containers greater than fiftyfive gallons; and (B) Hydrogen cyanide and hydrogen sulfide air monitors capable of detecting the release of any 40 CFR 261.23(a)(5) waste, including gaseous waste, are installed and remain in good-working order in CSA-A; (III) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6), provided, the Permittee shall ensure that any such waste, other than waste containing hydrogen peroxide, is limited to aerosol cans only with a capacity that does not exceed 32 ounces; (IV) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6) that contains hydrogen peroxide, provided that hydrogen peroxide does not constitute more NEICVP1493E01 Appendix A Page 41 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 than twenty (20) percent of such waste and the waste is in containers no greater than fifty-five (55) gallons in size; (V) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6) that contains hydrogen peroxide, provided that if hydrogen peroxide constitutes more than twenty (20) percent, but less than or equal to thirty (30) percent of such waste: (A) The waste is in containers no greater than fifty-five (55) gallons, although such containers may be placed inside containers greater than fifty-five gallons; and (B) At all times when such waste is present at the Facility the containers holding such waste have a vented closure capable of preventing accumulation of internal pressure; and (VI) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6) that contains hydrogen peroxide, provided that if hydrogen peroxide constitutes more than thirty (30) percent, but less than or equal to sixty (60) percent of such waste, the waste can only be in lab pack containers. (iii) Provided it is not otherwise prohibited by this Permit, only waste or other materials that are not solid, are permitted in Container Area B#1 and only waste or other materials that are solid, i.e., do not contain any free liquids, are permitted in Container Area B#2. (iv) The Permittee shall not bring to, place within or allow in Container Storage Area C, any waste or other material, other than the following wastes or materials, provided such wastes or materials are specified in Section II(A)(1)(d)(ii) of this Permit: (I) Wastes, in liquid form only, with a flash point of 200 degrees Fahrenheit or less; (II) Wastes, that are solid, semi-solid or compressed gas, that exhibit the characteristic of ignitability specified in 40 CFR 261.21(a)(2) or (3); and (III) Diesel fuel for use at the facility. (v) Provided it is not otherwise prohibited by this Permit, only waste or other materials that are solid, i.e., do not contain any free liquids, are permitted in Container Storage Area J. Appendix A Page 42 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (g) Prohibited Activity: The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage in a Container Storage Area any waste or other material that is not specifically authorized in Section II (A)(1) of this Permit. (2) BULK UNLOADING AND LOADING AREA (BULA) (a) Authorized Activity. The Bulk Unloading and Loading Area ("BULA") is 55 feet by 11.25 feet, identified on Drawing No. 62WC-7100-204 WMASP. The Permittee shall not use any other area of the Facility as part of the BULA. In addition, except as is specifically authorized by this Permit, the Permittee shall not use any other area of the Facility for the activities authorized in this section of the Permit. In the BULA the Permittee is authorized to: (i) Pump waste or other materials in liquid form from a Transportation Vehicle or from containers to the On-Site Wastewater Treatment System; (ii) Pump waste in liquid form from a Transportation Vehicle or from containers into Tanks 11 or 14; (iii) Load, in a Transportation Vehicle, waste in liquid form that is pumped from Tanks 11 or 14 for off-site shipment; (iv) Pump waste in liquid form from one Transportation Vehicle into another Transportation Vehicle; (v) Pump waste or other material in liquid form from a Transportation Vehicle into a container; and (vi) Store flammable waste or diesel fuel for use at the Facility in containers in CSA - C as provided for in Section II(A)(1) of this Permit. (b) Other than the accumulation of sludge from the filter press of the On-Site Wastewater Treatment Plant, which is subject to regulation under 40 CFR 262.34 if it is a hazardous waste and if not, is a CR05 non-hazardous waste, the Permittee shall not bring to, place within, process, store, treat, mix, dispose of, or otherwise manage waste or other material in the BULA in any way that is not authorized by this Permit. (c) Permitted Capacity. (i) The Permittee shall ensure that at no time does the total volume or amount of waste or other material in the BULA exceed the NEICVP1493E01 Appendix A Page 43 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut following: (I) 13,200 gallons of waste on Transportation Vehicles (equivalent to 2-6,000-gallon tankers or 240, 55-gallon containers); and (II) 2,310 gallons of waste (equivalent to 42, 55-gallon containers) in Storage Area C, located in the BULA, as identified on Drawing No. 62WC-7100-201. For purposes of determining compliance with the Permitted Capacity of the BULA each Transportation Vehicle or container in the BULA shall be assumed to be full. (d) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited by this Permit, except for the waste and diesel fuel in Container Storage Area C and the area of the BULA used for the accumulation of sludge from the On-Site Wastewater Treatment Plant, only the following wastes or other materials in liquid form are permitted in the BULA: (i) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, NEICVP1493E01 Appendix A Page 44 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut U091, U109, U141, U157, U174, U186, U204, U221, U243, U372, U093, U111, U142, U158, U175, U187, U205, U222, U244, U373, U094, U114, U143, U163, U176, U191, U206, U223, U247, U387, U095, U116, U145, U164, U177, U192, U207, U225, U248, U389, U097, U119, U148, U166, U178, U193, U210, U226, U271, U394, U101, U120, U149, U167, U179, U197, U214, U227, U278, U395, U102, U122, U150, U168, U180, U200, U215, U235, U279, U409, U105, U126, U151, U170, U181, U201, U217, U236, U280, U410, U106, U129, U152, U172, U183, U202, U218, U237, U364, U411; U107, U137, U155, U173, U185, U203, U219, U238, U367, (ii) CR02, CR03 and CR04 waste; (iii) Used oil; (iv) Other materials; and (v) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(5) and no other waste specified in 40 CFR 261.23; (e) Prohibited Wastes and Other Materials. The Permittee shall not bring to, place within, or allow in the BULA: (i) Any waste or other material not authorized under Sections II (A) (2) (b) and II(A)(2)(d) of this Permit; (ii) Any waste or other material specified in Section II (B) (1) of this Permit; (iii) Any waste or other materials containing PCBs. This includes any PCB Item; (iv) Any hazardous waste with a VO concentration equal to greater than 500 parts per million by weight (500 ppmw); except for containers stored in Area C containing hazardous waste with a VO concentration greater than 500 ppmw that shall comply with the Level Controls as required by 40 CFR 264.1086(d); (v) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; and (vi) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table. (f) The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage any waste or other material in the NEICVP1493E01 Appendix A Page 45 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut BULA that is not specifically authorized in this section of the Permit. (3) AREAS TO STAGE CONTAINERS ("M1," "M2" and "H") FOR UP TO FIVE (5) CALENDAR DAYS (a) Authorized Activity. The Areas to Stage Containers include Areas M1 and M2 and the nine (9) areas designated as Area H. The Areas to Stage Containers are all located in the Operations Building at the Facility. The nine (9) areas designated as Area H are shown in the WMASP and a February 13, 2019 drawing titled "Clean Harbors of Connecticut Inc., Permitted Staging Area H." drawing No. 62WC-7100-202. These nine areas have the following dimensions: 2 areas - 25.3 feet x 5.625 ("Areas H1 and H2") 2 areas - 20.625 feet x 6.25 feet ("Areas H3 and H4") 2 areas - 9.375 feet x 5.625 feet ("Areas H5 and H6") 1 area - 14.0 feet x 5.625 feet ("Area H7") 1 area - 18.75 feet x 6.25 feet ("Area H8") 1 area - 30 feet x 5.625 feet ("Area H9") (Note: the designation H1 through H9 do not appear on the drawings noted above but are noted here by dimension and used in Section (d), Permitted Capacity and Table II-1, below). Area M1 is shown on the WMASP and a drawing dated February 13, 2019, titled "Clean Harbors of Connecticut, Inc., Permitted Storage Area M1." Drawing No. 62WC-7100-207; and Area M2 is shown on the WMASP and a drawing dated February 13, 2019, titled "Clean Harbors of Connecticut, Inc., Permitted Storage Area M2." Drawing No. 62WC7100-208. Except as is otherwise authorized by this Permit, the Permittee shall not use any other area of the Facility as part of an area to stage containers or for the activities authorized in this section of the Permit. (i) In the nine (9) areas designated as Area H, the Permittee is authorized to: (I) Sample and stage waste or other materials in containers, prior to: (A) Pumping such waste or other materials into the OnSite Wastewater Treatment System; (B) Pumping such waste into tanks 11 or 14; NEICVP1493E01 Appendix A Page 46 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (C) Treating such waste in the Mix-Tub; (D) Relocation to a designated Container Storage Area; or (E) Off-site shipment; (II) Pump wastes or other materials in liquid form from containers into the On-Site Wastewater Treatment Plant; (III) Pump wastes in liquid form from containers into tanks 11 or 14; and (IV) Over-pack containers of waste or other materials whose integrity has been compromised. (ii) In the nine areas designated as Area H, in addition to the activities specified in Section II(A)(3)(a)(i) of this Permit, the Permittee is authorized to: (I) Open and unpack containers with lab packs and consolidate the containers from these lab packs into other or into larger lab pack containers; and (II) Remove wastes or other materials from lab pack containers to be poured into the lab pack pour-off sink. (iii) In the area designated as M1 the Permittee is authorized to: (I) Sample and stage acidic waste or other material in containers prior to relocation to a designated Container Storage Area; and (II) Over-pack containers of waste or other material whose integrity has been compromised. (iv) In the area designated as M2, the Permittee is authorized to: (I) Sample and stage alkaline waste or other material in containers prior to relocation to a Container Storage Area; (II) Over-pack containers of waste or other material whose integrity has been compromised; (III) Sort and stage PaintCare Program Waste; and (IV) Sample unlabeled PaintCare Non-Program Waste in Appendix A Page 47 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut accordance with Section III(C)(7)(d) of this Permit. (b) The Permittee shall ensure that no container of waste or other material remains in the Areas to Stage Containers longer than five (5) calendar days. In calculating these five (5) calendars days limit, the time a container of waste or other material remains in any Area to Stage Containers shall be included. The five (5) calendar day limit shall be calculated based upon date waste or other material is first received in any Area to Stage Containers. (c) Permitted Capacity. The Permittee shall ensure that at no time does the total volume or amount of waste or other material in each Area to Stage Containers exceed the following: (i) For Area M1 - 6,820 gallons; (ii) For Area M2 - 4,950 gallons; (iii) For the nine (9) areas designated as Area H: Areas H1 and H2 - 1320 gallons each Areas H3 and H4 - 1100 gallons each Areas H5 and H6 - 440 gallons each Area H7 - 660 gallons Area H8 - 880 gallons Area H9 - 1,540 gallons Area H total combined volumetric capacity is 8,800 gallons. For purposes of determining compliance with the Permitted Capacity of the Area to Stage Containers, each container in any Area to Stage Containers shall be assumed to be full. (d) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials are permitted in the Area to Stage Containers: (i) For Area M1 - Acidic Waste or other material only; (ii) For Area M2 - Alkaline waste or other material, PaintCare Program Waste and PaintCare Non-Program Waste only; and (iii) For the nine (9) areas designated as Area H: (I) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, NEICVP1493E01 Appendix A Page 48 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U018, U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U181, U197, U207, U222, U238, U280, U395, U005, U021, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U183, U200, U210, U223, U243, U364, U409, U006, U024, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U185, U201, U214, U225, U244, U367, U410, U010, U026, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U186, U202, U215, U226, U247, U372, U411; U011, U027, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U187, U203, U217, U227, U248, U373, U014, U028, U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U191, U204, U218, U235, U271, U387, U015, U030, U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U192, U205, U219, U236, U278, U389, U016, UO34, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, U193, U206, U221, U237, U279, U394, (II) CR01, CR02, CR03, CR04 and CR05 wastes; (III) Universal wastes; (IV) Used oil; (V) Crushed metal drums and scrap metal appliances and any Appendix A Page 49 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut other waste that the Commissioner has approved, in writing, for management at the Facility as a scrap metal; (VI) Other materials; (VII) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(2) or 40 CFR 261.23(a)(4), provided: (A) The waste is in lab packs only and not in any other container; and (B) The Permittee complies with all DOT packaging standards regarding such waste; (VIII) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(5), provided: (A) Such waste must be in containers no larger than fifty-five (55) gallons; and (B) Cyanide sulfide air monitors capable of detecting the release of any 40 CFR 261.23(a)(5) waste, including gaseous waste, are installed and remain in good-working order in the Operations Building; (IX) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(6), provided, the Permittee shall ensure that any such waste, other than waste containing hydrogen peroxide, is limited to aerosol cans only with a capacity that does not exceed 32 ounces; and (X) Waste or other materials containing PCBs. This includes any PCB Item should be stored in accordance with EPA Approval letter issued on December 11, 2018. (e) Prohibited Wastes and Other Materials - All Areas to Stage Containers. The Permittee shall not bring to, place within, or allow in any Area to Stage Containers: (i) Any waste or other material not authorized under Section II(A)(3)(e) of this Permit; (ii) Any waste or other material specified in Section II(B)(1) of this Permit; (iii) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 NEICVP1493E01 Appendix A Page 50 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut table, except for oxidizers in lab packs containers; and (iv) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for waste or other materials in Lab Packs 1 liter or less for liquids or 2.85 kilograms or less for solids. (f) The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage any waste or other material in any Area to Stage Containers that is not specifically authorized in this section of the Permit. (4) TANK SYSTEMS 11 AND 14 (a) Authorized Activity. Tank Systems 11 and 14 are located in the Operations Building. Tank 14 only, not other parts or piping associated with this tank, is shown on the WMASP and the February 13, 2019 drawing titled "Permitted Storage Tank 14." Drawing No. 62WC-7100215; and Tank 11 only, not other parts or piping associated with this tank, is shown on the WMASP and the February 13, 2019 drawing, titled "Clean Harbors of Connecticut, Inc., Permitted Storage Tank 11." Drawing No. 62WC-7100-214. The Permittee shall not use any other area of the Facility as part of these tank systems or for the activities authorized in this section of the Permit. The Permittee is prohibited to store in Tank Systems 11 and 14 wastes with Volatile Organic concentrations greater than 500 parts per million by weight (ppmw). (b) Permitted Capacity. The Permittee shall ensure that at no time does the total volume or amount of waste in Tanks 11 and 14 exceed the following: (i) For Tank 11 - 4,116 gallons; and (ii) For Tank 14 - 10,836 gallons. (c) Permitted Wastes. Provided it is not otherwise prohibited by this Permit, only the following wastes in liquid form are permitted in Tanks Systems 11 or 14: (i) CR02, CR03 and CR04 wastes; and (ii) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D002, D004, D005, D006, D007, D008, D009, D010, D011, D018, D019, D021, D022, D023, D024, D025, D026, D027, D028, D029, NEICVP1493E01 Appendix A Page 51 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut D030, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F032, F034, F035, F037, F038, F039 P001, P002, P007, P010, P021, P026, P030, P036, P037, P039, P040, P041, P044, P045, P046, P049, P057, P059, P066, P070, P072, P082, P085, P087, P088, P089, P093, P094, P097, P111, P113, P114, P115, P116, P118, P119, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U005, U035, U061, U089, U122, U155, U177, U193, U221, U248, U387, U010, U038, U062, U090, U129, U157, U178, U197, U222, U271, U389, U014, U039, U063, U091, U141, U164, U179, U200, U225, U278, U394, U015, U047, U067, U094, U142, U166, U180, U202, U235, U279, U395, U016, U049, U068, U095, U143, U167, U181, U203, U237, U280, U409, U018, U051, U073, U101, U145, U168, U183, U214, U238, U364, U410. U021, U058, U081, U114, U148, U172, U185, U215, U243, U367, U024, U026, U059, U060, U082, U087, U116, U119, U150, U151, U173, U174, U187, U192, U218, U219, U244, U247, U372, U373, (d) Prohibited Wastes and Other Materials - Tanks 11 and 14. The Permittee shall not bring to, place within, or allow in Tank Systems 11 or 14: (i) Any waste or other material not authorized under the Section II(A)(4)(c) of this Permit; (ii) Any waste or other material specified in Section II(B)(1) of this Permit; (iii) Waste or other materials containing PCBs; (iv) Any hazardous waste with a Volatile Organic concentration equal to or greater than 500 parts per million by weight; (v) Any hazardous waste specified in 40 CFR 261.23; (vi) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; and (vii) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table. NEICVP1493E01 Appendix A Page 52 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (e) The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage any waste or other material in Tank Systems 11 or 14 that is not specifically authorized in this section of the Permit. (5) MIX-TUB, BULK STORAGE AND TRANSFER AREA (MBSTA) (a) Authorized Activity. The Mix-Tub, Bulk Storage and Transfer Area ("MBSTA") is identified on Drawing No. 62WC-7100-204 of the WMASP. The Permittee shall not use any other area of the Facility as part of the MBSTA. In addition, except as is specifically authorized by this Permit, the Permittee shall not use any other area of the Facility for the activities authorized in this section of the Permit. (i) Storage (I) The Permittee is authorized to store in the MBSTA for up to, but no more than, thirty (30) calendar days: (A) Wastes in a solid or semi-solid state (i.e., no liquids): (1) In roll-off containers; and (2) In or on a Transportation Vehicle; and (B) Wastes or other materials in a Vacuum Truck. (II) The Permittee shall not use the Mix-Tub for the storage of any waste or other materials. (III) The Permittee shall ensure that no wastes or other materials is stored in the MBSTA for more than thirty (30) calendar days. These thirty (30) calendars day limit shall begin the date that any such waste or other material first arrives at the Facility, including any waste that has been solidified, stabilized, or bulked in the Mix-Tub, except that for waste in containers stored in other waste management areas at the Facility, these thirty (30) calendars day limit shall begin on the date any such container is brought to the MBSTA. (ii) Transfer. The Permittee is authorized to pump: (I) Waste or other material in liquid form from a Vacuum Truck in the MBSTA to the On-Site Wastewater Treatment Plant, or into a container; NEICVP1493E01 Appendix A Page 53 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (II) Waste in liquid from a Vacuum Truck in the MBSTA into Tank Systems 11 or 14. (iii) Stabilization in the Mix-Tub. The Permittee is authorized to stabilize certain hazardous waste only in the Mix-Tub, provided that stabilization is performed only by adding in a stabilization reagent such as cement kiln dust, lime or fly ash, to treat hazardous constituents by chemical fixation. (iv) Solidification in the Mix-Tub. The Permittee is authorized to use the Mix-Tub for solidification of waste, including liquids present in a distinct phase one inch or less only, to render such waste more amenable for shipment off-site, treatment or disposal. The Permittee shall solidify such waste only by adding in a solidification agent (e.g., paper pulp, saw dust, corncob grit). (v) Bulking. The Permittee is authorized to bulk wastes with similar composition in the Mix-Tub or in roll-off containers, provided: (I) At no time shall RCRA and Non-RCRA wastes be bulked or mixed together at the facility. (II) The waste to be bulked in roll-off containers shall come only from other containers or roll-off containers. (III) The waste to be bulked in the Mix-Tub comes from roll-off containers, other containers, or from a Transportation Vehicle, including a Vacuum Truck. And, (IV) Bulking is performed solely for the purpose of accumulating sufficient quantities for shipment off-site. (vi) In connection with the uses of the Mix-Tub authorized pursuant to Section II(A)(5)(a)(iii)-(v) inclusive of this Permit, the Permittee is authorized to: (I) Temporarily stage, 8-55 gallon, containers with waste in the Mix-Tub Drum Process Area identified on Drawing No. 62WC-7100-204 WMASP and transfer wastes in semisolid or solid form, i.e., no liquids, in such containers into the Mix-Tub, provided: (A) Containers are staged in this area only when the waste in such containers is being emptied or offloaded into the Mix-Tub and at no other time; and Appendix A Page 54 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (B) Such containers are not temporarily staged in the Mix-Tub Drum Process Area for more than six (6) consecutive hours, beginning from the time any such waste is first placed in this Area and that all six consecutive hours are within one calendar day, i.e., the six (6) consecutive hours cannot include a part of two calendar days; (II) Transfer hazardous wastes to be stabilized, in semi-solid or solid form, i.e., no liquids, being stored in a roll-off container, other container, Transportation Vehicle, including a Vacuum Truck, in the MBSTA into the MixTub; (III) Transfer wastes, after they have been solidified, stabilized, or bulked in the Mix-Tub, into a roll-off container or a Transportation Vehicle; and (IV) Use the Mix-Tub for the collection of rinsate from the decontamination of containers, roll-off containers, or Transportation Vehicles, including Vacuum Trucks, whose waste was emptied into or off-loaded into the Mix-Tub, provided that: (1) The Permittee may add such rinsate to the Mix-Tub only to serve as a reagent for the stabilization of hazardous waste - and for no other purpose, (i.e., rinsate cannot be added to waste being solidified or bulked); (2) If there is no waste in the Mix-Tub at the time such rinsate is added to the Mix-Tub, the Permittee shall remove and collect all such rinsate before adding any waste to the Mix-Tub and all collected rinsate shall be transferred to the On-Site Waste Wastewater Treatment Plant or to Tank Systems 11 or 14, provided the Permittee is authorized to receive such rinsate at the On-Site Wastewater Treatment Plant or Tank Systems 11 or 14; (3) The Permittee shall manage all rinsate put into the Mix-Tub as containing all of the wastes that were removed from the container, roll-off container, or Transportation Vehicle, including a Vacuum Truck, before decontamination, including, but not limited to, all hazardous waste codes. Appendix A Page 55 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (vii) Except as is provided for in Section II(A)(5)(a)(vi)(IV) of this Permit, the Permittee shall not stabilize, solidify, bulk, or place any liquids in the Mix-Tub and shall ensure that all of the waste to be stabilized, solidified, or bulked under this provision is in a solid or semi-solid physical state. (viii) For purposes of Section II (A) (5)(a) of this Permit: (I) In a solid state shall mean characterized by structural rigidity and resistance to changes of shape or volume. Unlike a liquid, a solid does not flow to take on the shape of its container, nor does it expand to fill the entire volume available to it like a gas does; (II) In a semi-solid state shall mean a waste or other material that lies along the boundary between a solid and a liquid. While similar to a solid in some respects, in that semisolids can support their own weight and hold their shapes, a semi-solid also shares some properties of liquids, such as conforming in shape to something applying pressure to it and the ability to flow under pressure. Mayonnaise is an example. Mayonnaise does not hold its shape like a solid but does not flow like a liquid; and (III) Any prohibition concerning liquids, i.e., no liquids, shall not include liquids that may have settled during transportation, provided that liquids that have settled during transportation shall be limited to liquids present in a separate distinct phase that do not occupy more than one inch in a roll-off container, Transportation Vehicle, or the Mix-Tub. (b) Permitted Capacity (i) The Permittee shall ensure that at no time is there more than 27 cubic yards of waste, stabilization agent or solidification agent in the Mix-Tub. In addition, the Permittee shall ensure that the daily maximum through-put for the Mix-Tub, five-hundred forty (540) cubic yards per day, is not exceeded. (ii) Excluding the Mix-Tub, the Permittee shall ensure that at no time does the total volume of waste or other material in the MBSTA exceed: (I) Four hundred sixty (460) cubic yards for roll-off containers or Transportation Vehicles only if there are no Vacuum Trucks in the MBSTA; NEICVP1493E01 Appendix A Page 56 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (II) Four hundred twenty (420) cubic yards for roll-off containers or Transportation Vehicles if either: (A) There is one Vacuum Truck in the MBSTA; or (B) The Mix-Tub is in use; (III) Three hundred eighty (380) cubic yards for roll-off containers or Transportation Vehicles if: (A) There is one Vacuum Truck in the MBSTA, and the Mix-Tub is in use; or (B) There are two Vacuum Trucks in the MBSTA, and the Mix-Tub is not in use; (IV) Three hundred forty (340) cubic yards for roll-off containers or Transportation Vehicles if: (A) There are two Vacuum Trucks in the MBSTA, and the Mix-Tub is in use; and (V) 8,000 gallons for Vacuum Trucks. The amounts specified in this section shall be reduced by the number of drums in the Mix-Tub Process area specified in Section II(A)(5)(a)(vi)(I) of this Permit. For purposes of determining compliance with this provision, each container, roll-off container, Vacuum Truck or Transportation Vehicle in the MBSTA shall be assumed to be full. (iii) The Permittee shall ensure that the permitted capacity of the MixTub Drum Staging Area, 8 - 55-gallon drums, is not exceeded at any time. (c) Permitted Wastes. (i) Storage. Provided it is not otherwise prohibited by the Permit, only the following wastes or other materials are permitted to be stored in the MBSTA: (I) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, NEICVP1493E01 Appendix A Page 57 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U018, U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U181, U197, U207, U221, U237, U279, U394, U005, U021, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U183, U200, U210, U222, U238, U280, U395, U006, U024, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U185, U201, U213, U223, U243, U364, U409, U010, U026, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U186, U202, U214, U225, U244, U367, U410, U011, U027, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U187, U203, U215, U226, U247, U372, U411; U014, U028, U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U191, U204, U217, U227, U248, U373, U015, U030, U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U192, U205, U218, U235, U271, U387, U016, U034, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, U193, U206, U219, U236, U278, U389, (II) CR02, CR03, CR04, and CR05 wastes; (III) Crushed metal drums and scrap metal appliances and any other waste or other material that the Commissioner has approved, in writing, for management at the Facility as a scrap metal; (IV) After treatment in the Mix-Tub, characteristic waste which no longer exhibits the characteristic of a hazardous waste and can be land disposed under 40 CFR Part 268; and Appendix A Page 58 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (V) Other Material (In Vacuum Trucks only). (ii) Stabilization. Provided it is not otherwise prohibited by this Permit, the Permittee is authorized to stabilize in the Mix-Tub only those hazardous wastes listed in the table in 40 CFR 268.40, entitled "Treatment Standards for Hazardous Wastes" if: (I) The treatment standard for one or more constituents specified in 40 CFR 268.40 is STABL, stabilization, rather than a concentration level; or (II) After the addition of reasonable amounts of stabilization reagents, at least one of the hazardous constituents shall be at or below the value specified in the table in 40 CFR 268.40 for such waste. (iii) Solidification. Provided it is not otherwise prohibited by this Permit, the Permittee is authorized to solidify only the following wastes in the Mix-Tub: (I) CR05 waste; or (II) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F028, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, U034, Appendix A Page 59 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U181, U197, U207, U221, U237, U279, U394, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U183, U200, U210, U222, U238, U280, U395, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U185, U201, U213, U223, U243, U364, U409, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U186, U202, U214, U225, U244, U367, U410, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U187, U203, U215, U226, U247, U372, U411. U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U191, U204, U217, U227, U248, U373, U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U192, U205, U218, U235, U271, U387, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, U193, U206, U219, U236, U278, U389, (iv) Bulking. Provided it is not otherwise prohibited by this Permit, the Permittee is authorized to bulk only the following wastes in the Mix-Tub or in roll-off containers: (I) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F028, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, U034, Appendix A Page 60 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U181, U197, U207, U221, U237, U279, U394, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U183, U200, U210, U222, U238, U280, U395, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U185, U201, U213, U223, U243, U364, U409, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U186, U202, U214, U225, U244, U367, U410, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U187, U203, U215, U226, U247, U372, U411; U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U191, U204, U217, U227, U248, U373, and U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U192, U205, U218, U235, U271, U387, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, U193, U206, U219, U236, U278, U389, (II) CR05 waste. (v) Transfer. Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials, in liquid form, are permitted to be transferred from the MBSTA: (I) CR02, CR03 and CR04 wastes; (II) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F032, F034, F035, F037, F038, F039 P001, P002, P007, P010, P021, P026, P030, P036, P037, P039, P040, P041, P044, P045, P046, P049, P057, P059, P066, P070, P072, P082, P085, P087, P088, P089, P093, P094, P097, P111, P113, P114, P115, P116, P118, P119, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U005, U010, U014, U015, U016, U018, U021, U024, U026, U035, U038, U039, U047, U049, U051, U058, Appendix A Page 61 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut U059, U074, U095, U142, U164, U178, U193, U218, U238, U280, U395, U060, U081, U101, U143, U166, U179, U197, U219, U243, U364, U409, U061, U082, U114, U145, U167, U180, U200, U221, U244, U367, U410 U062, U087, U116, U148, U168, U181, U202, U222, U247, U372, U063, U089, U119, U150, U172, U183, U203, U223, U248, U373, U067, U090, U122, U151, U173, U185, U214, U225, U271, U387, U068, U091, U129, U155, U174, U187, U215, U235, U278, U389, U073, U094, U141, U157, U177, U192, U217, U237, U279, U394, (III) Other Materials (In Vacuum Trucks only). (d) Prohibited Wastes and Other Materials. (i) Mix-Tub, Bulk Storage and Transfer Area. The Permittee shall not bring to, place within, or allow anywhere in the MBSTA, including the MixTub: (I) Any waste or other material not authorized under Section II (A)(5)(a) or II (A)(5)(c) of this Permit; (II) Any waste or other material specified in Section II (B)(1) of this Permit; (III) Any hazardous waste specified in 40 CFR 261.23; (IV) Liquids or waste or other materials that contain liquids. This prohibition, however, does not apply to: (A) Rinsate from rinsing containers, or Transportation Vehicles, including Vacuum Trucks, whose waste or other materials has been emptied or off-loaded into the Mix-Tub; (B) Wastes or other materials that are contained in Vacuum Trucks while in storage or awaiting transfer; or (C) Liquids that may have settled during transportation, provided that liquids that have settled during transportation shall be limited to liquids present in a separate distinct phase that do not occupy more than one inch in a roll-off container or Transportation Vehicle; NEICVP1493E01 Appendix A Page 62 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (V) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (VI) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (VII) Any hazardous waste with a VO concentration equal to or greater than 500 parts per million by weight, except for hazardous waste in a roll-off container that has a cover that complies with 40 CFR 264.1086(c)(ii) and the Permittee ensures that any such waste remains in the roll-off container and that the afore-mentioned cover remains on the roll-off container at all times when such waste is at the Facility. (VIII) Waste or other materials containing PCBs. This includes any PCB Item, except for soils contaminated with PCBs that are not prohibited only when stored in roll-off containers. (e) The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage any waste or other material in the MBSTA that is not specifically authorized in this section of the Permit. (6) MISCELLANEOUS PROCESSING AREAS (a) Authorized Activity. The Miscellaneous Processing Areas ("MPAs") at the Facility are the Drum Crusher Area, the Acidic and Alkaline Drum Rinse Stations and the Lab Pack Pour-Off Area. The MPAs are within the Operations Building at the Facility. The Drum Crusher Area, the Acidic and Alkaline Drum Rinse Stations are shown on the WMASP, Drawing No. 62WC-7100-204. The Permittee shall not use any other area of the Facility as part of the MPAs or for the activities authorized in this section of the Permit. (i) In the Drum Crusher Area, the Permittee is authorized to crush empty metal containers no greater than fifty-five (55) gallons. (ii) In the Alkaline Drum Rinse Station, the Permittee is authorized to rinse empty containers that formerly contained only alkaline or neutral waste or other material. (iii) In the Acidic Drum Rinse Station, the Permittee is authorized to rinse empty containers that formerly contained acidic waste or other material. NEICVP1493E01 Appendix A Page 63 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iv) In the Lab Pack Pour-Off Area, the Permittee is authorized to pour waste or other materials from lab packs only into a sink so that the waste or other material enter the On-Site Wastewater Treatment Plant. (b) The Permittee shall not bring to, place within, process, store, treat, mix, dispose of, or otherwise manage waste or other material in any MPA in any way that is not authorized by this Permit. (c) Permitted Capacity. (i) The Permittee shall ensure that there are no more than four (4) liters (liquid) in glass containers and twenty (20) liters (liquid) in metal or plastic containers or 14.25 kilograms (solids) of waste or other materials in the Lab Pack Pour-Off Area at any one time. The limits are per 49 CFR 173.12(b)(2), Combination packaging requirements for Lab packs, exception for shipment of waste materials. (ii) The Permittee shall ensure that there is no waste or other materials in the Drum Crusher Area, Acidic Drum Rinse Station or Alkaline Drum Rinse Station, except for containers to be crushed or rinsed, as applicable and any waste generated by the operation of such Rinse Station or Drum Crusher. (d) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited by this Permit, only the following are permitted in Miscellaneous Processing Areas: (i) In the Drum Crusher Area - empty metal containers no greater than fifty-five (55) gallons to be crushed; (ii) In the Acidic Drum Rinse Area - Empty containers that formerly contained acidic waste or other materials; (iii) In the Alkaline Drum Rinse Area - Empty containers that formerly contained alkaline or neutral waste or other materials; and (iv) Lab Pack Pour-Off Area - In Lab Pack containers only: (I) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, NEICVP1493E01 Appendix A Page 64 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U018, U035, U050, U064, U080, U090, U105, U120, U145, U158, U173, U181, U197, U207, U222, U238, U280, U395, U005, U021, U036, U051, U066, U081, U091, U106, U122, U148, U163, U174, U183, U200, U210, U223, U243, U364, U409, U006, U024, U038, U058, U067, U082, U093, U107, U126, U149, U164, U175, U185, U201, U214, U225, U244, U367, U410, U010, U026, U039, U059, U068, U085, U094, U109, U129, U150, U166, U176, U186, U202, U215, U226, U247, U372, U411; U011, U027, U042, U060, U071, U086, U095, U111, U137, U151, U167, U177, U187, U203, U217, U227, U248, U373, U014, U028, U047, U061, U073, U087, U097, U114, U141, U152, U168, U178, U191, U204, U218, U235, U271, U387, U015, U030, U048, U062, U074, U088, U101, U116, U142, U155, U170, U179, U192, U205, U219, U236, U278, U389, U016, UO34, U049, U063, U079, U089, U102, U119, U143, U157, U172, U180, U193, U206, U221, U237, U279, U394, (II) CR02, CR03, and CR04 wastes; (III) Other materials; and (IV) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(2) or 40 CFR 261.23(a)(4). Appendix A Page 65 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (e) Prohibited Wastes and Other Materials - Specific. (i) The Miscellaneous Processing Areas. The Permittee shall not bring to, place within, or allow anywhere in an MPA: (I) Any waste or other material not authorized under Section II(A)(6)(d) of this Permit; and (II) Any waste or other material specified in Section II(B)(1) of this Permit. (ii) The Lab Pack Pour-Off Area. In addition to Section II(A)(6)(e)(i) of this Permit, the Permittee shall not bring to, place within, or allow anywhere in the Lab Pack Pour-Off Area: (I) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for oxidizers in lab packs containers; and (II) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for waste or other materials in Lab Packs 1 liter or less for liquids or 2.85 kilograms or less for solids. (f) The Permittee shall not bring to, place within, process, store, stage, treat, mix, dispose of, or otherwise manage any waste or other material in any MPA that is not specifically authorized in this section of the Permit. (7) TRUCK-TO-TRUCK TRANSFER AREA (TTTA), INCLUDING LOADING/UNLOADING DOCK (CONTAINERS) (a) Authorized Activity. (i) The Truck-to-Truck Transfer Area ("TTTA") comprises of five (5) truck bays, each 56 feet long by 12 feet wide and a raised concrete Loading/Unloading Dock, 13 feet wide by 73.6 feet long. The TTTA, including the Truck Bays and Loading/Unloading Dock, is shown on the WMASP and a drawing last modified on December 17, 2018, titled "Clean Harbors of Connecticut, Inc., Truck-toTruck Transfer Area." Drawing No. 62WC-7100-212. The Permittee shall not use any other area of the Facility as part of the Truck-to-Truck Transfer Area or for the activities authorized in this section of the Permit. (ii) In the TTTA the Permittee is authorized to: (I) Load containers of waste from the Facility into NEICVP1493E01 Appendix A Page 66 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) (i) Transportation Vehicles for off-site shipment; (II) Unload containers of waste or other materials from Transportation Vehicles for receipt at the Facility; (III) Transfer containers of waste from one Transportation Vehicle to another Transportation Vehicle; and (IV) Temporarily stage containers of waste or other materials on the Loading Dock, for no more than twelve (12) consecutive hours, while performing the activities authorized under sections II(A)(7)(a)(ii)(I)-(III), inclusive, of this Permit. The Permittee shall ensure that no waste or other materials remains in the TTTA for a total of more than seventy-two (72) consecutive hours. In calculating this seventy-two (72) consecutive hour limit all of the following time shall be included: (I) The time a Transportation Vehicle carrying containerized waste or other material as authorized by Section II (A)(7) of this Permit, is anywhere at the Facility prior to arriving at the TTTA Loading/Unloading Dock for container transfer to another vehicle while in Transit to another Facility during a 72- consecutive- hour period in the Truck Bays permitted for such activity in the TTTA; (II) The time a container of waste or other materials remains on a Transportation Vehicle in the TTTA, even if waste is moved from one Transportation Vehicle to another; (III) The time a container remains in a vehicle at the Loading/Unloading Dock of the TTTA and the time a container remains on the Loading/Unloading Dock of the TTTA; (IV) The consecutive hours a containerized waste or other material is managed at the Facility outside of normal working hours, notwithstanding whether any such hours occur on Saturday, Sunday, a Federal Holiday, or a State Holiday; and (V) The consecutive hours a containerized waste or other material is present at an adjacent or abutting property utilized and/or controlled by the Permittee, prior to entering the Permitted Facility and/or after leaving the Permitted Facility. (ii) The Permittee shall ensure that no waste or other materials remains on the Loading Dock within the TTTA for more than twelve (12) consecutive hours. This includes waste or other materials offloaded from a Transportation Vehicle or waste brought to the Loading Dock from a Container Storage Area or Area to Stage NEICVP1493E01 Appendix A Page 67 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Containers. (c) The Permittee shall ensure that no waste or other materials is placed or stored in the Truck Bay except for containers on a Transportation Vehicle. The Permittee shall also ensure that at no time is there more than one Transportation Vehicle in any Truck Bay and no more than five (5) Transportation Vehicles at all of the Truck Bays combined. (d) The Permittee shall not bring to, place within, process, store, treat, mix, dispose of, or otherwise manage waste or other material in the TTTA in any way that is not authorized in this section of the Permit. (e) Permitted Capacity. The Permittee shall ensure that at no time does the total volume of waste or other materials exceed the following: (i) On the Loading Dock Area - 5,060 gallons; (ii) In any single Truck Bay - 5,060 gallons; and (iii) In all of the Truck Bays combined - 25,300 gallons. For purposes of determining compliance with the permitted capacity of the Loading Dock and Truck Bays at the TTTA, each container on the Loading Dock or in a Truck Bay shall be assumed to be full. (f) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials are permitted in the Truck-to-Truck Transfer Area: (i) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, NEICVP1493E01 Appendix A Page 68 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U024, U042, U062, U080, U093, U111, U142, U158, U175, U187, U205, U221, U243, U372, U005, U026, U047, U063, U081, U094, U114, U143, U163, U176, U191, U206, U222, U244, U373, U006, U027, U048, U064, U082, U095, U116, U145, U164, U177, U192, U207, U223, U247, U387, U010, U028, U049, U066, U085, U097, U119, U148, U166, U178, U193, U210, U225, U248, U389, U011, U030, U050, U067, U086, U101, U120, U149, U167, U179, U197, U213, U226, U271, U394, U014, U034, U051, U068, U087, U102, U122, U150, U168, U180, U200, U214, U227, U278, U395, U015, U035, U058, U071, U088, U105, U126, U151, U170, U181, U201, U215, U235, U279, U409, U016, U036, U059, U073, U089, U106, U129, U152, U172, U183, U202, U217, U236, U280, U410, U018, U038, U060, U074, U090, U107, U137, U155, U173, U185, U203, U218, U237, U364, U411; U021, U039, U061, U079, U091, U109, U141, U157, U174, U186, U204, U219, U238, U367, (ii) CR01, CR02, CR03, CR04 and CR05 wastes. (iii) Universal wastes; (iv) Used oil; (v) Crushed metal drums and scrap metal appliances and any other waste or other material that the Commissioner has approved, in writing, for management at the Facility as a scrap metal; (vi) Other materials; (vii) Biomedical waste; (viii) PaintCare Program Waste; (ix) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(2) or 40 CFR 261.23(a)(4), provided: (I) The waste is in lab packs only and not in any other container; and (II) The combined capacity of the containers in which any such waste is placed in the Truck-to-Truck Transfer Area and the Truck Parking Areas does not exceed 165 gallons. In Appendix A Page 69 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 calculating compliance with this provision all containers with such waste shall be assumed to be full; (x) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(5); (xi) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6) and that does not contain hydrogen peroxide, provided, any such waste is in aerosol cans only with a capacity that does not exceed 32 ounces; (xii) Hazardous waste that is reactive for the reasons specified in 40 CFR 261.23(a)(6) and contains hydrogen peroxide, provided that if hydrogen peroxide: (I) Constitutes less than twenty (20%) percent of such waste, the waste is in containers no greater than fifty-five (55) gallons in size; (II) Constitutes between twenty (20%) to thirty (30%) percent of such waste: (A) The waste is in containers no greater than fifty-five (55) gallons; and (B) At all times when such waste is present at the Facility the containers holding such waste have a vented closure capable of preventing accumulation of internal pressure; and (III) Constitutes more than thirty (30%) percent, but less than or equal to sixty (60%) percent of such waste, the waste is only in lab pack containers; (xiii) Lab Pack Containers with expired or spent materials, unused product or materials, and laboratory wastes that are hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D above in Section II(A)(7)(f)(i) of this Permit and the following: K061 P011, P012, P024, P029, P042, P108, P120, P121 U002, U003, U007, U022, U031, U037, U056, U069, U072, U112, U128, U132, U136, U140, U144, U154, U161, U165, U169, U196, U208, U209, U211, U220, U239, U240; Appendix A Page 70 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (xiv) Asbestos-containing materials; and (xv) Waste or other materials containing PCBs. This includes any PCB Item. (g) Prohibited Wastes and Other Materials. The Permittee shall not bring to, place within, or allow in the Truck-to-Truck Transfer Area: (i) Any waste or other material not authorized under Section II (A) (7)(h) of this Permit; (ii) Any waste or other material specified in Section II (B) (1) of this Permit; (iii) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (iv) Poisonous Materials identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table, except for: (I) Waste or other materials in Lab Packs 1 liter or less for liquids or 2.85 kilograms or less for solids; and (II) Pesticides covered under 40 CFR 273.3(a); (8) TRUCK PARKING AREAS 1 AND 3: FOR UP TO 10-DAYS OR LESS (a) Authorized Activity. (i) The Truck Parking Area ("TPA") consists of four (4) adjacent concrete bays (referred to TPA Area #1), and one concrete bay (referred to as TPA Area #3) 56 feet in length and 12 feet wide. The location of the TPAs are shown on the WMASP and a drawing last modified on December 17, 2018, titled "Clean Harbors of Connecticut, Inc., 10-Day or Less Trailer Storage Area Truck Parking Area 1 & 3." Drawing No. 62WC-7100-211. The Permittee shall not use any other area of the Facility as part of the TPA. In addition, except as is specifically authorized by this Permit, the Permittee shall not use any other area of the Facility for the activities authorized in this section of the Permit. (ii) In the TPA the Permittee is authorized to temporarily store for up to, but no more than, 240 hours: (I) Waste or other materials in containers that remain on a NEICVP1493E01 Appendix A Page 71 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Transportation Vehicle; or (II) Waste or other materials in solid or semi-solid form only, (i.e., no liquids) in roll-off containers no greater than 40 cubic yards. For purposes of this Provision, "liquid" shall not include liquids that may have settled during transportation, provided that liquids that have settled during transportation shall be limited to liquids present in a separate distinct phase that do not occupy more than one inch in the roll-off container. (iii) Unless the integrity of a container or roll-off container is compromised, the Permittee shall not remove, add, handle, or manage any waste or other material in the TPA. (b) (i) The Permittee shall ensure that no waste or other materials remains in the TPA for a total of more than two-hundred and forty (240) consecutive hours. In calculating this two-hundred forty (240) consecutive hour limit all of the following time shall be included: (I) The time a Transportation Vehicle carrying containerized waste or other material, in accordance with Section II (A)(8) of this Permit, is anywhere at the Facility prior to arriving at the TTTA Loading/Unloading Dock for container transfer to another vehicle at the TTTA Bays permitted for such activity; (II) The time a container with wastes or other materials remains in the TPA; (III) The time a container of waste or other materials remains on a Transportation Vehicle in the TTTA, even if waste is moved from one Transportation Vehicle to another or a Transportation Vehicle with waste or other materials is brought to the Truck Parking Area and then returns to the TTTA; (IV) The time a container remains in a vehicle at the Loading/Unloading Dock of the TTTA and the time a container remains on the Loading/Unloading Dock of the TTTA; (V) The consecutive hours a containerized waste or other material is managed at the Facility outside of normal working hours, notwithstanding whether any such hours occur on Saturday, Sunday, a Federal Holiday, or a State Holiday; and NEICVP1493E01 Appendix A Page 72 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (VI) The consecutive hours a containerized waste or other material is present at an adjacent or abutting property utilized and/or controlled by the Permittee, prior to entering the Permitted Facility and/or after leaving the Permitted Facility. (c) The Permittee shall not bring to, place within, process, store, treat, mix, dispose of, or otherwise manage waste or other material in the TPA in any way that is not authorized in this section of the Permit. (d) Permitted Capacity. The Permittee shall ensure that at no time does the total volume of waste or other materials in any Truck Bay at the TPA exceed 5,060 gallons for waste on Transportation Vehicles or 40 cubic yards for waste in roll-off container(s). For purposes of determining compliance with the Permitted Capacity of the TPA, each container or roll-off shall be assumed to be full. (e) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited by this Permit, only the following wastes or other materials are permitted in the Truck Parking Area: (i) The following hazardous wastes identified by the waste codes in 40 CFR Part 261, Subparts C and D: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, NEICVP1493E01 Appendix A Page 73 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 U039, U061, U079, U091, U109, U141, U157, U174, U186, U204, U221, U243, U372, U042, U062, U080, U093, U111, U142, U158, U175, U187, U205, U222, U244, U373, U047, U063, U081, U094, U114, U143, U163, U176, U191, U206, U223, U247, U387, U048, U064, U082, U095, U116, U145, U164, U177, U192, U207, U225, U248, U389, U049, U066, U085, U097, U119, U148, U166, U178, U193, U210, U226, U271, U394, U050, U067, U086, U101, U120, U149, U167, U179, U197, U214, U227, U278, U395, U051, U068, U087, U102, U122, U150, U168, U180, U200, U215, U235, U279, U409, U058, U071, U088, U105, U126, U151, U170, U181, U201, U217, U236, U280, U410, U059, U073, U089, U106, U129, U152, U172, U183, U202, U218, U237, U364, U411; U060, U074, U090, U107, U137, U155, U173, U185, U203, U219, U238, U367, (ii) CR01, CR02, CR03, CR04 and CR05 wastes; (iii) Universal wastes; (iv) Used oil; (v) Crushed metal drums and scrap metal appliances and any other waste or other material that the Commissioner has approved, in writing, for management at the Facility as a scrap metal; (vi) Other Materials; (vii) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(2) or 40 CFR 261.23(a)(4), provided: (I) The waste is in lab packs only and not in any other container; and (II) The combined capacity of the containers in which any such waste is placed in the Truck-to-Truck Transfer Area and the Truck Parking Areas does not exceed 165 gallons. In calculating compliance with this provision all containers with such waste shall be assumed to be full; (viii) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(5); (ix) Hazardous waste that is reactive (D003) for the reasons specified in 40 CFR 261.23(a)(6) that does not contain hydrogen peroxide, provided, any such waste is in aerosol cans only with a capacity that does not exceed 32 ounces; (x) Hazardous waste that is reactive (D003) for the reasons specified Appendix A Page 74 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut in 40 CFR 261.23(a)(6) that contains hydrogen peroxide, provided that if hydrogen peroxide constitutes less than twenty (20%) per cent of such waste, the waste is in containers no greater than fiftyfive (55) gallons in size; (xi) Waste or other materials containing PCBs. This includes any PCB Item; and (xii) PaintCare Program Waste. (f) Prohibited Waste or Other Materials. The Permittee shall not bring to, place within, or allow in the TPA: (i) Any waste or other material not authorized under Section II(A)(8)(e) of this Permit; (ii) Any waste or other material specified in Section II(B)(1) of this Permit; (iii) All materials identified in 49 CFR 173.115(b), except for materials in aerosol cans 32 ounces or less; (iv) Flammable Liquids identified in 49 CFR 173.120 (Class 3) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (v) Flammable Solids identified in 49 CFR 173.124(a) (Class 4, Division 4.1) assigned Packaging Group I in column 5 of the 49 CFR 172.101 table; (vi) Oxidizers identified in 49 CFR 173.127 (Class 5 Division 5.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (vii) Poisonous Material identified in 49 CFR 173.132 (Class 6, Division 6.1) assigned Packing Group I in column 5 of the 49 CFR 172.101 table; (viii) Ammonium nitrate fertilizers; (ix) Sulfur, except for sulfur in a lab pack; and (x) Liquids, or waste or other materials that contain liquids, in roll-off containers. This prohibition, however, does not apply to liquids that may have settled during transportation, provided that liquids that have settled during transportation shall be limited to liquids present in a separate distinct phase that do not occupy more than one inch in a container or Transportation Vehicle. NEICVP1493E01 Appendix A Page 75 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (B) GENERAL PROHIBITIONS (1) General Prohibitions. The Permittee shall not allow any of the following wastes or other materials to be brought to, processed, stored, staged, or managed anywhere within the Facility, including all Waste Management Areas: (a) Explosives identified in 49 CFR 173.50 (Class 1) and Forbidden Explosives identified in 49 CFR 173.54; (b) All materials identified in 49 CFR 173.115 (Class 2, Divisions 2.1, 2.2 and 2.3), except for: (i) Materials identified in 49 CFR 173.115(a), (d), (e), and (f) in aerosol cans 32 ounces or less; (ii) Refrigerant gas or dispersant gas, identified in 49 CFR 173.115(j), that is (I) In aerosol cans 32 ounces or less; or (II) Is removed from scrap metal appliances brought to the Facility; and (iii) Materials identified in 49 CFR 173.115(b); (c) Materials identified in 49 CFR 173.21, Forbidden Materials and Packages; (d) "Material poisonous by inhalation or Material toxic by inhalation" as defined in 49 CFR 171.8; (e) Biomedical waste in a putrescent state or any substance that is required by any federal, state, or other governmental entity, including through guidelines, to be maintained at a specified temperature (i.e., requires temperature control) or pressure; (f) Any hazardous wastes with a health hazard rating of 4, as defined in NFPA 704, Degree of Hazard Criteria, most recent edition; (g) Reactive hazardous wastes specified in 40 CFR 261.23(a)(1), 261.23(a)(3), 261.23(a)(7), and 261.23(a)(8); (h) Shock sensitive materials, defined as materials that are readily capable of detonation or explosive decomposition or reaction at normal temperatures and pressures, and materials sensitive to mechanical or localized thermal shock at normal temperatures and pressures, including materials designated by the NFPA 704 as having a reactivity hazard rating of 4; NEICVP1493E01 Appendix A Page 76 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (i) Spontaneously Combustible Materials identified in 49 CFR 173.124(b) (Class 4, Division 4.2), except for lab pack containers assigned Packaging Group II or III in column 5 of the 49 CFR 172.101 table; (j) Dangerous when wet materials identified in 49 CFR 173.124(c) (Class 4, Division 4.3), except for lab pack containers assigned Packaging Group II or III in column 5 of the 49 CFR 172.101 table; (k) Gaseous oxidizers, as defined in NFPA 55; (l) Radioactive materials defined in 49 CFR 173.403 (DOT Class 7); (m) Reactive hazardous waste specified in 40 CFR 261.23(a)(6) if hydrogen peroxide constitutes greater than sixty (60) per cent of such waste; and (n) Prohibited Materials identified in 49 CFR 173.12(b)(3). (2) Exception to General Prohibitions: The General Prohibitions in Section II(B)(1) of this Permit do not apply to the products or materials used by the Permittee in its laboratory or for maintenance at its property, provided such products or materials are present in quantities no greater than that necessary for use by the Permittee. Examples of such products and quantities are shown on Table II-2, in Section II of this Permit. NEICVP1493E01 Appendix A Page 77 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE II-1 -WASTE MANAGEMENT AREAS SELECTED INFORMATION Waste Management Areas Dimensions (1) Container Storage Areas Area A 20.2 ft. by 24.1 ft. Area B#1 (rows 1 through 7) Area B#2 (rows 8 through 10) B#1 is 43.75 ft. by 25 ft. B#2 is 16.25 ft. by 25 ft. Area C - Within the Bulk Unloading and Loading Area Area D 4.2 ft. by 23.3 ft. 6 ft. by 24.9 ft. Area E 18 ft. by 21.4 ft. Area F 12 ft. by 24.1 ft. Area G 12 ft. by 24.1 ft. Area J 26 ft. by 34 ft. Area K Area L 60 ft. long by 2.6 ft. wide by 2 ft. deep 5.5 ft. wide by 16 ft. (2) Bulk Unloading and Loading Area (BULA) Secondary Containment Capacity Permitted Capacity Permitted Waste 350 gallons 1,848 gallons 2,750 gallons B#1 -18,480 gallons (wastes that are not solid) Section II(A)(1)(f)(ii) Section II(A)(1)(d) 350 gallons 350 gallons 660 gallons 350 gallons 350 gallons 0 gallons (solid wastes only) 539 gallons 350 gallons B#2 - 18 pallets or 42 cubic yards (Solids Only) 2,310 gallons 2,640 gallons 6,600 gallons 2,750 gallons 2,970 gallons 40 cubic yards Section II(A)(1)(d) Section II(A)(1)(d)(ii) Section II(A)(1)(d) Section II(A)(1)(d) Section II(A)(1)(d) Section II(A)(1)(d) Section II(A)(1)(d) 5,390 gallons 990 gallons Section II(A)(1)(d) Section II(A)(1)(d) Loading and Unloading Area 55 feet by 11.25 feet 6,600 gallons (2 Tanker Truck Maximum) (3) Areas to Stage Containers (UP TO 5 DAYS) 13,200 gallons Section II(A)(2)(d) Area M1 Area M2 Area H (9 areas) 25 f long by 13 ft. wide x 1 ft. deep 25 ft. long by 13 ft. wide x 1 ft. deep 2 areas, H1 and H2 - 25.3 feet x 5.625 feet 2 areas, H3 and H4 - 20.625 feet x 5.625 feet 2 areas, H5 and H6 - 9.375 feet x 5.625 feet 1 area, Area H7 - 14 feet x 5.625 feet 1 area, H8 - 14 feet x 5.625 feet 1 area, H9 - 30 feet x 682 gallons 495 gallons Self-containment pallets that satisfy 40 CFR 264.175(b)(3) 6,820 gallons 4,950 gallons Areas H1 and H2 - 1320 gallons in each area; Areas H3 and H4 - 1100 gallons in each area; Areas H5 and H6 - 440 gallons in each area; Area H7 - 660 Section II(A)(3)(d)(i) Section II(A)(3)(d)(ii) Section II(A)(3)(d)(iii) NEICVP1493E01 Appendix A Page 78 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 5.625 feet gallons; Area H8 - 880 gallons; Area H9 - 1,540 gallons 8,800 gallons (All Areas H combined) (4) Tank Systems 11 and 14 Tank 11 Tank 14 9 feet in diameter by 8 feet in height Not Specified 29,539 gallons (5) Mix-Tub, Bulk Storage and Transfer Area (MBSTA) 30.5 ft. wide by 122.5 ft. long 4,116 gallons Section II(A)(4)(c) 10,836 gallons Section II(A)(4)(c) Mix-Tub (itself) Mix-Tub, Bulk Storage and Transfer Area (6) Miscellaneous Processing Areas Drum Crusher Station Drum Rinse Station Lab Pack Pour-Off Area 18,829 gallons 27 cubic yards Section II (A)(5)(b)(ii) Section II(A)(5)(c)(ii) to (iv) Section II(A)(5)(c)(i) and II(A)(5)(c)(v) No waste, except for containers to be crushed No waste, except for containers to be rinsed 4 liters (liquid in glass containers); 20 liters (liquid in metal or plastic containers) and/or 14.5 kilograms (solids) Empty 55-gallon metal containers Empty Containers Section II(A)(6)(d)(iv) (7) Truck-to-Truck Transfer Area Loading/Unloading Dock 5 Truck Bays 56 ft. long x 12 ft. wide Each bay is 56 ft. long 12 ft. wide 549 gallons, capacity in Truck Bay #3 549 gallons for Truck Bay 1, 2, 4, and 5, 1,100 gallons for Truck Bay 3 5,060 gallons 5,060 gallons per Truck Bay/25,300 gallons total) Section II(A)(7)(f) Section II(A)(7)(f) NEICVP1493E01 Appendix A Page 79 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (8) Truck Parking Areas Truck Parking Area 1 (5 truck bays) Truck Parking Area 3 (1 Truck Bay) Each bay is 56 ft. long by 12 ft. wide The bay is 56 ft. long by 12 ft. wide 549 gallons/ per Truck bay 549 gallons 40 cubic yards for waste in roll-off containers 5,060 gallons per Transportation Vehicle 40 cubic yards for waste in roll-off containers 5,060 gallons per Transportation Vehicle Section II(A)(8)(e) Section II(A)(8)(e) NEICVP1493E01 Appendix A Page 80 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE II-2 TYPICAL LABORATORY AND MAINTENANCE PRODUCTS/MATERIALS Product/Chemical Activated Charcoal Dexsil Kit (Sodium) Nitrogen Argon Argon P-5 (Argon/Methane) Helium Isotope 63 (Radioactive) Propane Propane Mixed Argon Oxygen Acetylene MAPP Gas Medical Oxygen Location Lab Lab Lab Lab Lab Lab Lab Lab Plant Propane Storage Maintenance Maintenance Maintenance Maintenance Various Quantity 1 kg 25 kits 7 - k bottles 3 - k bottles 2 - 600 lbs cryo tanks 2 - k bottles 2 - k bottles 2 units 5 - 30 lbs. cylinders 16 - 30 lbs. cylinders 2 - k bottles 2 - k bottles 4 - 50 lbs. cylinders 5 - 1 lbs. cylinders 10 cylinders Use decolorizing Cl- analysis ICP Gas ICP Gas ICP Gas GC Gas GC - MS GC ECD source Forklifts Forklifts Welding Welding/Cutting Welding/Cutting Plumbing First Aid NEICVP1493E01 Appendix A Page 81 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut RELEVANT DRAWINGS DRAWINGS Drawing No. 62WC-7100-201 Drawing No. 62WC-7100-202 Drawing No. 62WC-7100-203 Drawing No. 62WC-7100-204 Drawing No, 62WC-7100-205 Drawing No. 62WC-7100-206 Drawing No. 62WC-7100-207 Drawing No. 62WC-7100-208 Drawing No. 62WC-7100-211 Drawing No. 62WC-7100-212 Drawing No. 62WC-7100-214 Drawing No. 62WC-7100-215 TITLE Permitted Storage Area C (In the BULA Area) Operations Building-Permitted Staging Area H Operations Building-Permitted Storage Area L Waste Management Areas-Site Plan (WMASP) Container Storage Building- Permitted Storage Areas - A, B, D, E, F, G and J Operations Building-Permitted Storage Area K Operations Building-Permitted Staging Area M1 Operations Building-Permitted Staging Area M2 Truck Parking Areas 1 and 3 - 10-Days or Less Truck-To-Truck Transfer Area (Loading/Unloading Operations Building-Permitted Storage Tank 11 Operations Building-Permitted Storage Tank 14 Dock) NEICVP1493E01 Appendix A Page 82 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 83 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 84 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 85 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 86 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 87 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 88 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 89 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 90 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 91 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 92 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 93 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 94 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX II-1 EPA PCB Commercial Storage Exemption Letter dated December 11, 2018 NEICVP1493E01 Appendix A Page 95 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 96 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 97 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 98 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 99 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 100 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 101 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 102 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 103 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION III OPERATING CONDITIONS COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 104 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION III TABLE OF CONTENTS OPERATING CONDITIONS SECTION TITLE PAGE (A) Conditions Regarding the Facility and All Waste Management Areas . . . . . . III-3 (B) Specific Conditions Applicable to Containers, including Roll-Off Containers and Transportation Vehicles . . . III-21 (C) Requirements Regarding PaintCare Program Waste . . . III-23 (D) Specific Waste Management Area Operating Conditions . . III-26 (1) Container Storage Areas and Areas to Stage Containers . . III-26 (2) Bulk Unloading and Loading Areas (BULA) . . . III-30 (3) Tank Systems 11 and 14 . . . . . III-31 (4) Mix-Tub, Bulk Storage and Transfer Area (MBSTA) . III-35 (5) Miscellaneous Processing Areas . . . . III-41 (6) Truck-to-Truck Transfer Area . . . . III-43 (7) Truck Parking Areas 1 and 3 . . . . . III-45 APPENDIXES APPENDIX III-A APPENDIX III-B APPENDIC III-C Additional Items to be Included in The Third-Party Audits . . . . . III-47 Decontamination Procedures . . . . III-49 Example of a Tank Cleaning Certificate . . . III-51 NEICVP1493E01 Appendix A Page 105 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION III OPERATING CONDITIONS (A) CONDITIONS REGARDING THE FACILITY AND ALL WASTE MANAGEMENT AREAS In addition to any other requirements of this Permit, the Permittee shall comply with the following requirements regarding the Facility, including the Waste Management Areas at the Facility: General Conditions (1) The Permittee shall: (a) Operate the Facility so as to prevent any waste or other material from potentially causing or resulting in a hazard to human health or the environment (e.g., fires, explosions, toxic fumes); (b) Ensure that all waste or other materials in the Waste Management Areas is secure and remains inaccessible to unauthorized persons; and (c) Prevent unknowing entry or entry by unauthorized persons at the Facility; and (d) Ensure that at all times there is a single point of contact from the Facility who: (i) Is aware of the waste or other materials at the Facility, including, but not limited to, the hazards posed by such waste or other materials; and (ii) Can authorize response actions in the event of a release or emergency condition at the Facility. (2) The Permittee shall, at all times, provide a safe working environment for employees at the Facility. At a minimum, the Permittee shall ensure that: (a) There is adequate ventilation in each Waste Management Area; and (b) Whenever Facility personnel may be potentially exposed to wastes or other materials, appropriate personal protective equipment is utilized, as specified by, but not be limited to, the Safety Data Sheets (SDSs, formerly known as MSDSs), or by the National Institute for Occupational Safety and Health (NIOSH). (3) The Permittee shall not transport, load, unload, transfer, treat, manage, or handle any waste or other materials, within, over or on any area of the Facility that has bare soil or unprotected surfaces. In addition, the Permittee shall maintain all traveled surfaces at the Facility in good repair so that such surfaces can withstand the mechanical stress of traffic to which they are subjected and prevent damage to containers and spillage of waste or other materials during the use of such surfaces. For purposes of this provision, asphalt shall not be considered an "unprotected surface." NEICVP1493E01 Appendix A Page 106 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (4) The Permittee shall transport containers of waste at the Facility using forklifts, hand trucks and/or other equipment capable of transporting such containers. (5) The Permittee shall ensure that no waste placed in or brought to the Truck Parking Area is then placed in or brought to any other Waste Management Area at the Facility, other than the Truck-to-Truck Transfer Area. This provision includes, but is not limited to, a roll-off container or a Transportation Vehicle. (6) Except as provided for in this provision, the Permittee shall ensure that no waste brought to, placed in or from the Mix-Tub, Bulk Storage and Transfer Area, Container Storage Area, Tanks Systems 11 or 14, Bulk Unloading and Loading Area, or Area to Stage Containers is then brought to or placed in the Truck Parking Area. This provision includes, but is not limited to, waste in a roll-off container or a Transportation Vehicle, except that a roll-off container with waste from the Mix-Tub, Bulk Storage and Transfer Area, may be brought to the Truck Parking Area provided that any such roll-off container: (a) Does not contain waste that under this Permit is prohibited in the Truck Parking Area; (b) The storage time that is brought to or placed in the Truck Parking Area in the normal course of transportation (i.e., for shipment off-site, not temporary storage) that shall not exceed twenty-four (24) hours; (c) After being brought to or placed in a Truck Parking Area, the waste shall not be brought back to or placed in any Waste Management Area at the Facility; and (d) Once brought to the Truck Parking Area, the waste remains subject to all the requirements regarding waste in the Truck Parking Area. (7) The Permittee shall prevent damage to containers of waste or other materials due to freezing or low temperatures and shall protect such waste or other materials from high temperature. (8) The Permittee shall ensure that all transporters that enter the facility comply with RCSA Section 22a-449(c)-11 and RCSA Section 22a-449(c)-103 with respect to the transportation of hazardous wastes. (9) The Permittee shall not manage waste or other material at the Facility in a manner that does or could: (a) Generate extreme heat or pressure, fire, explosion, or violent reaction; (b) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment; (c) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion; (d) Damage the structural integrity of the item used to contain such waste or other material; or (e) Through other like means, threaten human health or the environment. NEICVP1493E01 Appendix A Page 107 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Training (10) The Permittee shall ensure that all wastes or other materials at the Facility are handled or managed by personnel who have completed all of the required training specified in the Personnel Training Plan (PTA) presented herein as Attachment C to this Permit. The PTA requires approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit. (11) The Permittee shall ensure that the transfer of containers and roll-off containers of waste or other materials is performed by appropriately trained personnel, experienced in the use of such equipment and techniques, as specified in the Personnel Training Plan presented herein as Attachment C to this Permit. The PTA requires approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit Condition of Containers, Including Transportation Vehicles and Roll-Off Containers (12) If a container or a roll-off container holding waste or other materials is not in good condition (e.g., there is severe rusting, cracks, apparent structural defects or bulging) or begins to leak, the Permittee shall immediately place the compromised container in a salvage container that is in good condition and complies with 49 CFR Part 173, or transfer the waste or other material from such container or roll-off container to a container that is in good condition and complies with 40 CFR Part 173. The Permittee shall manage, including disposal, all waste generated from a container or roll-off container that is not in good condition in accordance with this Permit and all applicable requirements. (13) The Permittee shall ensure that no container or roll-off container of waste or other material has any superfluous waste, liquids, sludge, or solids on the exterior of such container. This does not include dried paint or similar material and dirt/dust. (14) The Permittee shall ensure that each container or roll-off container with waste or other materials at the Facility is made of or lined with materials that will not react with, and are compatible with the waste or other materials so as not to impair the ability of such container to contain such waste or other materials. The Permittee shall ensure that only containers or roll-off containers that have been approved by DOT for use with a given waste or other material are brought to or used at the Facility. Spills, Releases, and Accumulated Liquids (15) The Permittee shall operate the Facility in a manner that minimizes the possibility of spills or releases of waste or other materials. The Permittee shall manage and maintain all Waste Management Areas within the Facility to prevent run-on into such area and prevent spills, releases, or accumulated liquids, including, but not limited to, precipitation from escaping a Waste Management Area. (16) The Permittee shall remove all spilled or leaked waste or any liquids, including, but not limited to precipitation, that accumulates in any Waste Management Area or containment area, including any secondary containment area. The Permittee shall remove such waste or liquid immediately upon detection, but in no event NEICVP1493E01 Appendix A Page 108 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut later than twenty-four (24) consecutive hours from the time, such waste or liquid should have been discovered. The Permittee shall ensure that any such spillage, leakage or liquid remains within the secondary containment area of a Waste Management Area. Notwithstanding the foregoing, if on a Saturday, Sunday or a federal holiday observed by Clean Harbors and the Facility is closed, except for the potential receipt of waste or other materials from an emergency, if precipitation accumulates in a Waste Management Area, including a secondary containment area, provided all precipitation remains within the secondary containment area, the Permittee shall have until the end of the next business day when the Facility is open to remove such precipitation. All collected material from these events must be sampled and analyzed for proper disposal pursuant to Section III(A)(17) of this Permit. (17) The Permittee shall manage all spilled or leaked waste or any liquid, including, but not limited to, precipitation removed from a Waste Management Area as a hazardous waste, unless the Permittee demonstrates that such waste or liquid is not a hazardous waste pursuant to 40 CFR 262.11. If not required to be managed as a hazardous waste, the Permittee shall manage all such waste or liquid in accordance with this Permit and all applicable requirements. (18) (a) The Permittee shall immediately notify the Commissioner using CT DEEP's Emergency Response & Spill Prevention Division (ERSPD) 24hour telephone number 860-424-3338 or, if that number is unavailable, at 860-424-3333, or toll free at 1-866-337-7745, of: (i) Any spill or release at the Facility, including, but not limited to, a leak from any container whose integrity has been compromised; or (ii) Any evacuation of the Facility for any purpose. (b) The Permittee shall immediately notify the Director of the Waste Engineering and Enforcement Division ("WEED") by email at DEEP.WEEDNotification@ct.gov of: (i) Any partial shutdown of the Facility that substantially disrupts normal operations for more than twenty-four hours; (ii) Any inability, for any period of time, to receive waste at the Facility; or (iii) Any significant threat to human health or the environment. (c) In addition to the provisions of Section III(A)(18)(a) of this Permit, the Permittee shall comply with all other applicable reporting or notification requirements regarding any spill or release at the Facility, including but not limited to, requirements under section 22a-450 of the CGS and 40 CFR Part 302. (19) (a) In addition to any other information that may be required by the ERSPD, within fifteen (15) calendar days of a spill or release at the Facility, the Permittee shall submit a written report containing the following information to the Director of WEED: NEICVP1493E01 Appendix A Page 109 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (i) Likely route of migration of the spill or release; (ii) Characteristics of the surrounding soil (soil composition, geology, hydrogeology, etc.); (iii) Results of any monitoring or sampling conducted in connection with the spill or release (if available). If sampling or monitoring data relating to the spill or release are not available within fifteen (15) calendar days, such data shall be submitted to ERSPD and WEED as soon as they become available; (iv) Proximity to down gradient drinking water wells, surface water, populated areas, wetlands or other environmentally sensitive areas, and habitat for endangered or threatened species; and (v) Description of all response actions taken or planned. (b) The Permittee shall maintain copies of all reports required under Section III(A)(19)(a) of this Permit and all subsequent reports filed with the Department regarding each such incident in the Operating Record until Final Closure of the Facility. Inspections (20) The Permittee shall inspect the Facility, each Waste Management Area and all safety equipment, emergency response equipment, security devices and operating and structural equipment to prevent releases and to ensure such equipment remains in good working order, the safe operation of the Facility and compliance with this Permit. At a minimum, the Permittee shall perform inspections in accordance with the Inspection Plan (IP) presented herein as Attachment B to this Permit. The IP requires approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit. The Permittee shall respond as soon as possible to any problem or deficiency identified by any such inspection. (21) The Permittee shall record inspections of each Waste Management Area in an inspection log. This log shall include the date and time of the inspection, the name of the inspector, company affiliation if by a company other than Clean Harbors, a notation of the observations made, and the date and nature of any repairs or required actions. The inspection log shall be maintained in the Operating Record for the Facility. Traffic Control and Vehicles Idling (22) The Permittee shall control all traffic related to the operation of the Facility in such a way as to mitigate the queuing of vehicles and prevent excessive or unsafe traffic impacts in the area where the Facility is located. (23) The Permittee shall prominently post and maintain signs in appropriate areas warning that trucks at the Facility cannot idle for more than three (3) consecutives minutes, pursuant to RCSA Section 22a-174-18(b)(3). NEICVP1493E01 Appendix A Page 110 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Signage (24) The Permittee shall post a sign with the legend, "Danger--Unauthorized Personnel Keep Out", at each entrance to the Facility, and at other locations, in sufficient numbers to be seen from any approach to the Facility. The legend must be written in English and in any other language predominant in the area surrounding the Facility and shall be legible from a distance of at least 25 feet. The Permittee may use signs with a legend other than "Danger--Unauthorized Personnel Keep Out" to comply with this provision, provided such posting otherwise meets the requirements of this provision and the legend on the sign clearly indicates that only authorized personnel are allowed to enter onto the Facility property and that entry onto the Facility property can be dangerous. Secondary Containment Requirements (25) The Permittee shall ensure that: (a) Each Waste Management Area has a secondary containment system that is capable of: (i) Containing any spills, leaks, precipitation, or other liquids; (ii) Preventing run-on into and run-off out of such system; and (iii) Ensuring that any waste or other materials in such Waste Management Area does not come in contact with any liquids, from spills, leaks, precipitation or otherwise, collected in the secondary containment system; (b) The following secondary containment systems are capable of containing the following amounts (The required secondary containment capacities are also specified in Table II-1 of this Permit): (i) Container Storage Areas: Area Area Area Area Area Area Area Area Area Area A - 350 gallons B - 1,848 gallons C - 350 gallons D - 350 gallons E - 660 gallons F - 350 gallons G - 350 gallons J - Solid waste only K - 539 gallons L - 350 gallons; (ii) Bulk Unloading and Loading Area - 6,600 gallons; (iii) Areas to Stage Containers: Area M1 - 682 gallons Area M2 - 495 gallons; NEICVP1493E01 Appendix A Page 111 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Area H - self-containment pallets that can contain 10% of the volume of all containers on a pallet or 100% of the largest container, whichever is greater; (iv) Tanks Systems: Tank 11 - 29,539 gallons Tank 14 - 29,539 gallons; (v) Mix-Tub, Bulk Stage and Transfer Area - 18,829 gallons; (vi) Truck-to-Truck Transfer Area: Loading Dock - 549 gallons Each Truck Bay- 549 gallons, except for Truck Bay #3 - 1,110 gallons (vii) Truck Parking Areas No. 1 and 3: Truck Parking Area #1, Each Truck Bay - 549 gallons plus the calculation for a 25-year, 24-hour storm event. Truck Parking Area #3 - 549 gallons plus the calculation for a 25-year, 24-hour storm event. (c) For purposes of determining compliance with Section III(A)(25)(b) of this Permit, the Permittee shall include any device or structure within a Waste Management Area that displaces the secondary containment volume capacity of such area. (26) The Permittee shall ensure that the strength of the secondary containment system in any Waste Management Area is sufficient to prevent failure owing to pressure gradients, physical contact with the waste, climatic conditions, and the stress of the Facility operation. (27) The Permittee shall ensure that whenever a container, roll-container, Transportation Vehicle, including a Vacuum Truck, with waste or other materials is in or is being managed in a Waste Management Area, that the entire container, roll-off container, or vehicle is wholly within the secondary containment area for such Waste Management Area. This includes, but is not limited to, waste being emptied into the Mix-Tub or stored in the Mix-Tub Bulk Storage and Transfer Area. (28) The Permittee shall ensure that at closure of any Waste Management Area, all waste and waste residues are removed from the secondary containment system of such area. In addition, the Permittee shall ensure that any areas of the base, liners, and/or soil containing or contaminated with waste or waste residues are decontaminated or removed and that the Permittee complies with the Closure Plan presented herein as Attachment E of this Permit. The Closure Plan requires approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit NEICVP1493E01 Appendix A Page 112 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Base and Berm Requirements for Secondary Containment Systems (29) The Permittee shall ensure that the base and berm of the secondary containment in each Waste Management Area is free of cracks or gaps and is sealed with a chemical resistant, impermeable coating compatible with all waste or other material in such a Waste Management Area such that the secondary containment system will contain leaks, spills or other liquids, including, but not limited to, precipitation. At a minimum: (a) The application of a chemical resistant impermeable coating shall be in conformance with the manufacturer's specifications. Prior to applying the coating, the Permittee shall inspect the Waste Management Area. If visible residue or any other material that could affect the performance of the coating is found, the residue and material shall be removed in accordance with Section III (A)(30) of this Permit; and (b) When there are gaps or cracks in a secondary containment system or a Waste Management Area's coating is in need of repair or application, the Permittee shall follow the procedures in Section III (A)(30), (A)(31), (A)(32) and (A)(33) of this Permit. (30) Whenever the integrity of a Waste Management Area's base, berm or coating specified in Section III (A) (29) of this Permit is impaired or in need of repair or reapplication, the Permittee shall: (a) Remove all waste and other materials from the Waste Management Area or affected portion thereof, as necessary; (b) Inspect the area for the presence of visible residue (stains, debris, and wetness) and if visible residue is found, remove the residue by scrubbing, and washing, and/or scarifying, as necessary. When removing residue, the Permittee shall only use materials that are standard in the industry for such purpose. The removed residue shall be samples and analyzed for disposal; (c) Determine the nature and extent of the impairment; (d) Repair the affected area, or repair and/or reapply the coating of the affected area as soon as possible, but not later than thirty (30) calendar days after the Permittee discovers that the integrity of the area or of the coating has been impaired or is in need of repair, except that if repairs to a Waste Management Area located outdoors cannot be completed in thirty (30) calendar days, the Permittee shall provide "alternate" secondary containment (e.g., containment pallets or a temporary liner such as a catch basin mat) for all waste or other materials in the affected area until the necessary repairs have been completed. A record of this alternate secondary containment measure, the extent of impairment noted and the reason for and length of delay in re-application of coating shall be made and maintained in the Operating Record until Final Closure of the Facility. NEICVP1493E01 Appendix A Page 113 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (31) The Permittee shall not use or place waste or other materials in a Waste Management Area, or any portion thereof, in which the integrity of the secondary containment is impaired or under repair. If only a portion of the secondary containment in a Waste Management Area is impaired or in need of repair or coating reapplication, the Permittee may continue to use other portions of the same Waste Management Area provided that: (a) The secondary containment in these other portions is not impaired, on in need of repair or coating reapplication; and (b) Before the Permittee uses any portion of the Waste Management Area, the Permittee shall take all the necessary measures to ensure that waste or other material does not or cannot migrate to any portion of the Waste Management Area where the secondary containment is impaired, or is in need of repair or coating reapplication. (32) When the integrity of the secondary containment system of a Waste Management Area is impaired or has been repaired or coating reapplied, the Permittee shall record in the Operating Record for the Facility the following information, to be kept until Final Closure of the Facility: (a) The location of the Waste Management Area requiring repair or coating reapplication; (b) The type and degree of repair or coating reapplication needed; (c) The method(s) of repair or reapplication; (d) The date the need for the repair or coating reapplication was noticed; (e) The date(s) all repair(s) were made or coating(s) reapplied; and (f) The name, title and identity of the person who determined that the repair or coating reapplication was sufficient to allow the Waste Management Area or portion thereof to be used again and the date of such inspection and any comments of the inspector regarding the repair or coating reapplication. (33) Before resuming use of a Waste Management Area requiring repair or reapplication of a coating, the Permittee shall ensure that the area is free of cracks or gaps and the area's coating is sufficiently impervious to contain leaks and/or spills, including inspection of the berm and base of the Waste Management Area to ensure the integrity of the coating Provisions Regarding Wastes or Other Materials that are Prohibited at the Facility (34) Prior to bringing, placing or allowing any wastes or other materials into the Facility, the Permittee shall determine that such waste or other materials is authorized to be brought to the Facility and can be properly managed in accordance with the terms and conditions of this Permit. The information used to comply with this provision shall be maintained in the Operating Record for the Facility until final closure of the Facility. NEICVP1493E01 Appendix A Page 114 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut At a minimum, the Permittee shall: (a) Determine whether each waste or other material is prohibited by Section II or any other provision of this Permit; (b) Determine the applicable degree of hazard as defined in the Waste Analysis Plan (WAP), presented herein as Attachment A to this Permit (The WAP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit) for each waste or other material; (c) Characterize each waste or other material in accordance with the parameters specified in the WAP, presented herein as Attachment A to this Permit (The WAP requires approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit). In addition to any requirements in such Waste Analysis Plan, for each hazardous waste identified with the EPA hazardous waste code D003, reactive wastes, the Permittee shall determine under what provision of 40 CFR 261.23 (i.e., 40 CFR 261.23 (a)(1) or 261.23(a)(2), etc.) the waste is considered reactive and the basis for the Permittee's determination, and shall maintain in the Operating Record of the Facility the basis for its determination, including but not limited to any waste profile sheets, sampling or other data upon which the Permittee's determination under this provision regarding such waste was made; and (d) Determine that the Contingency Plan will adequately address all potential hazards posed by each waste or other material, specifically the suitability and compatibility of the waste or other material with personal protective equipment ("PPE") (e.g., boots, gloves, suits), availability of appropriate respiratory protection and emergency response equipment, monitoring equipment (e.g., explosion detection equipment, vapor analyzers, dragger tubes) and other relevant equipment at the Facility, including necessary response procedures by, at a minimum, identifying the PPE required to properly handle the waste or other material, and identifying the appropriate response procedures for handling incidents involving the waste or other material. (35) The Permittee shall not allow any waste or other material that is prohibited under Section II of this Permit to enter or be accepted at the Facility; (36) (a) When waste or other materials first arrives at the entry gate to the Facility the Permittee shall: (i) Review all manifests or other shipping papers to determine if the waste or other material is prohibited under Section II of this Permit from being accepted at the Facility; and (ii) Record and retain in the Operating Record for the Facility the date and time, such waste or other material arrived at the Facility. NEICVP1493E01 Appendix A Page 115 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) (37) (a) (b) (c) NEICVP1493E01 The time when waste or other material first arrives at the Facility shall be used to determine compliance with the six (6) consecutive hour limit in Section III(A)(39)(a) of this Permit, the seventy-two (72) consecutive hour limit in the Truck-to-Truck Transfer Area, the two-hundred-forty (240) consecutive hours limit in the Truck Parking Area, and the thirty (30) calendar days limit for storage in the Mix-Tub, Bulk Storage and Transfer Area, and any other similar timeframe required under this Permit, unless another timeframe is specified in this Permit. If a container of waste or other materials, not apparent on the manifest or shipping paper (i.e., an extra container not on a manifest is on a Transportation Vehicle), is received at the Truck-to-Truck Transfer Area or in a lab pack container brought to Staging Area H, the Permittee shall: (i) Place such waste or other material in a separate Staging Area H on a containment pallet. The Permittee shall not place any other waste or other material in such staging area until the waste or other material in question has been identified. The Permittee shall record in the Operating Record for the Facility the date and staging area into which such waste or other material was placed; and (ii) Have five (5) calendar days from the date of discovery of any such waste or other material to determine the identification of such waste or other material and whether or not it can be managed at the Facility. If the Permittee is able to identify the waste or other material specified in Section II (A) (37) (a) of this Permit and determines that such waste or other material: (i) Can be managed at the Facility in accordance with the terms and conditions of this Permit, the Permittee shall so manage the waste or other material and shall also retain in the Operating Record of the Facility documentation that identifies the waste or other material in question, where and when it was discovered at the Facility, who generated the waste or other material, and how a determination of the identification of such waste or other material was made; or (ii) Cannot be managed at the Facility, the provisions of Section III (A) (38) of this Permit shall apply to such waste or other material. If the Permittee is not able to identify the waste or other material specified in Section II (A) (37) (a) of this Permit, the Permittee shall analyze the waste to determine the constituents of such waste. If based on such analysis the Permittee determine that the waste or other material: (i) can be managed at the Facility in accordance with the terms and conditions of this Permit, the Permittee may so manage such waste or other material and shall also retain in the Operating Record of the Facility documentation that identifies the waste or Appendix A Page 116 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut other material in question, where and when it was discovered at the Facility, and the results of the analysis used to identify the waste or other material; and (ii) cannot be managed at the Facility, the provisions of Section III (A) (38) of this Permit shall apply to such waste or other material. (38) If a review of manifests or other shipping papers for a waste or other material does not reveal that such waste or other material is prohibited under Section II of this Permit and such waste or other material inadvertently enters the Facility or is brought to a Waste Management Area: (a) Immediately after the Permittee determines or reasonably should have determined that such waste or other material is prohibited from the Facility or from a Waste Management Area by this Permit, the Permittee shall: (i) comply with all applicable requirements, including, but not limited to, the compatibility requirements in 40 CFR Part 264, Appendix V; and (ii) place such waste or other material in an area with secondary containment and ensure that such waste remains in an area with secondary containment until such waste is removed from the Facility; and (b) No later than twenty-four (24) hours after the Permittee determines or reasonably should have determined that a waste or other material is prohibited under Section II of this Permit, the Permittee shall remove such waste from the Facility. The Permittee may, for good-cause, request, in writing, that the Commissioner extend this twenty-four (24) hour period. If at the expiration of this 24 hour period, pursuant to 3-6a of the CGS, the Governor has declared an emergency prohibiting the use of the roads, the Permittee shall remove such prohibited waste or other material from the Facility no later than two (2) consecutive hours after the Governor declares that the emergency is over and use of the roads is Permitted. The Permittee shall comply with all applicable requirements regarding any waste or other material that is prohibited under Section II of this Permit and removed from the Facility pursuant to this provision. Termination of Manifest or Shipping Paper (39) The Facility shall be the Designated Facility on the manifest or similar shipping paper, terminating any such manifest or similar shipping paper, for all waste or other materials brought to any Container Storage Area, any Area to Stage Containers, the Bulk Unloading and Loading Area, and the Mix-Tub, Bulk Storage and Transfer Area, i.e., any waste or other material that does not remain solely within the Truck-to-Truck Transfer Area or the Truck Parking Area. General Tracking of Waste or Other Materials at the Facility (40) In addition to any other recordkeeping requirements of this Permit, the Permittee NEICVP1493E01 Appendix A Page 117 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut shall record and maintain in the Operating Record of the Facility until final closure of the Facility: (a) A waste profile sheet or a document with the equivalent information for each waste or other material brought to or placed in the Facility; (b) An inventory of each waste and other material brought to, stored, treated, or managed at the Facility, including an inventory of each waste and other material currently at the Facility; and (c) A record of the date and time that each waste or other material was placed into a Waste Management Area, moved from one Waste Management Area to another Waste Management Area and was taken off-site or removed from the Facility. In addition: (i) For waste or other material in containers in the Container Storage Area, the Area for Staging Containers, the Mix-Tub, Bulk Storage and Transfer Area and the Bulk Unloading and Loading Area, this record shall include the date each container entered or exited such area and how long such container has been in any such area; (ii) For waste or other material in the Truck Parking Area, this record shall include the date and time when such waste or other material on a Transportation Vehicle entered or exited such Area; (iii) For waste or other material in the Truck-to-Truck Transfer Area, this record shall include: (I) The date and time when such waste or other material on a Transportation Vehicle entered or exited such area; (II) The date and time each container was removed from a Transportation Vehicle; and (III) The date and time each container was placed on a Transportation Vehicle; (iv) For Tanks 11 or 14, this record shall include the date each time waste or other material was transferred into such tanks and the amount and identity of such waste or other material; (v) For waste or other materials being moved or transferred this record shall include the type and quantity of waste or other material moved or transferred and the name of the person who authorized such movement or transfer. (41) Before bringing any waste or other material to a Waste Management Area, the Permittee shall conduct a compatibility evaluation and shall ensure that the transfer or movement of waste or other materials does not violate the compatibility requirements of this Permit. NEICVP1493E01 Appendix A Page 118 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (42) (43) Audits (44) Before moving or transferring any waste or other material to or from a Waste Management Area to another Waste Management Area, the Permittee shall: (a) Conduct a hazardous waste characterization and verification in accordance with the WAP presented as Attachment A to this Permit (The WAP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit), if required; and (b) Verify compliance with Section III (A) (41) of this Permit. The Permittee shall ensure that the manifest or shipping paper that accompanies each waste or other material brought to the Facility includes the identification of each waste or other material by using the DOT description (including proper shipping name, hazard class, identification number, and packing group, if any). For each waste or other material present at the Facility the Permittee shall retain the manifest or similar shipping paper used when such waste or other material was brought to the Facility and shall utilize a record keeping system capable of providing such manifest of similar shipping paper upon request. The Permittee shall retain the manifest or similar shipping paper accompanying each waste or other material brought to the Facility in the Operating Record for the Facility. (a) No later than six (6) months after this Permit takes effect, and once each calendar year thereafter, the Permittee shall retain the services of a thirdparty consultant qualified to conduct an audit of the Facility as specified in Condition III(44)(b) below. No audit shall be conducted within 180 calendar days of a prior audit. For purposes of this provision a "third-party consultant," (including the person(s) conducting the audit and the entity employing such person(s)) shall mean a consultant that: (i) Is not a subsidiary of affiliated corporation of the Permittee; (ii) Other than through mutual funds or other similar indirect means, does not own stock in the Permittee or any parent, subsidiary, or affiliated corporation; (iii) Is not otherwise engaged by the Permittee to prepare documents or implement or oversee any other actions required by this Permit; (iv) Has no history of participation in any previous contractual agreement, and no anticipated future contractual relationships, other than a contract to perform audit under Section III(A)(41) of this Permit, with the Permittee or any parent, subsidiary, or affiliated corporation, which, in the Commissioner's judgment and after full disclosure of such participation, would affect the consultant's ability to exercise the independent judgment and discipline required to conduct the required audit(s); (v) Has no other direct financial stake in the outcome of the audit(s) NEICVP1493E01 Appendix A Page 119 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) (c) (d) NEICVP1493E01 required by this Permit; (vi) Is knowledgeable in the requirements of RCRA and DOT; (vii) Has at least three years of experience auditing facilities like the Permittee's; and (viii) At the time the audit is conducted, has a valid and effective (I) license as a Professional Engineer issued by the State of Connecticut; or (II) certification as a Certified Hazardous Materials Manager issued by the Institute of Hazardous Materials Management. If the Commissioner determines that the person(s) conducting the audit or the entity employing such person is unsatisfactory, the Commissioner shall provide the Permittee with a written statement of the reasons for such determination and the Permittee shall not utilize such person(s) or the entity employing such person for any future audit. In the third quarter of the year 2022, and once each calendar year thereafter, the third-party consultant shall audit the Permittee's compliance with the requirements of this Permit, compliance with all applicable statutes and regulations regarding waste and 49 CFR Parts 171 to 180, inclusive (Hazardous Materials Regulations) and if not otherwise included, the items listed in the "Specific Items to be Included in Third-Party Audits" in Appendix A to Section III of this Permit. Before conducting the audit, the third-party consultant shall develop an audit checklist that shall be used to perform the audit and review the terms and conditions of this Permit. As soon as possible, but not later than thirty (30) calendar days after completion of each third party consultant audit as required by this Permit, the Permittee shall take prompt action to address any problems and correct each and every violation discovered during any such audit and certify that the Facility has been brought back into compliance as to any violations discovered during the audit and retain documentation demonstrating such compliance. If the Permittee determines that the correction of any problem or requires more than thirty (30) days to complete, the audit report submitted to the Commissioner pursuant to Section III(A)(45)(d) of this Permit shall include a detailed written plan for correcting the problem or violation, including but not limited to, a schedule to complete any such action. Not later than forty-five (45) calendar days after completion of each audit performed by a third-party consultant required by this Permit, the Permittee shall: (i) Submit to the Commissioner a detailed written report of the results of the audit signed, in accordance with Section I (E) (11) of this Appendix A Page 120 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Permit, by the Permittee and the person conducting the audit. The report shall include, but not be limited to: (I) An Executive Summary of the audit performed that clearly summarizes the nature and scope of the audit, a table with all of violations noted during the audit and any corrective measures taken; (II) The report of the third-party consultant, including, without alteration, the observations, and conclusions of such consultant. Such conclusions and observations shall include, but need not be limited to, the Permittee's compliance with the requirements of this Permit, compliance with all applicable statutes and regulations regarding waste and 49 CFR Parts 171 to 180, inclusive (Hazardous Materials Regulations) and if not otherwise included, the items listed in Appendix A to Section III of this Permit; (III) A description of the audit process, including the areas of the facility inspected, a list of the records reviewed, and persons interviewed and a list or description of any other pertinent information; (IV) A description of all remedial actions taken to address each problem or violation discovered, including those corrected after the audit, but before and after submission of the audit report; and (V) A certification that the Facility has been brought back into compliance as to any violations discovered during the audit and documentation demonstrating such compliance. If the Permittee determines that the correction of any problem or violation discovered as a result of any such audit requires more than thirty (30) days to complete, the Permittee shall include a detailed written plan for correcting such problem or violation, including, but not limited to, a schedule to complete any such action. (ii) Post, in a prominent location on the website for Clean Harbors, Inc., currently www.CleanHarbors.com, or any successor website, the audit report submitted to the Commissioner and the completed audit checklist used to perform the audit. The Permittee shall ensure that the audit report remains posted on its website until the next audit report required by this Permit is posted on its website replacing the previous audit report. The Permittee may redact from the audit report posted on-line non-public information whose disclosure would compromise the security of the Facility, such as the location of security cameras, or would violate a confidentiality agreement between the Permittee and a third-party or information the Permittee has maintained as confidential on the grounds that disclosure could put the Permittee in a competitive disadvantage. Appendix A Page 121 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Should the Permittee redact any such information, no later than fifteen (15) consecutive calendar days after posting the audit report on its website, the Permittee must identify in writing to the Commissioner the information redacted and the basis for the redaction. (e) The Permittee shall retain in the Operating Record for the Facility each audit report and all documentation regarding the findings or results of such audit, and resolution of any identified issues/deficiencies, including the completed audit checklist used to perform the audit. (f) Nothing in the performance of the audit required under this Permit shall affect any authority of the Commissioner under any statute or regulation, including, but not limited to, the authority to issue any order, pursue enforcement action against the Permittee, initiate a permit modification proceeding, or prevent or abate sources of pollution or potential sources of pollution, even for matters discovered during the audit process. No audit conducted by the Permittee or the audit process pursuant to this Permit shall limit, or be construed to limit, in any way any authority of the Commissioner under any statute or regulation, including, but not limited to, any authority to inspect the Facility. Closure (45) In addition to any requirements in Section IV of this Permit, the Permittee shall close the Facility in accordance with the Closure Plan presented herein as Attachment E to this Permit (The Closure Plan will require approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit). When closing or partially closing the Facility, the Permittee must demonstrate that any contaminants remaining after closure will not impact human health or environmental media including ground water, surface water, sediments, soils, or air in excess of recommended exposure limits or factors considering all potential routes of exposure. At a minimum, the closure performance standards for each hazardous waste and other constituent of concern shall meet the remediation standards regulations, RSCA 22a-133k-1 et seq. The Permittee shall notify the Department of any partial closure or closure activities of units at this Facility. Managing Decontamination Waste Generated at the Facility (46) Unless this Permit provides otherwise, when decontaminating a container, roll-off container, or the waste carrying portion of a Transportation Vehicle, including a Vacuum Truck, or any other item, object or equipment, the Permittee shall comply with the provisions of Appendix B to Section III of this Permit. Special Requirements for Ignitable and Reactive Waste (47) In accordance with 40 CFR 264.176, the Permittee shall ensure that containers and roll-off containers holding ignitable or reactive waste are located at least 15 meters (50 feet) from the Facility's property line. The Permittee shall demarcate in any Waste Management Area, in a manner that is readily visible, any portion of any such Area that is less than 15 meters from the Facility property Boundary. NEICVP1493E01 Appendix A Page 122 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (48) The Permittee shall take precautions to prevent accidental ignition or reaction of ignitable or reactive waste at the Facility. This waste must be separated and protected from sources of ignition or reaction including, but not limited to: open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat-producing chemical reactions), and radiant heat. (49) The Permittee shall post "No Smoking" signs in conspicuous locations where ignitable or reactive waste can be managed or stored at the Facility and confine smoking and open flames to specially designated locations. (50) The Permittee shall ground/bond any container, including, but not limited to, a Transportation Vehicle, of ignitable waste or other materials stored or managed in the Facility, at least during the addition and removal of waste to and from any such container. Multiple Hazardous Waste Codes (51) If a hazardous waste is brought to the Facility and the manifest for such waste contains multiple EPA hazardous waste codes, the Permittee shall comply with all applicable requirements, including, but not limited to, the requirements of this Permit, for such waste codes. Land Disposal Restrictions (52) The Permittee shall comply with the land disposal restrictions in 40 CFR Part 268. As part of such compliance, the Permittee shall not mix hazardous waste that does not meet the applicable treatment standard in 40 CFR Part 268, subpart D, with debris that changes the treatment classification of such waste (i.e., from waste to hazardous debris). (53) Dilution Prohibition. The Permittee shall not in any way dilute a restricted waste or residual from treatment of a restricted waste as a substitute for adequate treatment in order to achieve compliance with 40 CFR Part 268. (54) Notifications. The Permittee shall maintain notifications from generators that are required by 40 CFR 268.7 to accompany an incoming shipment of hazardous waste subject to 40 CFR 268, Subpart C, that specify treatment standards, as required by 40 CFR 264.73 and 268.7 of this Permit. (55) Waste Analysis for Land Disposal Restrictions. (a) The Permittee must test his waste or extract developed, using the test method identified in Appendix I of 40 CFR Part 268, or use knowledge of the waste, to determine if the waste is restricted from land disposal. (b) For any waste with treatment standards expressed as concentrations in the waste extract, the Permittee must test the treatment residues or an extract of such residues developed using the test method described in Appendix I of 40 CFR Part 268, to assure that the treatment residues or extract meet the applicable treatment standard. NEICVP1493E01 Appendix A Page 123 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (c) If the treatment residues do not meet the treatment standards, or if the Permittee ships any restricted wastes to a different facility, the Permittee shall comply with the requirements applicable to generators in 40 CFR Part 268. (B) SPECIFIC CONDITIONS APPLICABLE TO CONTAINERS, INCLUDING ROLL-OFF CONTAINERS AND TRANSPORTATION VEHICLES. In addition to any other requirements of this Permit, the Permittee shall comply with the following requirements regarding containers, including roll-off containers and Transportation Vehicles, in the Container Storage Areas (including Container Storage Area C in the Bulk Unloading and Loading Area), the Areas to Stage Containers, the Mix-Tub, Bulk Storage and Transfer Area and the Bulk Unloading and Loading Area. (1) At all times, the Permittee shall maintain aisle space, at a minimum, of 24 inches, between a row or pallet of containers to allow for inspection container handling and the unobstructed movement of personnel and equipment used for emergency response, including, but not limited to, fire protection, spill control and decontamination and staging operations. (2) The stacking of containers (up to 55 gallons) in the Container Storage Areas shall be limited to two (2) tiers high. 350-gallon tote containers may be double stacked. If the Permittee stacks 350-gallon totes, safeguards must be in place to inspect their condition and labeling information at all times. The Permittee shall ensure that containers are not stacked at any time in: (i) Any of the Area H Areas to Stage Containers, other than containers with a capacity of five (5) gallon or less, which shall not be stacked more than two (2) tiers high; or (ii) The Mix-Tub, Bulk Storage and Transfer Area. (3) The Permittee shall ensure that each container with hazardous waste, including a roll-off container and Transportation Vehicle, is labeled or marked clearly with the words "Hazardous Waste" and other words that identify the contents of each container, such as "flammable," "acid", "alkaline", "cyanide", "reactive," "halogenated solvent," "latex paint," "oil paint" or the chemical name of the contents of the container. (4) (a) The Permittee shall not store any wastes or other materials that are incompatible within an Area to Stage Containers, a Container Storage Area, the Mix-Tub, Bulk Storage and Transfer Area or the Bulk Unloading and Loading Area. (b) Within the Container Storage Area building, the Permittee shall not store hazardous wastes or other materials that are incompatible, unless such wastes are protected or separated from each other by means of dike, berm, wall, tank, or other device. For purposes of this provision, compatibility shall be determined in accordance with 40 CFR Part 264, Appendix V. NEICVP1493E01 Appendix A Page 124 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (5) (a) At the time any container of waste or other material, including a roll-off container or Transportation Vehicle, is placed into any Container Storage Area or Area to Stage Containers, the Mix-Tub, Bulk Storage and Transfer Area or the Bulk Unloading and Loading Area, the Permittee's trained personnel shall ensure that: (i) The container is not deteriorated (e.g., cracked, rusted), damaged or leaking; (ii) The container is tightly closed; (iii) Any applicable requirements of the WAP, presented herein as Attachment A to this Permit (The WAP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit), have been complied with and recorded in the Operating Record for the Facility. (iv) The information on the Waste Analysis Profile Sheet for such container is consistent with the information on the label on the container, such that the waste or other material is in the appropriate container; and (v) A bar code, or similar tracking device, has been placed on the container such that at all times the Permittee can identify: (I) The contents of the container; (II) When a container was placed in a such area; and (III) All of the containers placed in any such area. (b) If inspection reveals that any of the conditions specified in Section III (B) (5) (a) of this Permit are not met, the Permittee shall correct the condition immediately. If an immediate correction is not possible, the Permittee shall segregate and isolate such waste or other material by placing it, by itself, in a separate Staging Area H on a containment pallet or a separate distinct part of the Mix-Tub, Bulk Storage and Transfer Area or Bulk Unloading and Loading Area for a roll-off container or Transportation Vehicle. The Permittee shall not place any other waste or other material in any such area until the Permittee is in compliance with all of the conditions in Section III (B) (5) (a) of this Permit. In the event waste or other material is segregated and isolated pursuant to this provision of the Permit, the Permittee shall record in the Operating Record for the Facility the date and area into which waste or other material was placed, the reason for placing such waste or other material in that area, any corrective or other action taken regarding such waste or other material and the date any such waste or other materials was removed from such area. In the event that the Permittee cannot comply with Section III (B) (5) (a) of this Permit, the Permittee shall comply with Section III (A) (38) (b) for any such waste or other material. (6) In addition to any other requirements of this Permit, the Permittee shall ensure that: NEICVP1493E01 Appendix A Page 125 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) Once a container leaves a Container Storage Area or an Area to Stage Containers and is brought into the Truck-to-Truck Transfer Area that any such container is sent off-site and is not returned to any Container Storage Area or Area to Stage Containers; and (b) Once a Transportation Vehicle leaves the Mix-Tub, Bulk Storage and Transfer Area or the Bulk Unloading and Loading Area, such vehicle shall not be brought to the Truck Parking Area or the Truck-to-Truck Transfer Area or Truck-to-Truck Parking Area. (C) REQUIREMENTS REGARDING PAINTCARE PROGRAM WASTE In addition to any other requirements of this Permit, the Permittee shall comply with the following requirements regarding all PaintCare Program Waste brought to the Facility. (1) PaintCare Program Waste shall be received at the Facility in containers that are in direct contact with waste, (e.g. paint cans) Inner Containers, that are within a larger container, an Outer Container, used to hold the Inner Containers. Upon arrival at the Facility, but before a Transportation Vehicle enters any Waste Management Area, the Permittee shall record the date that each Outer Container arrives at the Facility and shall maintain a record of the date in the Operating Record for the Facility. (2) The Permittee shall ensure that PaintCare Program Waste is off-loaded from a Transportation Vehicle onto the Loading Dock in the Truck-to-Truck Transfer Area. (3) After being off-loaded onto the Loading Dock, the Permittee shall visually inspect both the Inner and Outer Containers: (a) If an inspection reveals that the integrity of an Outer Container has been compromised, the Permittee shall transfer all of the Inner Containers to an Outer Container whose integrity is not compromised; and (b) If an inspection reveals that an Inner Container is or may be leaking, the Permittee shall immediately take all measures necessary to prevent leakage, or further leakage. If the integrity of an Inner Container has been compromised, the Permittee shall place the compromised container in salvage container or transfer the waste from the leaking container to a container whose integrity has not been compromised and, if necessary, transfer all of the other non-leaking Inner Containers to another Outer Container whose integrity has not been compromised. If a new Outer Container is used, the Permittee shall label the new Outer Container with the information taken from the Outer Container from which the Inner Containers were removed. (c) The Permittee shall properly characterize and manage any waste generated as a result of a leak, spill or release from an Inner or Outer Container in accordance with all applicable requirements. (4) The Permittee shall ensure that all PaintCare Program Waste leaving the Loading Dock is brought only to: NEICVP1493E01 Appendix A Page 126 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) Staging Areas H for staging only; the Permittee shall not sort, or otherwise manage, such waste in Staging Areas H; or (b) Staging Area M-2 for sorting, and if necessary, sampling pursuant to Section III(C) (6) (b) of this Permit. (5) (a) In Area M-2, the Permittee shall sort all of the Inner Containers into Waste Paint and Non-Paint Waste. The Permittee shall further sort all Waste Paint into Latex Waste Paint and Non-Latex Waste Paint. The Permittee shall place all of the sorted Inner Containers brought to Staging Area M-2 into a different Outer Container used solely for Latex Waste Paint, Non-Latex Paint Waste or Non-Paint Wastes. The Permittee shall ensure that during the sorting process all of the Inner Containers are sorted correctly and placed in the correct Outer Container (i.e., Latex Waste Paint is placed in an Outer Container only for such waste). Once sorted the Permittee shall not co-mingle or mix in a container Latex Waste Paint, Non-Latex Paint Waste or Non-Paint Wastes, except that if the Permittee determines, pursuant to Section III(C)(6) of this Permit that Non-Paint Wastes can be managed with Non-Latex Paint wastes, the two wastes can be co-mingled in the same Outer Container. (b) Nothing in the foregoing shall prevent the Permittee from managing all of the waste in an Outer Container as either Latex Waste Paint, Non-Latex Waste Paint or Non-Paint Waste, provided the Permittee retains in the Operating Record for the Facility the basis upon which it determined that all of the Inner Containers in any such Outer Container were of one waste type. (c) When sorting PaintCare Program Waste the Permittee may rely on the label of an Inner Container, unless the Permittee has reason to believe that the label is not accurate (i.e., the waste is not as specified on the label). (6) When sorting PaintCare Program Waste if the Permittee finds Non-Paint Waste: (a) The Permittee shall identify the waste and determine if it can be managed at its Facility, and if so, how it must be managed. In complying with this provision, the Permittee cannot rely on the household waste exclusion in 40 CFR 261.4(b); (b) In identifying Non-Paint Waste, the Permittee may rely on the label of the container for such waste provided the Permittee has no reason to believe that the waste is not as specified on the label. If there is no label on the container or the Permittee has reason to believe that the waste is not as specified on the label, the Permittee shall: (i) immediately place such waste in an Area H used for Staging Containers on a containment pallet and perform laboratory analysis to identify such waste. The Permittee shall not place any other waste in such staging area until the waste, after analysis, has been identified and the Permittee based upon such analysis has determined how such waste shall be managed; and NEICVP1493E01 Appendix A Page 127 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (ii) record in the Operating Record for the Facility the Staging Area where such waste has been placed, the results from the waste analysis for such waste and how such waste was managed at the Facility. (c) If the Permittee determines that Non-Paint Waste can be managed at its Facility, the Permittee may manage such waste and shall do so in compliance with all of the requirements of this Permit. (d) If the Permittee determines that Non-Paint Waste cannot be managed at the Facility, the Permittee shall comply with the requirements of Section III (A) (38) of this Permit regarding such waste. (7) Before using a new Outer Container for sorted waste, the Permittee shall first place a label on the container that: (a) Indicates whether the Outer Container is being used for Latex Waste Paint or Non-Latex Waste Paint; (b) Remains legible to emergency personnel; and (c) Indicates the date that an Inner Container was first placed in such Outer Container. The Permittee shall not remove or modify the label once it is placed on an Outer Container as long as Latex Waste Paint or Non-Latex Waste Paint remains in the container, even when the Outer Container is moved from Staging Area M-2 to a Container Storage Area at the Facility. Additionally, the Permittee shall not place any Inner Container into an Outer Container that is not labeled in accordance with this provision of the Permit. (8) Once an Inner Container with Latex Waste Paint or Non-Latex Waste Paint has been sorted and placed in an Outer Container, the Permittee shall not remove any such Inner Container and place it into another Outer Container, unless the Outer Container into which such Inner Container is being moved is labeled with a date that is earlier than the date on the Outer Container from which the Inner Container was removed. Notwithstanding the foregoing, if the Integrity of an Outer Container has been compromised and needs replacing, the Permittee shall label the new Outer Container with the information taken from the Outer Container whose integrity has been compromised. (9) Unless Section III(C)(6)(d) applies, the Permittee shall ensure that no later than five (5) days after PaintCare Program Waste has been brought to Area M-2 that: (a) all of the requirements of Section III(C)(5)-(8) of this Permit have been completed; and (b) that all such waste is removed from Area M-2 and brought to the Container Storage Area for storage or to the Truck-to-Truck Transfer Area for off-site shipment. NEICVP1493E01 Appendix A Page 128 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (10) The Permittee shall ensure that no Latex Waste Paint or Non-Latex Waste Paint remains at the Facility more than one year. The date recorded on an Outer Container shall be used when determining compliance with this provision, regardless of when any Inner Container was placed in such Outer Container. (11) The Permittee shall manage all Non-Latex Waste Paint as a hazardous waste, at a minimum for ignitability, unless based upon the results of a hazardous waste determination using the method specified in 40 CFR 262.11, the Permittee determines that the waste is not a hazardous waste. The Permittee shall retain the results of any such hazardous waste determination in the Operating Record for the Facility. (12) During the entire time that PaintCare Program Waste is at the Facility, the Permittee shall ensure that all such waste is away from and protected against ignition sources. (13) The Permittee shall maintain all PaintCare Program Waste containers, upright and in a manner that will protect them from breakage, rupture, and conditions that may cause them to leak. The Permittee shall keep all Inner Containers closed at all times, except if a container not in good condition (e.g., there is severe rusting, cracks, apparent structural defects or bulging) or if it begins to leak, the Permittee shall immediately take all measures necessary to prevent leakage, or further leakage. If the integrity of an Inner Container has been compromised, the Permittee shall place the compromised container in salvage container or transfer the waste from the compromised container to a container whose integrity has not been compromised, and, if necessary, transfer all of the other non-leaking Inner Containers to another Outer Container whose integrity has not been compromised. If a new Outer Container is used, the Permittee shall label the new Outer Container with the information taken from the Outer Container from which the Inner containers were removed. The Permittee shall properly characterize and manage any waste generated as a result of a leak, spill, or release from an Inner or Outer Container in accordance with all applicable requirements. (D) SPECIFIC WASTE MANAGEMENT AREA OPERATING CONDITIONS. The Permittee shall comply with the following conditions specific to the Waste Management Areas specified below. (1) CONTAINER STORAGE AREAS AND AREAS TO STAGE CONTAINERS: (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements at each Container Storage Area ("CSA") and each Area to Stage Containers ("ASC"). The Permittee shall ensure that: (i) All containers holding wastes or other materials are handled or stored in a manner that prevents leakage or spillage from such containers; (ii) All containers holding waste or other materials remain closed except: NEICVP1493E01 Appendix A Page 129 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) NEICVP1493E01 (I) During the time necessary to sample waste or other materials; (II) When lab pack wastes are being consolidated or poured into the On-Site Wastewater Treatment Plant; (III) When a container is not in good condition and the contents are being transferred, as provided for in Section III (A) (12) of this Permit; or (IV) When, in staging Areas H only, waste, or other materials is being pumped to the On-Site Wastewater Treatment Plant or Tanks Systems 11 or 14; (iii) If not provided for in the Inspection Plan presented herein as Attachment B to this Permit (The IP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit), whenever waste or other materials is present in any CSA or ASC, the Permittee visually inspects such Areas daily for the items identified in Section III (A) (20) of this Permit and shall take action and record such inspections as provided for in in Section III (A) (20) and (21) of this Permit; (iv) Each container storage area and each staging area has a secondary containment system that at a minimum complies with the requirements of 40 CFR 264.175; (v) The Permittee complies with all applicable requirements of 40 CFR 264, Subpart CC regarding hazardous waste in containers. The Permittee shall maintain in the Operating Record for the Facility all records needed to demonstrate compliance with the applicable requirements of 40 CFR 264, Subpart CC; and (vi) When waste or other materials is brought to or placed in in any ASC, a drum cart or a forklift truck is in the immediate vicinity of such Area to allow for quick transfer or movement of containers in the event of an emergency. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements at each Container Storage Area, including Container Storage Area C in the Bulk Unloading and Loading Area: (i) The Permittee shall post in each Container Storage Area, a sign, or signs, clearly identifying the type of waste or other material being stored (e.g., corrosivity, flammability, oxidizer, poison, toxic etc.) in such Area or portion of such area. The Permittee shall ensure that the sign(s) in each Container Storage Area, or portion of such area, is secure, legible, and clearly visible from a distance of at least twenty-five (25) feet. Any such sign shall remain posted as long as waste or other material of the type designated on the sign is stored in such area; Appendix A Page 130 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (ii) The Permittee may change the type of waste or other material stored in Container Storage Areas B, D, E, F, G, J, K and L, provided that before changing the type of waste or other material in any such Area the Permittee shall: (I) Remove all waste and other material from the Area; (II) Inspect the Area for the presence of visible residue and compliance with Section III (A) (29) of this Permit; (III) Comply with Sections III (A) (30) (b) to (d), inclusive and III (A) (31) and III (A) (32) of this Permit regarding such Area, as necessary; (IV) Post a new sign or signs that complies with Section III (D)(1)(b)(i) of this Permit for the Area, if necessary; and (V) Record the following information in the Operating Record for the Facility: (A) The name and title of the person inspecting the Area after the removal of all waste and other materials; (B) The date and results of the inspection of the Area, and any action taken as a result of the inspection; (C) The name and title of the person, who, after inspection, determined that the Area can be redesignated and used for a different type of waste or other material and the date of this inspection; and (D) The change in type of waste stored in the Area, including the previous and new waste. (iii) The Permittee shall ensure no reactions of a type specified in 40 CFR 246.17(b)(1)-(5) occur whenever the Permittee is changing the type of waste or other materials stored in a Container Storage Area. This includes, but is not limited to, changes involving waste or other materials that are incompatible, as determined in accordance with 40 CFR 264, Appendix V. (iv) Except for hazardous waste specified in 40 CFR Part 268.50(d) and (e), the Permittee may store hazardous waste restricted from land disposal, provided: (I) the Permittee clearly marks each container of waste to identify the contents of such container and the date such container was first placed into storage at a Container Storage Area at the Facility; (II) such waste is not stored for longer than one (1) year or Appendix A Page 131 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (c) (d) NEICVP1493E01 three hundred sixty-five (365) calendar days from the date such waste was first placed in storage at the Facility; and (III) the Permittee can demonstrate that such storage is solely for the purpose of accumulating such quantities necessary for recovery, treatment, or disposal of such waste. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements at Area M2 in connection with PaintCare Program Waste: (i) The Permittee shall ensure that Area M2 is equipped with appropriate emergency response equipment including, but not limited to, a fire extinguisher, a salvage drum, eye wash, safety shower, and a spill kit containing, at a minimum, safety goggles, gloves, absorbent, and personnel protective equipment; and (ii) In addition to all hazardous waste training, the Permittee shall ensure that all Facility personnel handling PaintCare Program Waste are trained in all of the requirements of this Permit, for such waste including, but not limited to, handling, inspecting, tracking, reporting and sorting and in the emergency response procedures and Facility standard Operating Procedures. The Permittee shall maintain training plans and records of the training provided to comply with this provision in the Operating Record for the Facility. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements in the Area to Stage Containers regarding the consolidation of lab packs with waste or other materials. (i) The Permittee shall not accept a lab pack for disassembly that: (I) Has not been pre-approved in accordance with the Facility's WAP incorporated as Attachment A to this Permit (The WAP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit); and (II) Is not accompanied by a packing slip denoting the chemical contents, waste codes and the type and sizes of individual containers within the lab pack. (ii) The Permittee may only consolidate lab packs in the designated Areas. (iii) When disassembling a lab pack the Permittee shall assess: (I) The physical condition of each container inside the lab pack to determine whether the integrity of any container inside the lab pack has been compromised. If the integrity of any such container has been compromised, the Permittee shall determine whether pour-off activities can safely be conducted or whether the lab pack container Appendix A Page 132 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut requires further disassembly or repackaging. The Permittee shall manage all waste generated from a container whose integrity of has been comprised, in accordance with all applicable requirements; and (II) Whether the containers within the lab-pack match the containers listed on the packing list for lab pack. If a discrepancy is discovered (e.g., container not listed on the packing list is discovered), the Permittee shall comply with Section III (A) (37) of this Permit regarding any such container. (iv) The Permittee may consolidate the waste or other materials in one lab pack with waste or other materials in another lab pack or take the waste or other materials in two or more lab packs and consolidate them in a new lab pack container, provided that: (I) The Permittee does not open any containers within a lab pack during the consolidation process; (II) The Permittee ensures that the contents of all lab packs being consolidated are compatible, as determined by 40 CFR Part 264, Appendix V; and (III) The Permittee disposes of all waste generated from the consolidation of lab packs in accordance with all applicable requirements. (2) BULK UNLOADING AND LOADING AREA (BULA) (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the Bulk Unloading and Loading Area (BULA). The Permittee shall ensure that: (i) No incompatible waste or other materials are in the Bulk Unloading and Loading Area at the same time. This includes, but is not limited to, waste or other materials on Transportation Vehicles or in a container. For purposes of this provision, compatibility shall be determined in accordance with 40 CFR Part 264 Appendix V; (ii) When decontaminating Transportation Vehicles, or any portion thereof of any equipment used in connection with the transfer of waste or other materials, the Permittee complies with Appendix B to Section III of this Permit; (iii) In addition to any other secondary containment requirements, the secondary containment system in the Bulk Unloading and Loading Area complies with the requirements of 40 CFR 264.175; and (iv) Prior to transferring any waste or other materials from the Bulk Unloading and Loading Area: NEICVP1493E01 Appendix A Page 133 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (I) All applicable sections of the Waste Analysis Plan, incorporated herein as Attachment A to this Permit have been complied with; (II) The receiving tank, including a tank associated with the On-Site Wastewater Treatment Plant, Transportation Vehicle or container has the capacity to receive the waste or other material to be transferred; (III) All waste or other materials being transferred from the Bulk Unloading and Loading Area is compatible with waste or other materials in the On-Site Wastewater Treatment Plant, Tank Systems 11 or 14 or in the receiving Transportation Vehicle or container. For purposes of this provision, compatibility shall be determined in accordance with 40 CFR Part 264 Appendix V; and (IV) That the name of the person who authorized such transfer and the amount of waste or other materials being transferred is recorded and maintained in the Operating Record for the Facility. (v) A sign is posted, or signs are posted, clearly identifying the type of waste or other material (e.g., corrosivity, reactive, ignitable, flammability, oxidizer, poison, toxic, etc.) in the Bulk Unloading and Loading Area or portion of such area. The Permittee shall ensure that all such signs are secure, legible, and clearly visible from a distance of at least twenty-five (25) feet and remain posted as long as waste or other material of the type designated on the sign is in such area; (3) TANK SYSTEMS 11 AND 14. The Permittee is prohibited to store wastes with Volatile Organic concentrations greater than 500 parts per million by weight (ppmw) by weight in Tank Systems 11 and 14. (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding Tank Systems 11 and 14. (i) The Permittee shall not place any waste in Tank Systems 11 and 14 that could cause any tank, its ancillary equipment, or containment system to rupture, leak, corrode or otherwise fail. (ii) The Permittee shall prevent spills and overflows from Tank Systems 11 and 14 or any containment system associated with these tanks systems. At a minimum, the Permittee shall use the following measures to prevent spills: (I) Spill prevention controls (e.g., check valves, dry disconnect couplings); and (II) Overfill prevention controls such as high-level alarms or automatic feed cutoffs. NEICVP1493E01 Appendix A Page 134 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Decontamination NEICVP1493E01 (iii) The Permittee shall retain in the Operating Record for the Facility, documentation demonstrating compliance with 40 CFR 264.191 and 40 CFR 264.192. This documentation shall include the certification statement required by 40 CFR 270.11(d). (iv) The Permittee shall ensure that all ancillary equipment associated with Tank Systems 11 and 14 is supported and protected against physical damage and excessive stress due to settlement, vibration, expansion, or contraction. (v) The Permittee shall comply with the requirements of 40 CFR 264.196, with respect to leaks or spills or unfit-for-use tank system(s). (vi) Prior to transferring any waste into Tank Systems 11 or 14, the Permittee shall: (I) Ensure compliance with all applicable sections of the WAP, incorporated herein as Attachment A to this Permit (The WAP needs written approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit); (II) Ensure that wastes with VO concentration greater than 500 ppmw are not accepted for storage in the Tank Systems. The Permittee shall conduct a sampling verification of the waste prior to any transfer; (III) Ensure that Tank Systems 11 or 14 have the capacity to receive the waste to be transferred; and (IV) Record and maintain in the Operating Record for the Facility the name of the person who authorized such transfer and the amount of waste being transferred. (vii) The Permittee shall comply with all applicable requirements including, but not limited to the requirements of this Permit, regarding the wastes in Tank System 11 and 14. Such compliance shall include, but not be limited to, compliance with the requirements applicable to each waste that may be added to a tank system and any resultant mixture (i.e. any resultant mixture shall be managed as containing each waste added to such mixture). The Permittee shall maintain in the Operating Record for the Facility all documentation used to demonstrate such compliance, including, but not limited to, records regarding the waste analysis requirements in 40 CFR 262.11 and the land disposal restrictions in 40 CFR Part 268. (viii) The Permittee shall decontaminate Tank System 11 or 14, as applicable, in accordance with Appendix B of this Section of the Appendix A Page 135 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (ix) Secondary Containment (x) Inspections (xi) Permit, whenever: (I) PCBs, at any level, are detected in a tank system or in any waste or other materials in, or added to, a tank system; or (II) All of the waste has been removed from a tank system, and (A) the waste removed and the waste to be added to such tank system thereafter are incompatible, as determined in accordance with 40 CFR Part 264, Appendix V; or (B) the waste removed contains a listed hazardous waste and the waste to be added to such tank system thereafter is a non-hazardous waste or is a characteristic hazardous waste. The Permittee shall comply with Appendix B to Section III of this Permit when decontaminating a tank system and in addition to such requirements, the Permittee shall keep and maintain in the Operating Record for the Facility a Tank Cleaning Certificate or equivalent documentation regarding decontamination of such tank system. An example of a Tank Cleaning Certificate is presented in Appendix C to Section III of this Permit; In addition to any other requirements of this Permit, the Permittee shall comply with 40 CFR 264.193 for Tank Systems 11 and 14. For purposes of determining compliance with this provision: (I) a number of tanks and ancillary equipment that are part of or are associated with the On-Site Wastewater Treatment Plant are located in the area that provides secondary containment for Tank Systems 11 and 14. All such tanks and equipment, including, but not limited to, the volume of such tanks and equipment, shall be considered; and (II) any device or structure creating negative containment volume (e.g., equipment or tanks that are part of or are associated with the On-Site Wastewater Treatment Plant) shall be included. If not provided for in the Inspection Plan incorporated herein as Attachment B to this Permit (The Inspection Plan needs review and written approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit), the Permittee shall ensure that inspections of Tank Systems 11 and 14 include a daily evaluation of: NEICVP1493E01 Appendix A Page 136 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (I) The overfill controls (high level alarms, automatic waste feed cut-off, and all other overfill/spill control equipment associated with each tank system) to ensure that such controls are in good working order; (II) The above ground portions of the tank system to identify corrosion, leaks, deterioration or structural fatigue in any portion of the tank or system components (all piping, including flanges, joints, valves, and other connections, flow metering devices associated with each tank system) to ensure that it is in good working order; Incompatibles (III) The area immediately surrounding the externally accessible portion of each tank system, including the secondary containment system (e.g., dikes) to identify signs of leaks (e.g., wet spots) or spills; and (IV) Analysis of any data received from leak detection monitors or alarms. (xii) The Permittee shall not place incompatible wastes, in the same tank system, unless before doing so the Permittee performs a bench scale test that demonstrates that mixing incompatible wastes will not result in any of the reactions specified in 40 CFR 264.17(b). Should the Permittee mix incompatibles in the same tank system it shall maintain separately in the Operating Record for the Facility documentation that clearly identifies the incompatible wastes that were mixed, the bench scale tests performed on mixing such wastes and the results of such tests. For purposes of this provision, the compatibility shall be determined in accordance with 40 CFR Part 264, Appendix V. (xiii) Labeling/Recordkeeping Tank Systems 11 and 14 are located in a vault system that also contains numerous tanks and ancillary equipment that are part of or are associated with the On-Site Wastewater Treatment Plant. The Permittee shall ensure that at all times, all wastes placed in Tank Systems 11 and 14 remain separated from any incompatible waste in the same vault system, including the contents of tanks or equipment that are part of or are associated with the On-Site Wastewater Treatment Plant, or are protected from such incompatibles by means of dike, berm, wall, double-walled tank or other device. For purposes of this provision, compatibility shall be determined in accordance with 40 CFR Part 264, Appendix V. (xiv) The Permittee shall ensure that any tank (11 or 14) into which hazardous waste is labeled or marked clearly on the outside of such tank with the words "Hazardous Waste," and other words NEICVP1493E01 Appendix A Page 137 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut that identify the contents of the tank, such as "flammable," etc. The Permittee shall ensure that any such label or marking is secure, legible, and clearly visible from a distance of at least twenty-five (25) feet and remains posted as long as hazardous waste is stored in such tank system. (xv) The Permittee shall ensure that any tank (11 or 14) into which non-hazardous waste is labeled or marked clearly on the outside of such tank, with words "Non-RCRA Wastes" and other words that identify the contents of such tank such as "non-flammable." The Permittee shall ensure that any such label or marking is secure, legible, and clearly visible from a distance of at least twenty-five (25) feet and remains posted as long as nonhazardous waste is stored in such tank system. (xvi) The Permittee shall place a label or mark on the outside of tank 11 and 14 clearly indicating the capacity of each tank system. The Permittee shall ensure that any such label or marking is secure, legible, and clearly visible from a distance of at least twenty-five (25) feet. (xvii) The Permittee shall maintain in the Operating Record for the Facility the quantity of waste added to a tank system and the date and time, that such quantity was added to such tank system. Land Disposal Restriction Requirements (xviii) Except for hazardous waste specified in 40 CFR Part 268.50(d) and (e), the Permittee may store hazardous waste restricted from land disposal provided: (I) the Permittee records and maintains in the Operating Record for the Facility, the date such waste was put into Tank 11 or 14; (II) such waste is not stored for longer than one (1) year or three hundred sixty-five (365) calendar days from the date such waste was put into Tank 11 or 14; and (III) the Permittee can demonstrate that such storage is solely for the purpose of accumulating such quantities necessary for recovery, treatment, or disposal of such waste. (4) MIX-TUB, BULK STORAGE AND TRANSFER AREA (MBSTA) (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements in the Mix-Tub, Bulk Storage and Transfer Area. (i) The Permittee shall ensure that the secondary containment system in the Mix-Tub, Bulk Storage and Transfer Area complies with the requirements of 40 CFR 264.175. NEICVP1493E01 Appendix A Page 138 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) NEICVP1493E01 (ii) Weather permitting, the Permittee shall power wash or clean the Mix-Tub, Bulk Storage and Transfer Area monthly. The Permittee shall perform a hazardous waste determination on the rinsate and shall manage such rinsate in accordance with all applicable requirements. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the storage of waste or other materials in roll-off containers, Transportation Vehicles, including Vacuum Trucks, within the Mix-Tub, Bulk Storage and Transfer Area: (i) Prior to placing any waste or other materials in the Mix-Tub, Bulk Storage and Transfer Area, the Permittee shall: (I) Post a sign or signs, clearly identifying the type of waste or other material (e.g., corrosivity, flammability, oxidizer, poison, toxic, etc.) in such Area or portion of such area. The Permittee shall ensure that any such sign(s) is secure, legible, and clearly visible from a distance of at least twenty-five (25) feet. Any such sign shall remain posted as long as waste or other material of the type designated on the sign is in the Mix-Tub, Bulk, Storage and Transfer Area; (II) Visually inspect such roll-off container, Truck or Vehicle and shall not place or store such container in the Mix-Tub, Bulk Storage and Transfer Area unless the container, Truck or Vehicle: (a) Is properly marked and labeled; (b) Is in good condition and free of impairment or damage; (III) Ensure that the required profile form and manifest or shipping paper has been received at the Facility and all applicable sections of the WAP, incorporated herein as Attachment A (The WAP needs review and written approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit) to this Permit have been complied with; and (IV) Is covered in a manner that meets the requirements of Section III (D) (4) (b) (ii) of this Permit; (ii) The Permittee shall ensure that at all times, except when waste is being removed from or placed in a roll-off container, Transportation Vehicle, including a Vacuum Truck, that each rolloff container or vehicle has a seal or cover: (I) Capable of preventing fugitive emissions; (II) Capable of preventing precipitation from entering the Appendix A Page 139 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (c) NEICVP1493E01 container or that portion of the Vehicle or Truck holding waste; and (III) Of sufficient strength to prevent any tears during handling operations; and (iii) If a roll-off container or Transportation Vehicle, including a Vacuum Truck, holding waste does end up containing free draining liquids as a result of precipitation, the Permittee shall remove such liquid within twenty-four (24) hours from the time of discovery or the time the Permittee should have discovered such accumulated precipitation; (iv) Except for hazardous waste specified in 40 CFR Part 268.50(d) and (e), the Permittee may store hazardous waste restricted from land disposal in the Mix-Tub, Bulk Storage and Transfer Area provided such storage is solely for the purpose of accumulating such quantities necessary for recovery, treatment or disposal of such waste; and (v) The Permittee shall ensure that no Vacuum Truck in the Mix-Tub, Bulk Storage and Transfer Area containing liquids, semi- solids or solids, has a capacity that exceeds 4,000 gallons, except a Vacuum Truck that was in the Bulk Unloading and Loading Area and after it has transferred all of its liquid contents into the Facility from the Bulk Unloading and Loading Area is brought to the MixTub, Bulk Storage and Transfer Area for the sole purpose of cleaning out the inside of such truck. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the Mix-Tub in the Mix-Tub, Bulk Storage and Transfer Area. (i) The Permittee shall not place any waste in the Mix-Tub except when stabilizing, solidifying, or bulking such waste or when collecting rinsate from decontamination activities. (ii) The Permittee shall have in place a Sampling Protocol Procedure to prevent treating wastes with a VO concentration above 500 ppmw in the Mix-Tub. The Permittee is prohibited from treating wastes with VO concentrations above 500 ppmw. Such a documentation shall be maintained in the Operating Record for the Facility. (iii) The Permittee shall ensure that if a container brought to the MixTub Drum Process Area identified on Drawing No. 62WC-7100204, Waste Management Areas, Site Plan, or a Vacuum Truck brought to the Mix-Tub, Bulk Storage and Transfer Area contains liquids or a mixture of solids, semi-solids and liquids, that: (I) The Permittee is authorized to receive the liquid portion of such waste at the On-Site Wastewater Treatment Plant, Tank 11 or 14 or in containers, excluding roll-off Appendix A Page 140 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 containers; (II) The liquid portion of any such waste is removed from such container or Vacuum Truck before such waste is placed into the Mix-Tub; and (III) Such liquid is pumped to the On-Site Wastewater Treatment Plant, to Tank 11 or 14 or to a container, excluding roll-off containers. (iv) The Permittee shall ensure that if a Transportation Vehicle, other than a Vacuum Truck, is brought to the MBSTA with waste to be bulked in the Mix-Tub, that any liquids in such waste are removed from such waste in the BULA, before the waste is emptied into the Mix-Tub. For purposes of this provision, the term liquids shall not include liquids that may have settled during transportation, provided that liquids that have settled during transportation shall be limited to liquids present in a separate distinct phase that do not occupy more than one inch in a container, Transportation Vehicle, including a Vacuum Truck. (v) Prior to solidifying or bulking any wastes or stabilizing any hazardous waste the Permittee shall: (I) Ensure compliance with all applicable sections of the Waste Analysis Plan, including, but not limited to, any compatibility assessment, incorporated herein in Attachment A to this Permit; and (II) Record and maintain in the Operating Record for the Facility the name of the person who authorized such solidification, stabilization, or bulking. (vi) (I) The Permittee shall not place incompatibles wastes into the Mix-Tub for any purpose and shall ensure that any substance added to solidify or stabilize a waste is compatible with such waste. (II) The Permittee shall ensure that any residue present in the Mix-Tub is compatible with any waste added to the MixTub or any substance added to solidify or stabilize a waste. For purposes of Section III (4) (D) (iv) of this Permit, compatibility shall be determined in accordance with 40 CFR Part 264, Appendix V. (vii) The Permittee shall inspect the Mix-tub for signs of spills and leaks before, during and after each use. The Permittee shall ensure that: Appendix A Page 141 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 (I) Any spills or leaks detected during inspection are immediately and properly remediated; (II) As a result of such inspection, any necessary repairs are made as soon as possible; and (III) Such inspections and any action taken as a result of such inspections are recorded in an inspection log that is maintained in the Operating Record for the Facility. (viii) The Permittee shall ensure that when using the Mix-Tub, all waste, rinsate collected or material added for solidification or stabilization purposes, remains in the Mix-Tub, and does not spill out of or leave the Mix-Tub. (ix) (I) The Permittee shall not stabilize different hazardous wastes - those with different EPA Hazardous Wastes Codes - in the Mix-Tub at the same time, unless: (A) When the waste being stabilized arrived at the Facility it contained different wastes codes as noted on the manifest accompanying such waste, provided after arriving at the Facility the Permittee does not add any other waste to such waste; or (B) The EPA Hazardous Wastes Codes for the waste to be stabilized together are D004, D005, D006, D007, D008, D009, D010, or D011 and such wastes are not incompatible as determined in accordance with 40 CFR Part 264 Appendix V. (II) The Permittee shall comply with all applicable requirements including, but not limited to, the requirements of this Permit, regarding the waste generated from stabilization in the Mix-Tub. Such compliance shall be based upon the hazardous waste codes for such waste before stabilization and, shall include, but not be limited to, whether after stabilization, such waste satisfies all, or only a portion, of the treatment standards specified in 40 CFR Part 268, Subpart D. The Permittee shall maintain in the Operating Record for the Facility all documentation used to demonstrate such compliance, including, but not limited to, records regarding the waste analysis requirements in 40 CFR 262.11 and the land disposal restrictions in 40 CFR Part 268. (x) (I) The Permittee may solidify or bulk more than one waste in the Mix-Tub at the same time, provided such wastes are not incompatible as determined in accordance with 40 CFR Part 264 Appendix V. (II) The Permittee shall comply with all applicable Appendix A Page 142 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Decontamination requirements including, but not limited to the requirements of this Permit, regarding the waste generated from the solidification or bulking in the Mix-Tub. Such compliance shall include, but not be limited to, compliance with the requirements applicable to each waste added to the resultant mixture (i.e. the resultant mixture shall be managed as containing each waste added to the mixture). The Permittee shall maintain in the Operating Record for the Facility all documentation used to demonstrate such compliance, including, but not limited to, records regarding the waste analysis requirements in 40 CFR 262.11 and the land disposal restrictions in 40 CFR Part 268. (xi) The Permittee shall manage all waste treated in the Mix-Tub as a waste, including waste that has been treated, regardless of whether such waste still exhibits the characteristics of a hazardous waste or can be land disposed under 40 CFR Part 268. (xii) (I) The Permittee shall decontaminate the Mix-Tub, as well as equipment used in the solidifying, stabilization or bulking process (i.e., the backhoe or excavator, hoses, shovels, etc.), in accordance with Appendix B of this Section of the Permit, whenever: (A) PCBs, at any level, are detected in the Mix-Tub or in any waste in, or added to, the Mix-Tub. Any such decontamination shall include any roll-off or other container, Transportation Vehicle that may have contained waste containing PCBs; or (B) All of the waste has been removed from the MixTub and (1) The waste removed, including any rinsate from decontamination, and the waste to be added to the Mix-Tub thereafter are incompatible, as determined in accordance with 40 CFR Part 264, Appendix V; or (2) The waste removed contains a listed hazardous waste and the waste to be added to the Mix-Tub thereafter is a nonhazardous waste or is a characteristic hazardous waste. (xiii) The Permittee shall comply with Appendix B to Section III of this Permit when decontaminating (I) the Mix-Tub, any equipment used in the solidifying, stabilization, or bulking process (i.e., the backhoe, or excavator, hoses, shovels, etc.), or a roll-off or other containers, or NEICVP1493E01 Appendix A Page 143 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (II) the waste carrying portion of any Transportation Vehicle, including a Vacuum Truck, whose contents have been emptied into the Mix-Tub or transferred to the On-Site Waste Water Treatment Plant or Tank Systems 11 or 14 from the Mix-Tub, Bulk Storage and Transfer Area, or when decontaminating any equipment used in connection with the transfer process. Additional Requirements (xiv) Whenever the Permittee is changing the waste to be solidified, stabilized or bulked in the Mix-Tub, before a new waste is added, the Permittee shall ensure that all wastes are removed from the Mix-Tub and placed into a roll-off container or Transportation Vehicle such that the Mix-Tub is "broom-clean". (xv) The Permittee shall ensure that the bulking of hazardous waste does not result in such waste being treated by dilution. The Permittee shall ensure compliance with 40 CFR 268.3 when bulking hazardous waste. (xvi) The Permittee shall record and maintain in the Operating Record for the Facility the quantity of waste and solidification and stabilization agents placed into the Mix-Tub each day. (xvii) The Permittee shall ensure that when the Mix-Tub is not in use, (when a waste is not being added to, removed from, or mixed in the Mix-Tub), the Mix-Tub is: (I) empty; and (II) covered with a tarp or plastic liner capable of preventing precipitation, snow, and any other weather-related variable from accumulating in the Mix-Tub and of sufficient strength to prevent any tears. (xviii) Before waste is placed into the Mix-Tub for any purpose and while the Mix-Tub is in use, the Permittee shall attach sides or sidepanels that prevent waste from leaving the Mix-Tub. The Permittee may remove such panels when removing waste from the Mix-Tub. (5) MISCELLANEOUS PROCESSING AREAS. The Miscellaneous Processing Areas at the Facility are the Drums Crusher Area, the Acidic and Alkaline Rinse Stations and Lab Pack Pour-off Area. (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the Drum Crusher Area and the Acidic and Alkaline Rinse Stations: (i) The Permittee shall ensure that the rinsing and crushing areas are properly maintained in good working order and do not pose a NEICVP1493E01 Appendix A Page 144 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) (c) (d) NEICVP1493E01 hazard to human health or the environment; (ii) When rinsing and crushing containers the Permittee shall ensure that incompatible waste is not mixed, and these operations do not result in any of the conditions specified in 40 CFR 264.17(b). For purposes of this provision, compatibility shall be determined in accordance with 40 CFR Part 264 Appendix V; (iii) Other than crushed containers, the Permittee shall collect and containerize all waste generated from rinsing and crushing operations, shall characterize such waste in accordance with 40 CFR 262.11 and shall comply with all applicable requirements regarding the management, including disposal, of such waste; and (iv) Other than containers to be rinsed or crushed, as applicable, the Permittee shall not store, keep, or place waste or other materials containers in the areas used for rinsing or crushing containers. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the Acidic and Alkaline Rinse Stations; the Permittee shall not rinse any container that is not empty. Before rinsing containers, the Permittee shall ensure that the container to be rinsed is properly inverted over the water spray nozzle of the rinse station before the water spray is activated. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding the Drum Crusher Area: (i) The Permittee shall not crush any container that is not empty; and (ii) After containers have been crushed in the Drum Crushing Area, the Permittee shall collect and store all of the crushed containers in a covered roll-off container in the Roll-Off Storage Area, Bulk Storage and Transfer Area before shipping such containers offsite. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements regarding pouring off the contents of a lab pack in the Lab Pack Pour-Off Area: (i) The Permittee shall not open a lab pack, unless the lab pack is on a containment pallet and shall not open the containers within a lab pack to be poured off unless such containers are over the Lab Pack Pour-Off sink; (ii) Before any waste or other material from a lab pack is poured off into the On-Site Wastewater Treatment Plant, the Permittee shall ensure that a laboratory chemist at the Permittee's facility has authorized the activity and determined that doing so will not cause any of the reactions specified in 40 CFR 264.17(b). In addition, the Permittee shall ensure that such chemist is available on duty at the Facility when the contents of such lab pack are poured into Appendix A Page 145 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut the On-Site Wastewater Treatment Plant; (iii) The Permittee shall ensure that the contents of a lab pack are: (I) in liquid form only (i.e., no solids or semi-solids); (II) poured off only into the lab pack pour-off sink that goes directly into a tank that is part of the On-Site Wastewater Treatment Plant; and (III) authorized to be added to the On-Site Wastewater Treatment Plant by the discharge permit issued by the Commissioner. (iv) The Permittee shall ensure that all employees performing the lab pack pour-off activities are trained in the use of required personal protective equipment when performing all pour-off activities. At a minimum, personnel shall become familiar with the use of a Tyvek suit, Kevlar and PVC gloves and appropriate respiratory protection as required by the Personnel Training Plan (PTP) incorporated as Attachment C to this Permit (The PTP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit); (v) The Permittee shall ensure that all containers which contents have been poured into the lab pack pour-off sink are empty before the Permittee disposes of any such container. If the container is not empty, the Permittee must treat the waste in any such container as a hazardous waste. The Permittee shall manage, including disposal, all of the empty containers from a lab pack, poured off into the On-site Wastewater Treatment Plant, in accordance with all applicable requirements. (6) TRUCK-TO-TRUCK TRANSFER AREA (TTTA) (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements in the Truck-to-Truck Transfer Area (TTTA): (i) The Permittee shall comply with the requirements of 49 CFR 177.848 regarding all waste or other material in the TTTA; (ii) If not included in the Inspection Plan (IP) incorporated herein as Attachment B to this Permit (The IP needs approval by the Commissioner after submission by the Permittee in accordance with Section V of this Permit), the Permittee's inspection of the TTTA shall include determining if liquid or other material is being released from any Transportation Vehicle in this area; (iii) The Permittee shall visually inspect each container of waste brought to the TTTA from a Container Storage Area or Area to Stage Containers, before placing it on a Transportation Vehicle, to NEICVP1493E01 Appendix A Page 146 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (b) NEICVP1493E01 ensure that each container is closed, not leaking and packaged, labeled and marked as required by 40 CFR 262.30 (Packaging), 262.31 (Labeling) and 262.32 (Marking - "Hazardous Waste" or other designation for non-hazardous waste, with a generic description of the waste, and other relevant information), as applicable and that the labels, marking and packaging correspond to the description of such waste or other materials on the manifest or shipping papers; (iv) The Permittee shall keep all containers in the TTTA closed. The Permittee shall not remove waste or other material from any container and shall not transfer any waste or other material from one container to another container, except if the integrity of a container has been compromised. In that event, the Permittee shall place the compromised container in salvage container or transfer the waste or other material in the compromised container to a container in good condition and that is approved by DOT for waste or other material, as applicable. The Permittee shall manage, including disposal, all waste generated from a container whose integrity of has been comprised, in accordance with all applicable requirements; (v) The Permittee shall ensure that container management equipment, such as a drum cart or a forklift truck, is available for use at all times to allow for quick transfer or movement of containers in the TTTA in the event of an emergency; (vi) The Permittee shall ensure that at no time is there a single container with more than 350 gallons of liquids in the TTTA; and (vii) The Permittee shall comply with the requirements of RCSA 22a209-15(c), 22a-209-15(d) and any other applicable requirement in RCSA 22a-209-15 regarding biomedical waste brought to or transferred in the TTTA. In addition to the other requirements of this Permit, the Permittee shall comply with following requirements in each Truck Bay of the Truck-toTruck Transfer Area: (i) Whenever waste or other materials is present in the Truck-toTruck Transfer Area, the Permittee shall ensure that at all times any Transportation Vehicle in such area can immediately be moved out of the area and, if necessary, a tractor or other auxiliary power unit capable of moving such vehicle is present and available for use at the Facility; and (ii) The Permittee shall ensure that the secondary containment system in the TTTA is: (I) sloped to a sump capable of containing liquids; and (II) capable of preventing the commingling of any wastes, Appendix A Page 147 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut other materials, or liquids from one Truck Bay into another Truck Bay. As part of the secondary containment system in the TTTA, the Permittee shall maintain a containment wall or berm, one (1) foot wide along the entire length of the side of each Truck Bay capable of containing and preventing run-on into and run-off out of the Truck Bay. (7) TRUCK PARKING AREAS (TPA 1 and TPA 3) (a) In addition to the other requirements of this Permit, the Permittee shall comply with following requirements in the Truck Parking Areas: (i) Whenever waste or other materials are present on a Transportation Vehicle or in a roll-off container, the Permittee shall ensure that at all times: (A) such vehicle or roll-off container can immediately be moved out of the area; and (B) a tractor or other auxiliary power unit capable of moving such vehicle or roll-off container into or out of the TPA, is present and available, if necessary, for use at the Facility. (ii) The Permittee shall comply with the requirements of 49 CFR 177.848 regarding all waste or other material in the TPA; (iii) The Permittee shall keep all containers in the TPA closed, shall not add or remove waste or other material, to or from any container, including, but not limited to a roll-off container in the TPA, and shall not transfer any waste or other material from one container to another container, including a roll-off container, except if the integrity of a container has been compromised. In that event, the Permittee shall place the compromised container in a salvage container or transfer the waste or other material in the compromised container, including a roll-off container to a container in good condition and that is approved by DOT for such waste or other material. The Permittee shall manage, including disposal, all waste generated from a container whose integrity of has been comprised, in accordance with this Permit and all applicable requirements; (iv) The Permittee shall ensure that at no time is there a single container with more than 549 gallons of liquids in any Truck Bay, regardless of whether the container is on or is considered to be part of a Transportation Vehicle or a Transportation Vehicle itself is considered to be the container; (v) The Permittee shall ensure that the secondary containment system in the TPA is: NEICVP1493E01 Appendix A Page 148 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (I) sloped to a sump capable of containing liquids; and (II) capable of preventing the commingling of any wastes, other materials, or liquids from one Truck Bay into another Truck Bay. As part of the secondary containment system in the TPA, the Permittee shall maintain a containment wall or berm, one (1) foot wide along the entire length of the side of each Truck Bay capable of containing and preventing run-on into and run-off out of the Truck Bay; (vi) If not provided for in the Inspection Plan (IP) presented herein as Attachment B to this Permit (The IP needs approval by the Commissioner after submission by the Permittee in conformance with the terms of Section V of this Permit), whenever waste or other materials is present in the TPA, the Permittee shall visually inspect such area daily to determine if liquid or other material is being released from a Transportation Vehicle or whether the integrity of any roll-off container has been compromised; and (vii) If waste or other materials is in a roll-off container, the Permittee shall ensure that each roll-off container has a seal or cover (i.e., tarp or plastic liner) capable of preventing precipitation from entering the roll-off. If a roll-off container does contain free draining liquids, the Permittee shall ensure that such liquid is removed within twenty-four (24) hours from the time of discovery or the time the Permittee should have discovered such liquids. (viii) The Permittee shall ensure that container management equipment, such as a drum cart or a forklift truck, is available for use at all times to allow for quick transfer or movement of containers in the TPA in the event of an emergency. NEICVP1493E01 Appendix A Page 149 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX A TO SECTION III ADDITIONAL ITEMS TO BE INCLUDED IN THIRD-PARTY AUDITS At a minimum, in addition to Permit Condition II(A)(44), the following items are to be included in the third-party audits: A. Operational Records: (1) The focus under these items is maintenance, calibration (as appropriate) and continuous operation (or documenting instances of downtime, where appropriate): (i) Caustic air scrubber (including air fan, water pump(s) and caustic metering pump(s); (ii) Toxic gas detectors; and (iii) Waste treatment and tank headspace sensors. (2) Noting any instances of process control automated shutdown failures (high temperature, pH and tank volume). Include a brief narrative of the response actions in each case. (3) Noting any instances of positive detections in any of the toxic gas detectors. Include a brief narrative of the circumstances and response actions taken in each case. (4) Evaluate records with regard to assessing waste compatibility. Noting any anomalies resulting from that program (identification of unexpected waste incompatibility). (5) Recording any instance of spilled materials coming in contact with an incompatible material (if any). B. Rejected Waste Loads. Summarize in a table each instance of a rejected waste load, the reason for the rejection, where the waste originated, type of waste, and ultimate disposition (re-shipped to another location; returned to the generator; revised profile and accepted). C. City of Bristol Fire Chief Visits. Contact the City of Bristol Fire Chief and summarize any concerns raised, if any, with regard to his visits during the evaluation year. D. General Housekeeping: Summarize the following kinds of indicators of general housekeeping found at the time of the audit inspection: (1) Summarize in a table the releases at the Facility: which area; type of vessel involved; cause of release. Group like incidents together. Compare numbers to previous year of records, since this manner of summary was begun. NEICVP1493E01 Appendix A Page 150 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (2) Note any areas of the facility during the visit that are not accessible (when they are supposed to be) and for what reason (if any). (3) Note the general condition of the epoxy floor coatings, painted areas designating storage limits, warning signs. (4) Note any pumps, hoses or other tools or equipment deployed in a work area, but not being used (left unattended). (5) Note the conditions and accessibility of logbooks. (6) Note the condition and general appearance of the laboratory. (7) Note the general appearance and condition of container storage and truck to truck transfer areas. (8) Note the general appearance and condition of secondary containment areas. (9) Take photographs, as appropriate and as allowed by facility policies, to document conditions found. NEICVP1493E01 Appendix A Page 151 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX B TO SECTION III DECONTAMINATION PROCEDURES When Section III of this Permit specifies that decontamination shall be performed in accordance with Appendix B of this Permit, the following shall apply: (I) The Permittee shall begin by ensuring that all waste or other materials are removed from the item undergoing decontamination, such that the item is "empty". For the Mix-Tub, the Permittee shall ensure that all wastes are removed from the Mix-Tub and placed into a roll-off container or Transportation Vehicle such that the Mix-Tub is "broom-clean." (II) The Permittee shall rinse the item being decontaminated with clean water only, unless: (A) Use of clean water is not standard in the industry, in which case the Permittee shall rinse the item being decontaminated using materials that are standard in the industry; or (B) Rinsing with clean water could potentially cause an adverse reaction, such as those specified in 40 CFR 264.17(b) (1) through (5), inclusive, in which case the Permittee shall rinse the item being decontaminated using a material that does not cause any such reaction and is standard in the industry for such rinsing; (III) The Permittee shall ensure that any such decontamination: (A) Meets any applicable standard (e.g., triple rinsing if the item undergoing decontamination held, contained, or was used to transfer an acute hazardous waste); (B) Prevents hazardous waste residues from contaminating non-hazardous waste; and (C) Protects against any harms resulting from incompatible wastes, as determined by 40 CFR Part 264, Appendix V, including any residues in the item being decontaminated; (IV) The Permittee shall ensure that, except as provided for in V(C) of this Appendix, all rinsate from decontamination is (A) Collected in containers; or (B) Transferred, to the On-Site Waste Wastewater Treatment Plant or to Tank Systems 11 or 14, provided the Permittee is authorized to receive such rinsate at the On-Site Wastewater Treatment Plant or Tank Systems 11 or 14. (V) Rinsate from the decontamination of roll-off or other containers, Transportation Vehicles, including any Vacuum Truck that held waste transferred into the Mix-Tub may be placed into the Mix-Tub provided that; (A) The Permittee may add such rinsate to the Mix-Tub only to serve as a reagent for the stabilization of hazardous waste - and for no other purpose (i.e., rinsate cannot be added to waste being solidified or bulked); NEICVP1493E01 Appendix A Page 152 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (B) If there is no waste in the Mix-Tub at the time such rinsate is added to the Mixtub, the Permittee shall remove and collect all such rinsate before adding any waste to the Mix-Tub and all collected rinsate shall be transferred to the On-Site Waste Wastewater Treatment Plant or to Tank Systems 11 or 14, provided the Permittee is authorized to receive such rinsate at the On-Site Wastewater Treatment Plant or Tank Systems 11 or 14; and (C) The Permittee manage all rinsate put into the Mix-Tub as containing all of the wastes removed from the container, roll-off container, or Transportation Vehicle before decontamination, including, but not limited to, all hazardous waste codes; (VI) The Permittee shall ensure that after collection or transfer, all rinsate from decontamination is managed in accordance with all applicable requirements, including, but not limited to, the requirements of this Permit; and (VII) The Permittee shall maintain in the Operating Record for the Facility all documentation used to demonstrate compliance with this provision, including, but not limited to, records regarding compliance with the waste analysis requirements in 40 CFR 262.11 and the land disposal restrictions in 40 CFR Part 268 regarding any waste generated from the decontamination process. (VIII) The Permittee shall collect a sample to verify that the area has been decontaminated. NEICVP1493E01 Appendix A Page 153 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX C TO SECTION III EXAMPLE OF A TANK CLEANING CERTIFICATE NAME: _____________________________________________________ ADDRESS: ___________________________________________________ EPA ID NUMBER: _____________________________________________ TANK CLEANING CERTIFICATE I/We being the person(s) responsible (as indicated by my/our signature(s) below) for the cleaning of the tanks listed below state that I/we have been trained in tank decontamination requirements and procedures, including, but not limited to the decontamination requirements of this Permit regarding decontamination of tanks, and that the decontamination for which I/we have been responsible for is, to the best of my/our knowledge and belief, in compliance with Permit No. DEEP/HWM-017-004 and NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, latest edition. TANK No. TANK WASTE TANK COATED/UNCOATED Number of Continuation Sheet(s): _______ NAME (In block letters): _________________________________________________________ POSITION: _____________________________________________________________________ For and on behalf of: Address: _______________________________________________________________________ Signature: _____________________________________ Date: _____________________________ NEICVP1493E01 Appendix A Page 154 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION IV GENERAL FACILITY CONDITIONS COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 155 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION (A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L) (M) (N) (O) (P) (Q) (R) (S) (T) (U) SECTION IV TABLE OF CONTENTS GENERAL FACILITY CONDITIONS TITLE PAGE Imminent Hazard Actions . . . . . IV-3 Required Transfer Notice . . . . . . IV-3 Waste Analysis . . . . . . . IV-3 Security . . . . . . . . IV-4 General Inspection Requirements . . . . IV-5 Personnel Training . . . . . . IV-5 General Requirements for Ignitable, Reactive or Incompatible Wastes, and/or Other Co-stored Materials . . IV-7 Preparedness and Prevention . . . . . IV-8 Contingency Plan . . . . . . . IV-11 Manifest System . . . . . . . IV-16 Operating Record . . . . . . . IV-17 Availability, Retention and Disposition of Records . . IV-18 Biennial Report . . . . . . . IV-18 Closure . . . . . . . . IV-18 RCRA Corrective Action Requirements . . . . IV-23 Financial Requirements . . . . . . IV-33 Air Emission Requirements - Subpart CC . . . IV-35 Universal Wastes . . . . . . . IV-40 Used Oil . . . . . . . . IV-40 Applicable Laws . . . . . . . IV-40 Location Standards . . . . . . IV-40 NEICVP1493E01 Appendix A Page 156 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION IV GENERAL FACILITY CONDITIONS (A) IMMINENT HAZARD ACTIONS. Notwithstanding any provision of this Permit, enforcement actions may be brought pursuant to Section 7003 of Resource Conservation and Recovery Act (RCRA), Section 22a-6 of the Connecticut General Statutes (CGS), or any other applicable law. (B) REQUIRED TRANSFER NOTICE. In addition to complying with the requirements of Section I (E)(12) of this Permit, prior to transferring ownership or operation of the Facility during its life, the Permittee shall notify the new owner or operator in writing of the requirements of this Permit, 40 CFR 264 and 270, and the Regulations of Connecticut State Agencies (RCSA) Sections 22a-449(c)-100 et. seq. The Permittee shall provide such new owner or operator with a copy of this Permit. The Permittee's failure to notify the new Permittee of the requirements of this Permit in no way relieves the new Permittee of his obligations to comply with all applicable requirements. (C) WASTE ANALYSIS (1) The Permittee shall follow the procedures described in the Waste Analysis Plan, incorporated herein as Attachment A. Such Waste Analysis Plan, at a minimum, shall comply with the requirements of 40 CFR 264.13. In the event of a conflict between any application or submittal made by the Permittee regarding the renewal of this Permit and the terms and conditions of this Permit, the requirements, terms, or conditions of this Permit shall take precedence and apply. (2) The Permittee shall maintain, at all times, an up-to-date copy of the Waste Analysis Plan (WAP) at the Facility in the Operating Records. A copy of any revisions made to the WAP shall be kept in the Facility's Operating Record. Such a plan shall include a protocol or a quality assurance/quality control (QA/QC) laboratory analysis plan for the onsite analysis of waste at the Facility. The QA/QC protocols or plans shall include all information and procedures required by 40 CFR 264.13 to ensure appropriate on-site analysis of waste by the Facility laboratory operations. (3) The Permittee shall maintain generator waste profile sheets, and copies of all records, documents or other information required to demonstrate compliance with the Waste Analysis Plan in the Facility's Operating Record. This specifically includes, but it is not limited to: NEICVP1493E01 Appendix A Page 157 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) Waste characterization, verification and analysis of each hazardous waste stream stored and/or treated at the Facility, as required by this Permit and the Waste Analysis Plan; and (b) Compatibility analyses, as required by the Waste Analysis Plan. (4) The Permittee shall at all times have available for inspection and review by Department or EPA personnel copies of all records, forms, procedural documents, manuals, and any other related documentation, used to achieve compliance with the Waste Analysis Plan and 40 CFR 264.13. (5) Unless otherwise specified in the Waste Analysis Plan, all hazardous waste characterization and analytical work performed in accordance with the Facility Waste Analysis Plan shall be as specified in EPA document SW-846, "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," latest edition. (D) SECURITY (1) Pursuant to 40 CFR 264.14(a), the Permittee shall prevent the unknowing and unauthorized entry of persons, livestock, or other animals into the Facility. (2) The Permittee shall ensure that: (a) All entrances to the Facility are locked at all times unless authorized personnel are present; (b) Access to the Facility is limited to the emergency coordinators, security personnel or other authorized personnel who have received training in accordance with this Permit and all other applicable law; and (c) The warning signs bearing the legend, "Danger-Unauthorized Personnel Keep Out" ; "Danger-Authorized Personnel Only"; and/or "Danger - No Trespassing" shall remain posted on the fence surrounding the Facility, at each entrance to the Facility and at other locations in sufficient numbers to be seen from any approach to the Facility's entrance. Each sign shall be written in English and shall be legible from a distance of at least twenty-five (25) feet. (3) The Permittee shall ensure that the Facility has: (a) A fence in good repair which completely surrounds the Facility and/or the real property on which the Facility is located; and (b) A means to control entry, at all times, through gates or other entrances to the Facility. NEICVP1493E01 Appendix A Page 158 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (4) The Permittee shall maintain all security equipment systems in good repair at all times until Final Closure of the Facility. (5) The Permittee shall maintain any security recording of the facility for at least 12 months or in the event of a noncompliance event at the Facility until the Facility resolves the violations or is in compliance. (E) GENERAL INSPECTION REQUIREMENTS. In addition to any other inspection, requirements specified elsewhere in this Permit, the Permittee shall: (1) Perform inspections of the Facility in accordance with the Facility Inspection Schedule, incorporated herein as Attachment B of this Permit. The Permittee shall maintain the Inspection Plan, approved by the Commissioner, at the Facility at all times. (2) Inspect the Facility for malfunctions and deteriorations, operator errors, and discharges, which may be causing or may lead to: (a) Releases of hazardous waste constituents to the environment, and (b) A threat to human health or the environment. (3) Remedy any deterioration or malfunction of equipment or structure, which an inspection reveals on a schedule which ensures that the problem does not lead to an environmental or human health hazard. Where a hazard is imminent or has already occurred, remedial action shall be taken immediately. (4) Ensure that records of inspections are maintained at the Facility at all times, and contain such information and be on such forms as prescribed by the Facility Inspection Schedule, incorporated herein as Attachment B. The Permittee shall maintain the records pertaining to inspections, remedial actions and repairs resulting from such inspections for at least (3) three years from the date of the inspection. (F) PERSONNEL TRAINING (1) The Permittee shall conduct personnel training as required by 40 CFR 264.16. This training shall comply with the requirements of 40 CFR 264.16, and include training in the elements outlined in the Personnel Training Plan, incorporated herein as Attachment C. The Permittee shall train all Facility personnel in a manner that teaches them to perform their duties and ensures that the Facility remains in compliance with the requirements of this Permit and all applicable regulations. The Permittee shall maintain a copy of the Personnel Training Plan and all records demonstrating compliance with the training requirements of this Permit and applicable regulations at the Facility at all times. NEICVP1493E01 Appendix A Page 159 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (2) The Permittee shall ensure that the personnel training provided to employees at the Facility includes, but is not limited to, the following, if relevant to an employee's position: (a) Implementation of the Facility Contingency Plan (Attachment D); (b) The activities authorized and prohibited by this Permit; (c) The waste prohibitions contained in Section II of this Permit; (d) The high-level alarms and other alarms systems at the Facility; (e) Sampling methods and sample handling procedures required to comply with the requirements of this Permit; (f) The requirements of the Waste Analysis Plan (Attachment A); (g) The hazards associated with and the safe handling practices for all of the wastes or other materials authorized to be managed at the Facility; (h) The selection and use of proper personnel protection equipment and emergency equipment; (i) The marking and labeling requirements of this Permit; (j) Emergency response procedures, including but not limited to, routes of exposure associated with any release, relevant technical information regarding any waste or other materials authorized to be managed at the Waste Management Areas of the Facility and the requirements specified in 40 CFR 264.16(a)(3); (k) The requirements regarding the use of manifests, bills of lading or other required shipping papers; (l) The requirements regarding the management of wastes and other materials relevant to each employee position; and (m) On the job training and instruction given to Facility personnel regarding the safe handling and the management procedures of authorized wastes and other materials managed at the Facility that are relevant to each job position. (3) The Permittee shall ensure that Facility personnel successfully complete the requirements for personnel training and the training requirements of this Permit no later than sixty (60) days after each employee begins their employment or before any assignment to a new Waste Management Area or a new position in the Facility. The Permittee shall ensure that no untrained employees handle, manage or become involved in managing waste and other materials authorized by under this Permit. Employees shall not work in unsupervised positions until they have completed the training requirements of this Permit. (4) The Permittee shall ensure that all Facility personnel receive and successfully complete an annual review of the personnel training within three hundred and sixty-five (365) days of the date that any such personnel received initial training or the previous year's annual review of the training program. NEICVP1493E01 Appendix A Page 160 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (5) The Permittee shall maintain the following documents and/or records in its Operating Record at the Facility: (a) The job title for each position at the Facility related to waste management and the name of the employee filling each position; (b) A written job description for each position listed under Section IV (F)(5)(a) of this Permit. This description shall be consistent with descriptions for other similar positions at the Facility but must include the requisite skill, education or other qualifications, and duties of employees assigned to each position; (c) A written description of the type and duration of both introductory and continuing training that will be given to each person filling a position listed under Section IV (F)(5)(a) of this Permit; and (d) Records documenting that the training or job experience required by 40 CFR 264.16(a), (b) and (c) and as specified in Attachment C (Personnel Training Plan) has been given to, and completed by, Facility personnel or other qualified personnel. (6) The Permittee shall keep training records on current personnel until Final Closure of the Facility. Training records on former employees shall be kept for at least three (3) years from the date the employee last worked at the Facility. (7) The Permittee shall ensure that anyone providing training to Facility personnel shall be trained in hazardous waste management procedures or other relevant procedures (e.g., Hazard Communication) and be thoroughly familiar with the requirements of this Permit. The Permittee shall also ensure that any training provided to Facility personnel includes instruction which teaches Facility personnel waste management procedures relevant to the positions in which they are employed. (G) GENERAL REQUIREMENTS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE WASTE, AND/OR OTHER MATERIALS. The following requirements are in addition to any other requirements specified in this Permit regarding ignitable, reactive, or incompatible waste and other materials. (1) The Permittee shall prevent accidental ignition or reaction of ignitable or reactive waste or other materials at the Facility. At a minimum, the Permittee shall ensure that: (a) Any waste or other material is separated and protected from all sources of ignition or reaction including but not limited to: open flames, smoking, cutting, welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., NEICVP1493E01 Appendix A Page 161 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut from heat producing chemical reactions), radiant heat, and any other condition that could cause the waste or other material to ignite. (b) All cutting, welding or other operations involving open flames performed within the proximity of any ignitable waste has been approved in advance in writing by the designated safety personnel under the direct supervision of the Facility's Emergency Coordinator or Alternate Emergency Coordinator (designee). Such written approval shall be maintained at the location of the activity during the entire time the activity is taking place. (c) No smoking shall be allowed in any Waste Management Area where ignitable or reactive waste or other material is being stored, handled, or otherwise managed. For purposes of this subsection the term "ignitable waste" shall be defined as any substance or material exhibiting the characteristics of ignitability as described in 40 CFR 261.21. (2) The Permittee shall prevent reactions which: (a) Generate extreme heat, pressure, fire, explosions, or violent reactions; (b) Produce uncontrolled toxic mists, fumes, dusts, or gases capable of threatening human health or the environment; (c) Produce uncontrolled flammable fumes or gases capable of posing a risk of fire or explosion; (d) Damage the structural integrity of any Waste Management Area, container, tank, or any emergency equipment; or (e) Through other like means, threaten human health or the environment. (3) The Permittee shall ensure that no smoking or open flames occur wherever there is a hazard from ignitable or reactive wastes or other materials. The Permittee shall prominently display and maintain one or more "No Smoking" signs in each such area. Each "No Smoking" sign shall be legible from a distance of twenty-five (25) feet. (4) The Permittee shall ensure that containers holding ignitable or reactive wastes or other materials shall be located at least fifteen (15) meters or fifty (50 feet) from the Facility property line. (H) PREPAREDNESS AND PREVENTION (1) Design and Operation of Facility (40 CFR 264.31). The Permittee shall maintain and operate the Facility so as to prevent fire, explosion, or any unplanned, sudden or non-sudden, release of waste or waste constituents thereof to or other materials to or from any Waste Management Areas to NEICVP1493E01 Appendix A Page 162 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut air, soil, surface water or ground water. (2) Required Equipment (40 CFR 264.32). The Permittee shall ensure that the emergency equipment specified in the Facility Contingency Plan, incorporated herein as Attachment D, is available and ready for use at all times. The Permittee shall locate all of the emergency equipment as shown or described in the Facility Contingency Plan, and conduct inspections of such equipment in accordance with the Inspection Schedule. The Permittee shall, at a minimum, have at the Facility: (a) An internal communication or alarm system that does not alarm unless there is an actual emergency; (b) A device, such as telephone, capable of summoning emergency assistance from local emergency response teams; (c) Portable fire extinguishers, fire control equipment, spill control and decontamination equipment; and (d) Water at adequate volume and pressure to supply water hose streams, or foam producing equipment that does not contain perfluoroalkyl and polyfluoroalkyl substances (PFAS). (3) Testing and Maintenance of Equipment (40 CFR 264.33) (a) The Permittee shall test and maintain all safety equipment as necessary but at least annually to ensure its proper operation in case of an emergency. (b) The Permittee shall inspect and maintain the equipment in accordance with the manufacturer's recommendations. (c) The Permittee shall ensure that the Facility's communication systems, alarm systems, fire protection equipment, emergency equipment, spill control equipment and decontamination equipment are immediately accessible and operate properly at all times. (d) The Permittee shall inspect and test such equipment in accordance with all applicable laws, regulations, ordinances, and the Facility Inspection Plan, incorporated herein as Attachment B. (e) The Permittee shall maintain in the Operating Record for the Facility written records indicating the date and time of each inspection, the name of the inspector, the results of the testing of the equipment noted in this paragraph, any action(s) taken in response to such testing and the date and nature of any necessary corrective measures. (4) Access to Communication or Alarm System (40 CFR 264.34). The Permittee shall ensure that whenever waste or other material is being moved, sampled, poured, emptied, treated, pumped or otherwise handled at the Facility, all personnel involved have immediate access to an internal alarm or emergency communication device, either directly or through visual or verbal communication with other Facility personnel. If there is NEICVP1493E01 Appendix A Page 163 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ever just one person at the Facility conducting any of these activities, the Permittee shall ensure that this person has immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance. (5) Required Aisle Space (40 CFR 264.35). The Permittee shall maintain aisle space in all Waste Management Areas, especially in the areas designated as Area H, to allow, at all times, the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment to every area of the Facility in case of an emergency. (6) Arrangement with Local Authorities (40 CFR 264.37). (a) Whenever any change occurs in the Facility layout or operation, or in the Facility Contingency Plan itself, which materially affects implementation or execution of such, the Permittee shall, within fifteen (15) days of the approval of a modification to this Permit or within fifteen (15) days of such change if no permit modification is needed, send in an electronic format or by certified mail, return receipt requested, to all police, fire department, hospital and emergency response teams in the vicinity of the Facility, including but not limited to those listed below, the revisions to the Contingency Plan. At a minimum, the Permittee shall notify the following entities: (i) City of Bristol Police Department; (ii) City of Bristol Fire Department; (iii) Bristol Hospital; (iv) City of Bristol Health Department; (v) Capitol Region Emergency Planning Committee (CREPC); and (vi) The Permittee's Emergency Contractors. (7) The Permittee shall ensure that each entity under contract to provide emergency response services at the Facility has a permit, issued by the Commissioner pursuant to Section 22a-454 of the CGS, authorizing such entity to provide emergency response services. The Permittee shall maintain a copy of such permit in the Operating Record for the Facility. (8) The Permittee shall ensure that each entity under contract with the Permittee to provide emergency response service visits the Facility every year to become familiar with the location and be able to respond to an emergency. The Permittee shall ensure that each such entity becomes familiar and maintains familiarity with the Facility Contingency Plan, including any modifications, amendments thereto, approved by the Commissioner. At a minimum, each such entity shall become and maintain familiarity with: NEICVP1493E01 Appendix A Page 164 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) The Facility layout, alarm systems and emergency equipment; (b) The properties of the wastes and other materials which are or may be present at the Facility and the health and environmental hazards associated with all such wastes and other materials; (c) Places where Facility personnel may be located; (d) Entrances to and exits from the Facility; (e) Evacuation routes, from the Facility; and (f) The contacts for all persons or entities that might provide emergency response services at the Facility. The Permittee shall maintain in the Operating Record for the Facility a certification, attested to by each emergency response entity under contract with the Permittee to provide emergency response services, stating that such entity has complied with the requirements specified in this condition of this Permit. (9) The Permittee shall invite the police department, fire department, hospital and governmental emergency response teams listed in Section IV (H)(6) of this Permit to visit the Facility and shall attempt to make arrangements to enable each such entity to respond in the event of an emergency at the Facility. At a minimum, the Permittee shall provide each such entity with information regarding the layout, alarm systems and emergency equipment at the Facility, the wastes and other materials which are or may be at the Facility and the health and environmental hazards associated with all such wastes and other materials, places where Facility personnel may be located, entrances to and exits from the Facility, evacuation routes and the contacts for all persons or entities who might provide emergency response services at the Facility. The Permittee shall maintain in the Operating Record for the Facility records demonstrating compliance with the requirements specified in this condition, including any records it receives in response to actions under this condition. (I) CONTINGENCY PLAN (1) The Permittee shall ensure that the provisions of the Facility Contingency Plan, incorporated herein as Attachment D, are carried out, and shall follow the emergency procedures described below, whenever there is an emergency event such as a fire, explosion, or release of waste or waste constituent(s) thereof or other materials or constituent(s) thereof which threatens human health or the environment. The Permittee shall provide the Facility Contingency Plan in an electronic format to the local Emergency Response Teams that may respond to an emergency at the Facility. (2) Content of the Contingency Plan. The Permittee shall maintain at all times at the Facility, a Contingency Plan which has been approved by the Commissioner, which describes the actions the Facility personnel shall NEICVP1493E01 Appendix A Page 165 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut take in response to an emergency event which threatens or may potentially threaten human health or the environment. At a minimum the Plan shall include: (a) A description of arrangements agreed to by the Police Department, Fire Department, Bristol Hospital, the Permittee's emergency response contractors, and as applicable, federal, state, and local emergency response teams, to coordinate emergency services pursuant to 40 CFR 264.37. (b) An up-to-date list of the names addresses and phone numbers (office, home and cellular as applicable) of all persons qualified to act as emergency coordinators and/or alternate emergency coordinators. Where more than one person is listed, one shall be identified as the primary emergency coordinator and others shall be listed in the order in which they shall assume responsibility as alternates. The Permittee shall ensure that an Emergency Coordinator or an Alternate Coordinator is available and can be contacted by phone at all times in the event of an emergency. (c) An up-to-date list of the emergency equipment at the Facility (such as fire extinguishing systems, spill control equipment, communication, and alarm systems (internal and external) and decontamination equipment). In addition, the plan shall include the location, number, and a physical description of each item on the list, and a brief outline of the capability of each piece of emergency equipment. (d) An evacuation plan for Facility personnel that describes the signal(s) to be used to initiate an evacuation, evacuation routes, and alternate evacuation routes (in cases where the primary routes could be blocked by releases of waste, fire, or explosion); (e) A protocol for determining who will make decisions and remain in charge when responding to an emergency at the site; and (f) An up-to-date inventory of all wastes and other materials on-site. This inventory shall identify the wastes and other materials in each Waste Management Area. (3) The Permittee shall maintain the most recent version of the Contingency Plan, incorporated herein as Attachment D, as approved by the Commissioner, at the Facility at all times. The Emergency Coordinator, alternate Emergency Coordinator(s), and any other personnel responsible for the implementation of the Contingency Plan shall receive copies of the Contingency Plan and all updates to the Contingency Plan and shall be briefed on the implications of any such changes. NEICVP1493E01 Appendix A Page 166 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (4) Amendment of the Contingency Plan. (a) The Permittee shall immediately amend the Contingency Plan, in accordance with the permit modification procedures specified in Section I (E)(6) of this Permit whenever: (i) The Contingency Plan fails in an emergency; (ii) The Facility changes in its design, operation, or maintenance, or changes the response measures which must be taken in an emergency; (iii) A modification to the list of emergency coordinators is necessary; or (iv) A modification to the list of emergency equipment is necessary. (b) The Contingency Plan changes specified in Section IV (I)(4)(a) of this Permit are mandatory. However, the Permittee may submit to the Department, in writing, a request to make any other changes to the Contingency Plan. These requested modifications should be submitted with an application, accompanied by the appropriate fee, for a permit modification. (5) In accordance with 40 CFR 264.55, the Permittee shall ensure that at all times there shall be at least one employee either on the Facility premises or on call (i.e., available to respond to an emergency event by reaching the Facility within a short period of time), with the responsibility for coordinating all emergency response measures. This Emergency Coordinator or Alternate Emergency Coordinator shall be thoroughly familiar with all aspects of the Facility's Contingency Plan, all operations and activities at the Facility, internal Facility alarms or communication systems, the location and characteristics of waste and other materials, the location of all records within the Facility, and the Facility layout. In addition, the Emergency Coordinator or Alternate Emergency Coordinator shall have the authority to commit the resources needed to implement the Contingency Plan. The Permittee shall ensure that the generator waste profile sheets, material survey forms, prequalification information, waste characterization data, laboratory analysis sheets, Safety Data Sheets (SDSs), manifests, bills of lading and/or shipping papers are available to the Emergency Coordinator or designee on a twenty-four (24) hour-a-day, seven (7) day-a-week basis. (6) Emergency Procedures. (a) Whenever there is an imminent or actual emergency event, the Emergency Coordinator or Alternate Emergency Coordinator shall immediately: NEICVP1493E01 Appendix A Page 167 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (i) Activate internal Facility alarms or communication systems, where applicable, to notify all Facility personnel of an emergency situation; and (ii) Notify appropriate state or local agencies and/or private emergency response providers with designated response roles. (b) Whenever there is an emergency event (release, fire, or explosion), the Emergency Coordinator or Alternate Emergency Coordinator shall immediately identify the character, location, source, amount and extent of any waste, other materials, or any constituent(s) thereof, which have been or may have been released. The Emergency Coordinator or Alternate Emergency Coordinator may do this by observation, review of Facility records, and, if necessary, by chemical analysis. (c) Concurrently, the Emergency Coordinator or Alternate Emergency Coordinator shall assess possible hazards to human health or the environment that may result from the emergency. This assessment shall consider both direct and indirect effects of the emergency (e.g., the effects of any toxic, irritating or asphyxiating gases that are generated or the effects of any hazardous surface water run-off from water or chemical agents used to control fire and heat-induced explosions). (d) If the Emergency Coordinator or Alternate Emergency Coordinator determines that the Facility has had an emergency that threatens or may potentially threaten human health or the environment, the Emergency Coordinator on behalf of the Permittee shall report his findings as follows: (i) The Permittee shall immediately notify the Commissioner using the 24-hour emergency response and spill prevention number (860) 424-3338, or a toll free number such as 1-866337-7745 or such other number that may be specified by the Commissioner, and provide orally to the Commissioner the information specified in Section IV(I)(6)(d)(iii) of this Permit; and (ii) As required by federal law, the Permittee shall notify either the government official designated as the on-scene coordinator for that geographical area (in the applicable regional contingency plan under 40 CFR 1510) or the National Response Center using their 24-hour toll free number 1-800-424-8802. The notification shall include: NEICVP1493E01 Appendix A Page 168 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (1) Name and telephone number of reporters; (2) Name and address of Facility; (3) Time and type of incident (e.g., release, fire explosion); (4) Name and quantity of waste(s) or constituent(s) thereof involved, to the extent known; (5) The extent of injuries, if any; and (6) The possible hazards to human health or the environment. (iii) If the Emergency Coordinator's assessment indicates that evacuation of local areas (surrounding businesses and residences) may be advisable, the local and state authorities shall be immediately notified. The Emergency Coordinator or Alternate Emergency Coordinator shall be available to assist local and state officials in deciding whether local areas should be evacuated; Once the decision is made to evacuate surrounding businesses and residences, the Emergency Coordinator or Alternate Emergency Coordinator shall ensure the following: (1) The surrounding businesses and residences are notified in the order specified in the Facility Contingency Plan; and (2) All notifications to the surrounding businesses and residences are completed within fifteen (15) minutes of contacting the Dispatcher Services; (e) During an emergency, the Emergency Coordinator or Alternate Emergency Coordinator shall take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, re-occur, or spread. These measures shall include stopping operations, collecting, and containing any released wastes, other materials, or any constituent(s) thereof and removing or isolating containers or vehicles. (f) If operations are suspended in response to an emergency, the Emergency Coordinator or Alternate Emergency Coordinator shall monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, containers, or other equipment, where and when appropriate. (g) Immediately after an emergency, the Emergency Coordinator or Alternate Emergency Coordinator shall provide the assistance necessary to the emergency responders for recovering and either NEICVP1493E01 Appendix A Page 169 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut storing or disposing of recovered waste, other materials, or any constituent(s) including contaminated soil, surface water or any other material that results from a release, fire, or explosion at the Facility. (h) The Emergency Coordinator or Alternate Emergency Coordinator shall ensure that, in the affected area(s) of the Facility: (i) No waste that may be incompatible with any recovered waste, contaminated soil, surface water or any other material that results from a release is stored or disposed of until cleanup procedures are completed; and (ii) All emergency equipment listed in the Facility Contingency Plan is replenished or cleaned and fit for its intended use before operations are resumed. (i) The Permittee shall notify the Commissioner, as well as state and local authorities, that the Facility complies with Section IV (I)(6)(h) of this Permit, before resuming any operations at the Facility. (j) The Permittee shall note in the Operating Record the time, date and details of any incident that requires implementing the Contingency Plan. Within fifteen (15) calendar days after the incident, the Permittee shall submit a written report on the incident to the Commissioner. The report shall include: (i) Name, address, and telephone number of the Permittee; (ii) Name, address, and telephone number of the Facility; (iii) Date, time, and type of incident (e.g., fire, explosion); (iv) Description of the emergency and its cause; (v) Name and quantity of waste or constituent(s) thereof involved; (vi) The extent of injuries, if any; (vii) An assessment of actual or potential hazards to human health or the environment, where this is applicable; (viii) Estimated quantity and disposition of recovered material that resulted from the incident and all response actions taken or to be taken; (ix) All corrective measures taken or to be taken in response to the incident; and (x) All corrective measures taken or to be taken to ensure that the incident does not happen again. (J) MANIFEST SYSTEM. Whenever a shipment of hazardous of waste is received at the Facility or initiated from the Facility, the Permittee shall comply with the applicable requirements of Sections of 22a-449(c)-100 through 119 and 22a- NEICVP1493E01 Appendix A Page 170 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 449(c)-11 of the RCSA, the requirements of 40 CFR 262, and the applicable sections of 40 CFR 264 Subpart E, regarding hazardous waste manifests. (K) OPERATING RECORD. The Permittee shall maintain, in writing or in an electronic record that can be easily accessed or reproduced upon request by the Commissioner, the following information in the Facility's Operating Record until Final Closure of the Facility: (1) A description and the quantity of each waste and other material received, and the method(s) and date(s) of its storage, treatment, and disposition at the Facility, as required by 40 CFR 264, Appendix I; (2) A record of the wastes and other materials received into each Waste Management Area including the dates such wastes and other materials were received, the quantities and the dates such wastes and other materials were removed from each Waste Management Area; (3) A record of the location and quantity of each waste and other material previously and currently stored, treated or managed at the Facility. This information shall include cross-references to specific manifest or other document tracking numbers if the waste or other material was accompanied by a manifest or other shipping paper numbers; (4) Records and/or results of waste analyses performed as specified in the Waste Analysis Plan and 40 CFR 264.13, 40 CFR 268.4(a) and 40 CFR 268.7; (5) Summary reports and details of all incidents that require implementing the Facility Contingency Plan, as specified in Section IV (I)(6)(j) of this Permit; (6) Records and results of inspections required by this Permit and the Inspection Schedule, incorporated herein as Attachment B. The records and results of such inspections shall be kept for three (3) years from the date of any such inspection; (7) Monitoring, testing or analytical data and corrective action where required by 40 CFR 264 Subpart F or any regulatory section noted in 40 CFR 264.73(b)(6); (8) The latest closure cost estimate prepared in accordance with 40 CFR 264.142(a) and (c) and, when this estimate has been adjusted in accordance with 40 CFR 264.142(b), the latest adjusted closure cost estimate; (9) A certification by the Permittee that it has a program in place (i.e., in accordance with the biennial hazardous waste report requirement), to reduce the volume and toxicity of hazardous waste to the degree NEICVP1493E01 Appendix A Page 171 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut determined by the Permittee to be economically practicable, and the proposed method of treatment, storage or disposal currently available to the Permittee, which minimizes any threat to human health and the environment; (10) A Copy of all notices and/or certifications, the information contained in the notice (except the manifest number) and the certification and demonstration, if applicable, required by 40 CFR 268.7, and/or 40 CFR 268.8 prior to shipping any waste to an off-site Permitted Facility; and (11) Any other information required by this Permit or by any applicable law to be maintained in the Facility Operating Record (e.g., copies of each biennial report). (L) AVAILABILITY, RETENTION, AND DISPOSITION OF RECORDS (1) The Permittee shall ensure that all records required under Sections 22a-449(c)-100 to 119 of the RCSA, and this Permit, including all plans, are furnished upon request, and made available at all reasonable times for inspection to any officer, employee, or representative of the Department of Energy and Environmental Protection (DEEP) or EPA. (2) The retention period for all records required under Sections 22a-449(c)-100 to 119 of the RCSA and this Permit shall automatically be extended during the course of any unresolved enforcement action regarding the facility until such enforcement action is fully resolved or for any reasonable period of time as may be requested by the Commissioner. Any exemption from this requirement shall require the written approval of the Commissioner. (M) BIENNIAL REPORT. The Permittee shall prepare and submit a biennial report to the Commissioner by March 1st of each even numbered year regarding waste activities at the Facility for the previous calendar year on a form prescribed by the Commissioner. In addition, the Permittee shall provide any other information that the Commissioner specifies relating to the activities at the Facility. The Permittee shall comply with all the requirements of 40 CFR 264.75. (N) CLOSURE (1) Closure performance standard. The Permittee shall close the Facility in a manner that: (a) Minimizes the need for further maintenance; (b) Controls, minimizes or eliminates, to the extent necessary to protect human health and the environment, the escape of waste, other materials, and constituents, thereof including leachate, contaminated run-off or waste decomposition products to the soil, NEICVP1493E01 Appendix A Page 172 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut groundwater or surface water or to the atmosphere; and (c) Complies with the closure requirements of Section 22a-449(c)-104 of the RCSA, any applicable portions of 40 CFR 264, Subparts G (Applicable to Closure), and requirements in 40 CFR 264, Subparts I, J, L and X, the CT DEEP "RCRA Closure Plan Guidance" document and the Closure Plan, incorporated herein as Attachment E. (2) Closure Plan. The Permittee's Closure Plan shall contain all the information specified in 40 CFR 264.112(b), except that wherever the word "hazardous waste" is used in 40 CFR 264.112(b), it shall mean "waste" and "other materials" as those terms are defined in this Permit and where the term "hazardous waste management unit" is used in 40 CFR 264.112(b), it shall mean "Waste Management Unit" as that term is defined in this Permit and shall also include the waste pile formerly used at the property where the Facility is located. (a) Written Plan. The Permittee shall have a written Closure Plan, Attachment E of this Permit presents a copy of the most recent Closure Plan. A copy of the Permittee's most current plan shall be kept at the Facility until final closure is completed and certified in accordance with Section IV (N)(7) of this Permit. A copy of the most current Closure Plan shall be furnished to the Commissioner upon request and shall be provided during any inspection, to any officer, employee, or representative of the DEEP or EPA. (b) Content of the Plan. The Closure Plan shall identify steps necessary to perform partial and/or final closure of the Facility. The Closure Plan, at a minimum, shall include the following: (i) A description of how each Waste Management Unit and the waste pile formerly used at the property where the Facility is located shall be closed in accordance with 40 CFR 264.111; (ii) An estimate of the maximum inventory of wastes onsite at the Facility and a detailed description of the methods to be used during partial closure and/or final closure, including methods for removing, transporting, and disposing of all wastes and other materials; (iii) A detailed description of the steps needed to remove or decontaminate all residues from waste and other materials and contaminated containment system components, equipment, structures, and soils during partial and/or final closure, including procedures for cleaning equipment and removing contaminated soils, methods for sampling and testing surrounding soils, groundwater or other environmental media and criteria for determining the extent of decontamination required to satisfy the closure NEICVP1493E01 Appendix A Page 173 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut performance standard; (iv) A detailed description of other activities necessary during the closure period to ensure that all partial closures and final closure satisfy the closure performance standards; and (v) A schedule for closure of each Waste Management Unit and the waste pile formerly used at the property where the Facility is located and an approximate year for final closure of the Facility. (c) Amendment of the Closure Plan (1) The Permittee shall submit an application, accompanied by the appropriate fee, to the Commissioner to request a permit modification to amend the Closure Plan at any time prior to the notification of partial or final closure of the Facility. A copy of the proposed amended plan shall be included with the application. If changes are made, the Permittee shall maintain a summary of changes identifying the differences from the Closure Plan that was issued with this Permit. (2) The Permittee shall submit an application to the Commissioner for a permit modification to authorize a change in the Closure Plan for the Facility whenever: (i) There is a change in operating plans or Facility design affecting the Closure Plan; (ii) There is a change in the expected year of closure; (iii) In conducting partial or final closure activities, unexpected events occur requiring a modification of the Closure Plan; or (iv) New or additional information becomes known which requires a modification of the Closure Plan. (3) The Permittee shall submit an application for a permit modification to the Commissioner, including a copy of the proposed amended Closure Plan, for approval at least sixty (60) calendar days prior to the proposed change in Facility design or operation, or no later than sixty (60) calendar days after an unexpected event has occurred which has affected the Closure Plan. This requirement to amend the Closure Plan is in addition to and shall not relieve the Permittee of its obligation to comply with the permit modification procedures specified in Section I (E)(6) of this Permit regarding any changes in an operating plan for or design of the Facility. If an unexpected event occurs during the Partial or Final Closure Period, the Permittee shall submit a proposed amendment to the Commissioner no NEICVP1493E01 Appendix A Page 174 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut later than thirty (30) calendar days after the unexpected event. Any such proposed amendment shall constitute and be treated as a request to amend this Permit and shall require the submission of an application, accompanied by the appropriate fee, to, modify this Permit. (4) The Commissioner may request modifications to the Closure Plan under the conditions described in Section IV (N)(2)(c) of this Permit. If such a request is made before the Permittee's Closure Plan has been modified by the Commissioner pursuant to Section IV (N)(2)(c) of this Permit, the Permittee shall make the requested modifications within sixty (60) calendar days of the Commissioner's request, or within thirty (30) calendar days if an unexpected event occurs during Partial or Final closure. If an unexpected event occurs during the partial or final closure period, the Permittee shall submit a proposed amendment to the Closure Plan to the Commissioner no later than thirty (30) calendar days after the unexpected event. Any such proposed amendment shall constitute and be treated as a request to amend this Permit and shall require the submission of an application, accompanied by the appropriate fee, to modify this Permit. (d) Notification of Partial Closure and/or Final Closure of the Regulated Waste Management Area(s). (i) The Permittee shall notify the Commissioner in writing at least forty-five (45) calendar days prior to the date it expects to begin either partial or final closure of the Facility and submit the Closure Plan for the Facility to the Commissioner with such notice. The date when the Permittee "expects to begin closure" shall be not later than thirty (30) calendar days after the date on which any Waste Management Area receives the known final volume of hazardous wastes, or if there is a reasonable possibility that the Waste Management Area will receive additional hazardous wastes, no later than one year after the date on which such area receives the final volume of wastes. (ii) If the Facility's permit is terminated, or if the Facility is otherwise ordered, by judicial decree or final administrative order requiring the Permittee, to cease receiving wastes or to close, then the requirements of notification of Partial Closure and/or Final Closure does not apply. However, the Permittee shall close the Facility in accordance with the deadlines established in 40 CFR 264.113. NEICVP1493E01 Appendix A Page 175 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (3) Disposal or decontamination of equipment, structures, and soils. Within ninety (90) calendar days of the approval of the Permittee's Closure Plan, or ninety (90) calendar days after receiving the final volume of waste at the Facility or a Waste Management Area, whichever is later, the Permittee shall properly decontaminate or remove from the Waste Management Area(s) or Facility, all waste and other materials, as applicable, in accordance with the Closure Plan approved by the Commissioner and all applicable requirements of Sections 22a-449(c)-100 through 119 of the RCSA. The Commissioner may approve a longer period for closure if the Permittee demonstrates to the Commissioner's satisfaction that the activities required to comply with the requirements of the approved Closure Plan will take longer than ninety (90) calendar days to complete and that the Permittee has taken and will continue to take all steps needed to prevent threats to human health and the environment and will comply with any additional conditions deemed necessary by the Commissioner arising from the Partial or Final Closure. Any such demonstration shall be made at least thirty (30) calendar days before the expiration of the ninety (90) calendar days period in Section IV (N)(3) of this Permit. (4) Prior to beginning closure activities of the Facility, the Permittee shall submit to the Commissioner for review and final approval a revised Closure Plan that complies with the CT DEEP (formerly DEP) RCRA Closure Plan Guidance, as amended. (5) Time allowed for closure. The Permittee shall complete Partial and/or Final Closure activities, as applicable, in accordance with the Closure Plan approved by the Commissioner within one-hundred-eighty (180) calendar days after such approval or within one-hundred-eighty (180) calendar days after receiving the final volume of waste at the Facility or a Waste Management Area, as applicable. The Commissioner may approve a longer period for closure if the Permittee demonstrates to the Commissioner's satisfaction that the activities required to comply with the approved Closure Plan will by necessity take longer than one-hundredeighty (180) calendar days to complete and that the Permittee has taken and will continue to take all steps needed to prevent threats to human health and the environment and will comply with any additional conditions deemed necessary by the Commissioner arising from the Partial or Final Closure. Any such demonstration shall be made at least thirty (30) calendar days before the expiration of the one-hundred-eighty (180) calendar days period in Section IV (N)(5) of this Permit. (6) The Permittee shall manage all waste generated during Partial or Final Closure in accordance with all applicable statutes and regulations. NEICVP1493E01 Appendix A Page 176 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (7) Certification of closure. Within sixty (60) calendar days of the completion of Partial Closure or Final Closure of the Facility or any Waste Management Area, as applicable, the Permittee shall submit to the Commissioner by registered mail, a certification signed by both the Permittee and by an independent, registered professional engineer, licensed to practice in the state of Connecticut ("licensed P.E."), stating that the Waste Management Area or the Facility, as applicable, has been closed in accordance with the Closure Plan approved by the Commissioner. Documentation supporting the independent, registered professional engineer's certification shall be furnished to the Commissioner upon request, until the Commissioner releases the Permittee from the financial assurance requirements for closure under Section IV (P)(5) of this Permit. (O) RCRA CORRECTIVE ACTION REQUIREMENTS (1) Performance of Corrective Action. The Permittee shall perform site-wide corrective action in accordance with the requirements of this Permit, the Remedial Action Plan submitted and approved pursuant to section IV (O)(2)(a) of this Permit and any other plan(s) submitted and approved pursuant to this Permit. The conditions of this section apply to: (a) Any AOC discovered during the course of corrective action, characterization, groundwater monitoring, field investigations, environmental audits or other means (As used in this Permit, the terms "discover," "discovery," or "discovered" refer to the date on which the Permittee either: (i) visually observes evidence of a new AOC, (ii) visually observes evidence of a previously unidentified release of hazardous constituents thereof to the environment, (iii) receives information which suggests the presence of a new release of waste, other material or constituents thereof to the environment, or (iv) receives information which suggests the presence of a previously undocumented release of waste, other materials or constituents thereof to the environment), and (b) Contamination that has migrated or may migrate beyond the Facility boundary, whereas necessary to protect human health and the environment. The Permittee shall implement corrective action beyond the Facility boundary where necessary to protect human health and the environment consistent with 40 CFR 264.101(c), unless the Permittee demonstrates, to the satisfaction of the Commissioner, that despite the Permittee's best efforts, as determined by the NEICVP1493E01 Appendix A Page 177 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Commissioner, the Permittee was unable to obtain the necessary permission to undertake such actions. The Permittee is not relieved of all responsibility to clean up a release that has migrated beyond the Facility boundary where off-site access is denied. Onsite measures to address such releases will be determined on a case-by-case basis. A mechanism for financial assurance for completion of such off-site corrective action must be provided by the Permittee to the satisfaction of the Commissioner. (2) Schedule/Scope of Work. The Permittee shall submit schedule(s)/scope(s) of work for further investigation and remediation of releases of waste. Other materials and constituents thereof at or from the Facility such that the remediation will achieve compliance with the Remediation Standard Regulations (RSRs). Such schedule(s) and scope(s) of work shall include, at a minimum, a schedule for development and implementation of the following plans and/or reports. (a) Remedial Action Plan (RAP). The Permittee shall prepare and submit for the Commissioner's review and written approval one or more RAP(s) and associated cost estimates, developed in accordance with Section IV (O)(13) of this Permit (Financial Responsibility for RCRA Corrective Action) and Sections 22a449(c)-104(a)(1) and 22a-133k-1 et. seq. of the RCSA (RSRs), incorporating 40 CFR 264 Subpart G, which details the steps to be taken to perform corrective action. The RAP(s) shall address each environmental media at the entire property on which the Facility is located, or area affected by or any portion thereof and shall include: (i) Descriptions of the areas at which the remediation will take place identifying the Solid Waste Management Units (SWMUs) and AOCs addressed and the environmental media being remediated; (ii) Descriptions of the remedial alternatives considered for performing the specified remediation and the most expeditious schedule for performing each alternative; (iii) The proposed preferred alternative with supporting justification therefore; (iv) A proposed, detailed implementation plan and schedule to perform the preferred remedial actions, including the generation and collection of information needed to support completion of remedial design. Such schedule shall include a schedule for applying for and obtaining all permits and approvals required for such remedial actions and describe the establishment of a mechanism for financial assurance for each proposed phase of remedial activity; (v) Identify the data gaps and describe the rationale used for determining whether (1) no further investigation is required, NEICVP1493E01 Appendix A Page 178 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut or (2) additional investigation is necessary to fill any significant data gaps. If additional investigation is needed, the Permittee shall include a plan for the implementation of such investigations and submission of a report summarizing the findings; and (vi) Identify all areas exceeding any remedial criteria and a proposal for the additional characterization data needed to complete the remedial design in order to achieve compliance with RSR criteria for polluted soil, surface water and groundwater; or any other environmental media; and a proposed implementation plan and schedule addressing such areas of contamination. Any RAP proposing monitored natural attenuation as the selected remedy for groundwater migrating off-site shall include: (1) an evaluation of the need for source mitigation to achieve compliance with the RSRs; (2) a monitoring and data evaluation plan designed to evaluate the remedy performance; and (3) a contingency remedy conceptual approach in the event that monitored natural attenuation does not perform as anticipated and a schedule for implementation. (b) Quality Assurance Project Plan. The Permittee shall prepare and submit for the Commissioner's review and written approval a Quality Assurance Project Plan, prepared in accordance with the document titled: Quality Assurance Guidance for Conducting Brownfield Site Assessments, US Environmental Protection Agency OSWER Directive No. 9230.0-83P and incorporating Connecticut's Reasonable Confidence Protocols. The Permittee shall ensure that the data used to comply with the corrective action requirements of this Permit is scientifically valid and defensible, with a level of precision, accuracy, and sensitivity commensurate with its intended use. (3) Ecological Risk Assessment ("ERA"). Pursuant to Section 22a-133k-2(i) of the RCSA, the Permittee shall prepare and submit for the Commissioner's review and written approval an Ecological Risk Assessment evaluating the potential for ecological receptors to be exposed to contaminants and describing measures to ensure that any remedial goals and objectives address protection for those receptors from existing or potential contaminant exposures. (4) Notification and Assessment Requirements for Newly Identified AOCs. The Permittee shall notify the Commissioner in writing, within fifteen (15) calendar days of discovery, of any new suspected or confirmed AOCs as discovered under Section IV (O)(1)(b) of this Permit. Such notification shall include, at a minimum, the following information: NEICVP1493E01 Appendix A Page 179 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (a) Location of the AOC on a topographic map of appropriate scale (such as required under 40 CFR 270.14(b) (19)); (b) Designation of the type and function of the AOC; (c) General dimensions, capacities, and structural description of the AOC (supply any available plans/drawings); (d) The date that the AOC operated, if known; (e) Specifications of all wastes or other materials that have been managed at/in the AOC, to the extent available. Include any available data on waste or other material or constituents thereof; and (f) All available information (groundwater, soil, soil gas, sediment, air and/or surface water data) pertaining to any release of waste, other materials, or constituents from such AOC. (5) Notification Requirements for Newly Discovered Releases from AOCs. (a) The Permittee shall notify the Commissioner in writing of any newly discovered release(s) of waste, other materials or constituents thereof discovered during the course of characterization, groundwater monitoring, field investigations, environmental audits, or other means, within fifteen (15) calendar days of discovery. Such newly discovered release(s) may be from any location on the property in which the Facility is located including but not limited to, AOCs identified in Section IV (O)(1)(b) of this Permit or AOCs previously identified for which it had been determined that further investigation was not required. (b) If the Commissioner determines that further investigation of any AOC is needed, the Permittee shall be required to prepare a plan for such investigation within thirty (30) calendar days of written notification by the Commissioner. (6) Interim Measures (IM) (a) Work Plan (i) Upon written notification by the Commissioner, the Permittee shall prepare and submit an Interim Measures (IM) Work Plan for any AOC that the Commissioner determines is necessary in order to minimize or prevent the further migration of contaminants, thereby limiting current and future potential for human and environmental exposure to contaminants while long-term corrective action remedies are evaluated and, if necessary, implemented to meet the requirements of the RSRs. NEICVP1493E01 Appendix A Page 180 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The IM Work Plan shall be submitted within sixty (60) calendar days of such notification and shall include the elements listed in Section IV (O)(6)(a)(iii) of this Permit. Such interim measures may be conducted concurrently with investigations required by this Permit. (ii) The Permittee may initiate IM at an AOC by submitting the appropriate notification pursuant to this Permit. The Commissioner will process Permittee initiated IM by either conditionally approving the IM or imposing an IM Work Plan per Section IV (O)(6)(a)(i) of this Permit. The Permittee initiated IM shall be considered conditionally approved unless the Commissioner specifically imposes an IM Work Plan within thirty (30) calendar days of receipt of notification of the Permittee initiated IM. The scope and success of Permittee initiated IM conditionally approved shall be subject to subsequent in-depth review. The Commissioner will either comment on or approve the Permittee initiated IM. The Permittee initiated IM shall follow the progress and final reporting requirements in Section IV (O)(6)(c) of this Permit. (iii) The IM Work Plan shall ensure that the interim measures are designed to mitigate any current or potential threat(s) to human health or the environment and are consistent with and integrated into any long-term solution at the Facility. The IM Work Plan shall include: the interim measure's objectives, procedures for implementation (including any designs, plans and/or specifications) and schedules for implementation. (b) IM Implementation (i) The Permittee shall implement the IM under Section IV (O) (6)(a)(i) of this Permit in accordance with the approved IM Work Plan. (ii) The Permittee shall give notice to the Commissioner within seven (7) calendar days of any planned changes, reductions or additions to the IM Work Plan required under Section IV (O)(6)(a)(ii) of this Permit. (c) IM Reports (i) If the time required for completion of interim measures required under Section IV (O)(6)(a)(i) of this Permit or implemented under Section IV(O)(6)(a)(ii) of this Permit is greater than one (1) year, the Permittee shall provide the Commissioner with progress reports at intervals specified in NEICVP1493E01 Appendix A Page 181 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut the approved IM Work Plan or annually for Permittee initiated interim measures. The Progress Reports shall contain, at a minimum, the following information: (A) A description of the portion of the interim measures completed; (B) Summaries of the findings; (C) Summaries of any deviations from the IM Work Plan during the reporting period; (D) Summaries of any problems or potential problems encountered during the reporting period; and (E) Projected work for the next reporting period. (ii) The Permittee shall prepare and submit to the Commissioner, within ninety (90) calendar days of completion of interim measures and receipt of validated analytical data conducted under Section IV (O)(6) of this Permit (IM Reports). Such report shall contain, at a minimum, the following information: (A) A description of the interim measures implemented; (B) Summaries of results, including any data gaps; (C) Summaries of all problems encountered; (D) Summaries of accomplishments and/or effectiveness of interim measures; and (E) Copies of all relevant laboratory/monitoring data obtained in accordance with this Permit. (7) Remedy Selection and Notification of Remediation Implementation (a) The Permittee shall propose a remedy or evaluate one or more remediation alternatives, if necessary, to meet the criteria in the RSRs. The Commissioner may require that specific remediation alternatives be evaluated. All remedial alternatives shall meet the threshold and balancing criteria specified below. Threshold Criteria: (i) Protect human health and the environment; (ii) Achieve media cleanup objectives using the RSRs; and (iii) Control sources of releases to reduce or eliminate further releases. Balancing Criteria: (i) Long-term effectiveness; (ii) Toxicity, mobility, and volume reduction; NEICVP1493E01 Appendix A Page 182 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iii) Short-term effectiveness; (iv) Implementability; (v) Cost; (vi) Community acceptance; and (vii) State acceptance. The proposed remedy may include any Interim Measures (IM) implemented to date. (b) The Commissioner shall select and approve the remedy to be implemented at the entire or portion of the property where the Facility is located. The Commissioner is not confined to those alternatives evaluated by the Permittee when selecting and approving a remedy. (8) Public Participation Plan. The Permittee shall prepare and submit for the Commissioner's review and written approval a Public Participation Plan. Such plan shall, at a minimum, comply with the public participation requirements of the RSRs and shall include: (a) The development of a mailing list that at a minimum includes: The Chief Elected Official(s), Fire Chief, Chief of Police, State Representative(s), and Senator(s) that represent the City of Bristol, community organizations, and the adjacent property owners. (b) A provision for notifying the owners and/or occupants of the properties, at least thirty (30) calendar days prior to the start or completion of remediation work or when there is a significant change in the environmental conditions of the site or area(s) affected by the property on which the Facility is located. (c) A provision for notifying the owners and/or occupants of any additional properties identified by the US EPA or the DEEP to be within the area in which the groundwater can reasonably be expected to become polluted as the result of any pollution emanating from the property on which the Facility is located. (d) A proposal for providing semi-annual written updates via a letter, newsletter, or any other means to the mailing list regarding the status of corrective action and all areas affected by the property on which the Facility is located. (e) A public notice prior to the start of or completion of remedial activities at the property on which the Facility is located or areas affected by the property on which the Facility is located or any portion thereof consistent with Section IV (O)(9) of this Permit. (f) The submittal of a copy of such notice to the Commissioner ten (10) NEICVP1493E01 Appendix A Page 183 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut calendar days prior to the date of the publication; and (g) The submittal of a written summary of all comments received and responses thirty (30) calendar days after the end of the comment period. The Permittee shall submit a revised Public Participation Plan sixty (60) calendar days after the installation of any future remediation treatment and control system or any significant change in conditions on the property on which the Facility is located The Commissioner shall review the summary of the comments in response to the public notice and the Permittee's responses and shall either adopt the responses, adopt the responses with modifications or reject the responses and prepare a response to each comment. In the event of substantial changes in the remedial approach, the Commissioner may require an additional opportunity for public comment with respect to such changes. (9) Public Notice Requirements. The Permittee shall provide public notice of any proposed remediation and the Commissioner `s tentative determination that site-wide remediation of the Hazardous Waste Management Unit(s) and the area formerly used as a waste pile is complete. Each public notice shall provide a forty-five (45) calendar day comment period and indicate that a public information meeting will be held within thirty (30) calendar days from the date of the public notice. (a) Prior to the commencement of any proposed remedial action, the public notice shall summarize the investigations undertaken, the results of the investigations, clearly identify the proposed remedial activities and include an address and telephone number for a contact person. The Permittee shall: (i) Publish the notice in a newspaper having substantial circulation in the municipality in which the property on which the Facility is located, or the affected area is located; (ii) Broadcast the notice on a radio station during the highvolume listening times on the same day the notice is published; (iii) Provide a copy of the notice to the Chief Elected Official(s) and the Health Director in Bristol; (iv) Provide a copy of the notice to the owner or operator of the property on which the Facility is located (if the Permittee is no longer the owner or operator) and to all persons on the Facility mailing list maintained pursuant to 40 CFR NEICVP1493E01 Appendix A Page 184 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 124.10(c)(1)(ix); and (v) Erect and maintain a sign at least six (6) feet by four (4) feet for at least thirty (30) calendar days in a legible condition at the Facility, clearly visible from the street and including the words "ENVIRONMENTAL CLEAN-UP IN PROGRESS AT THIS SITE. FOR FURTHER INFORMATION CONTACT: and a telephone number at which any interested person may obtain additional information about the remediation." (b) Prior to the Commissioner's final determination that site-wide remediation of any Hazardous Waste Management Area including the area formerly used as a waste pile, is complete, the Permittee shall: (i) Publish the notice in a newspaper having substantial circulation in the municipality in which the property on which the Facility is located, or the affected area is located; (ii) Broadcast the notice on a radio station during the highvolume listening times on the same day the notice is published; (iii) Provide a copy of the notice to all persons on the Facility mailing list maintained pursuant to 40 CFR 124.10(c)(1)(ix); and (iv) Include a summary of the basis for the Commissioner's determination. (c) Upon the completion of the public comment period, the Commissioner shall make a final determination. If the final determination is that the remediation is complete, then a Certificate of Completion shall be issued by the Commissioner to the Permittee. (10) Implementation of Remedial Activities. The Permittee shall perform all remediation activities for soil, groundwater, surface water and any other environmental media in accordance with the RAP(s) approved by the Commissioner, any schedules contained therein and the RSRs. (11) Completion of Active Remediation (a) The Permittee shall notify the Commissioner in writing at least ninety (90) calendar days prior to the date it expects to complete the active remedial activity(ies) at the property on which the Facility is located or area affected by the property on which the Facility is located or any portion thereof. (b) Within sixty (60) calendar days after the completion of the active remediation, the Permittee shall submit to the Commissioner via NEICVP1493E01 Appendix A Page 185 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut registered mail, a certification signed by the Permittee and by an independent, registered professional engineer stating that the active remediation phase(s) at the property on which the Facility is located or areas affected by the property on which the Facility is located or any portion thereof has been completed in accordance with the specifications of the approved RAP(s). Documentation supporting the certification shall be furnished upon the Commissioner's request. (12) Miscellaneous. For any substances reported at or emanating from the property on which the Facility is located, for which no remediation criteria has been adopted, the Permittee shall, in accordance with the RSRs, submit for the Commissioner's review and written approval a proposal for additional remediation. (13) Financial Responsibility for RCRA Corrective Action (a) Cost Estimate. The Permittee shall submit for the Commissioner's review a detailed RAP that includes a detailed written estimate of the current cost to perform investigation and remediation of the site. The Permittee shall ensure that such written estimate is prepared in accordance with Section 22a-449(c)-104 of the RCSA, incorporating 40 CFR 264.142(a) and 40 CFR 264.144(a), as applicable. A fifteen percent (15%) contingency shall be applied to the estimate for unforeseeable elements or events which may increase the cost of performing corrective action. (b) The Permittee shall establish and continuously maintain financial assurance for corrective action using one or more of the instrument formats for such. Such assurance may be established incrementally, if so, approved by the Commissioner. (c) Inflationary Adjustments. The Permittee shall adjust the cost estimate for corrective action to reflect inflationary costs as required by Section 22a-449(c)-104 of the RCSA, incorporating 40 CFR 264.142, and any factors that bear on the cost of performing the work that remains to be completed under this Permit. Adjustments shall be made each year, on the anniversary of the establishment of the mechanisms(s) for financial assurance until the Commissioner releases the Permittee from the financial assurance requirements of this Permit. The Permittee shall ensure that the mechanism established for financial assurance for corrective action is sufficiently funded to cover the most recent adjustment of the cost estimate for corrective action. The latest adjusted cost estimate shall be kept at the Facility and a signed original shall be submitted to the Commissioner within NEICVP1493E01 Appendix A Page 186 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut fourteen (14) calendar days of preparation. (d) Periodic Reductions. Upon request by the Permittee, the Commissioner may approve periodic reductions in the amount of financial assurance commensurate with the completion of corrective action activities. Such request shall include a revised cost estimate and demonstration of completed work activities which equates to at least a fifteen percent (15%) reduction in the most recent cost estimate for corrective action. (e) Maintenance of Financial Assurance. The Permittee shall maintain one or more mechanisms for financial assurances for corrective action in effect until the Commissioner notifies the Permittee in writing that it is no longer required to maintain such a mechanism for financial assurance, as provided for in Section IV(O)(13)(f) of this Permit. (f) Release of Financial Assurance. Provided the corrective action requirements of this Permit have been satisfied, within sixty (60) calendar days after receiving certification, submitted pursuant to Section IV (O)(11)(b) of this Permit, that remedial activities have been completed in accordance with the approved RAP, the Commissioner will notify the Permittee in writing that either it is no longer required to maintain financial assurance for remedial activities, or that the Commissioner has reason to believe that the remedial activities have not been performed and/or completed in accordance with the approved RAP. The Commissioner shall provide the Permittee with a detailed written statement of any such reason(s) to believe that the remedial activities have not been performed and/or completed in accordance with the approved plan. (P) FINANCIAL REQUIREMENTS (1) The Permittee shall prepare and maintain at the Facility, pursuant to 40 CFR 264.142, a written estimate of the current cost of closing the Facility in accordance with the approved Closure Plan. (2) The Permittee shall adjust the cost estimate for closing the Facility to reflect inflationary costs as required by 40 CFR 264.142(b). The adjustment shall be made each year on the anniversary of the establishment of the mechanism(s) of financial assurance for closure until the Commissioner releases the Permittee from the financial assurance requirements of this Permit in accordance with Section IV (P)(5) of this Permit. The Permittee shall maintain the latest adjusted closure cost estimate in the operating record for the Facility and a signed original shall be submitted to the Director of the Waste Engineering and Enforcement Division, Bureau of Materials Management and Compliance Assurance, NEICVP1493E01 Appendix A Page 187 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CT DEEP, 79 Elm Street, Hartford, Connecticut 06106. A fifteen percent (15%) contingency shall be applied to the estimate for unforeseeable elements or events which may increase in the cost of performing closure. (3) The Permittee shall revise the closure cost estimate whenever Partial Closure of the Facility or any Waste Management Area has been completed or there is a change in the Closure Plan that will affect the cost of closure. Any revised closure cost estimate shall then be adjusted for inflation as specified in Section IV (P)(2) of this Permit. (4) The Permittee shall establish and continuously maintain financial assurance for the Facility using one or more of the methods specified in 40 CFR 264.143(a)-(f). The Permittee shall maintain such financial assurance in effect until the Commissioner notifies the Permittee in writing that it is no longer required to maintain such financial assurance in accordance with 40 CFR 264.143(i). (5) Release of the Permittee from the requirements of Financial Assurance (40 CFR 264.143(i)). Within sixty (60) calendar days after receiving certification from the Permittee that final closure of the Facility has been completed in accordance with the approved Closure Plan, the Commissioner will notify the Permittee in writing that either the Permittee is no longer required to maintain financial assurance for closure of the Facility, or that the Commissioner has reason to believe that Final Closure has not been completed in accordance with the approved Closure Plan. The Commissioner shall provide the Permittee with a detailed written statement of any such reason to believe that closure has not been in accordance with the approved Closure Plan. The Permittee shall maintain the financial assurance required by Section IV (P)(4) of this Permit in effect until the Commissioner notifies the Permittee in writing that it is no longer required to maintain such financial assurance. (6) Liability Requirements (40 CFR 264.147(a): Coverage for Sudden Accidental Occurrences). The Permittee shall establish and continuously maintain liability coverage for sudden accidental occurrences at the Facility in the amounts and in accordance with 40 CFR 264.147(a). The liability coverage shall be in the amount of at least $1 million per occurrence with an annual aggregate of at least $2 million, exclusive of legal costs. The Permittee shall ensure that the wording of any instrument used for the purposes of compliance with this Section of this Permit is identical to the wording specified in 40 CFR 264.151, as modified by Section 22a-449(c)-104(a)(2) of the RCSA. The Permittee shall maintain such liability coverage in effect until the Commissioner notifies the Permittee in writing that the Permittee is no longer required to maintain such coverage, as is provided for in Section 22a-449(c)-104(a)(1) of the RCSA, incorporating 40 CFR 264.147(e). NEICVP1493E01 Appendix A Page 188 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (7) Liability Period of Coverage (40 CFR 264.147(e)). Within sixty (60) calendar days after receiving certification from the Permittee that Final Closure of the Facility has been completed in accordance with the approved Closure Plan, the Commissioner will notify the Permittee in writing either that the Permittee is no longer required to maintain liability coverage for the Facility, or that the Commissioner has reason to believe that final closure has not been in accordance with the approved Closure Plan. The Commissioner shall provide the Permittee with a detailed written statement of any such reason for belief that closure has not been in accordance with the approved Closure Plan. The Permittee shall maintain in effect the liability coverage required by Section IV (P)(6) of this Permit until the Commissioner notifies the Permittee in writing that maintaining such coverage is no longer required. (8) The Permittee shall comply with the requirements specified in 40 CFR 264.148 in the event of incapacity of the Permittee, guarantors, or financial institutions. (Q) AIR EMISSION REQUIREMENTS - 40 CFR 264 SUBPART CC (AIR EMISSION STANDARDS FOR TANKS AND CONTAINERS) (A) General (1) The Permittee shall comply with all applicable requirements of 40 CFR 264.1080 through 264.1090, regarding air emission standards for containers and tanks units handling hazardous waste. All containers units no exempt from 40 CFR Part 264, Subpart CC, shall be managed using Level 1, Level 2, or Level 3 control as appropriate. (2) The Permittee must control air pollutant emissions from the container having a design capacity greater than 0.1 m3 in accordance with Level 3 control during the waste stabilization process as defined in 40 CFR 264.1081, when the hazardous waste in the container is exposed to the atmosphere. (B) Waste Determination. The Permittee shall determine the average VO concentration of: (1) generated hazardous waste at the point of origination, (2) treated hazardous waste, in accordance with the procedures specified in 40 CFR 264.1083. The Permittee must determine the maximum organic vapor pressure of a hazardous waste. (C) Containers (1) Requirements for Level 1 Containers Standards The Permittee shall manage hazardous waste with a VO NEICVP1493E01 Appendix A Page 189 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 concentration of 500 parts per million and greater by weight (ppmw) in containers with Container Level 1 standards as specified in 40 CFR 264.1086(c). The hazardous waste stored in Level 1 containers must meet the following requirements: a. Unless all containers are treated as Level 2 containers, they must be stored in a separate area or clearly marked to avoid potential mix-up with the Level 2 containers. b. Containers with a design capacity equal to or greater than 0.46 m3 (122 gallons) shall not be used in light material service as defined in 40 CFR 264.1081. c. The Permittee shall ensure that all level 1 container shall comply with one of the following: i. Applicable U.S. Department of Transportation (DOT) regulations as specified in 40 CFR 264.1086(f)); ii. Be equipped with a cover and closure devices with an acceptable tightness and construction materials in accordance with 40 CFR 264.1086(c)(1); or iii. Be an open-top container with organic vapor suppressing barrier to prevent hazardous waste from being exposed to the atmosphere as specified in 40 CFR 264.1086(c)(1). d. Containers that do not meet the DOT regulations as specified in 40 CFR 264.1086(f) shall be equipped with covers and closure devices suitable for the physical and chemical characteristics of hazardous waste in containers, for maintaining container integrity throughout the life of the container, and the environments under which the containers are placed in the Facility. Any chemical used for vapor suppression shall not generate heat and/or fume and shall be compatible with the hazardous waste in the container. Vapor suppression chemicals shall act as an acceptable and stable barrier to the hazardous waste, thus preventing release of volatile organics into the environment. The barrier shall not chemically react to the hazardous waste as required by 40 CFR 264.1086(c)(2). e. The Permittee shall ensure that all covers, and closure devices on Level 1 container are in closed position whenever hazardous waste is in a container. Opening of a closure device or cover is allowed if it meets the purposes Appendix A Page 190 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut and operates as provided for in 40 CFR 264.1086(c)(3). f. The Permittee shall inspect and repair all Level 1 containers, their covers and closure devices in accordance with 40 CFR 264.1086(c)(4). (2) Requirements for Level 2 Containers Standards a. Containers with a design capacity greater than 0.46 m3 (122 gallons) and in light material service as defined in 40 CFR 264.1081 must be managed in accordance with Container Level 2 standards as required by 40 CFR 264.1086(d). The Permittee shall ensure that all Level 2 Containers comply with one of the following: i. Applicable U.S. DOT regulations as specified in 40 CFR 264.1086(f); ii. Operate with no detectable organic emissions as defined in 40 CFR 264.1081 and determined in accordance with the procedure specified in 40 CFR 264.1086(g); or iii. Be vapor tight as demonstrated within the preceding 12 months by using 40 CFR Part 60, Appendix A, Method 27 in accordance with the procedures specified in 40 CFR 264.1086(d(1)(iii). b. Transfer of hazardous waste in or out of a Level 2 container shall be conducted using an engineered method generally accepted and practiced by the industry, or its equivalent method to minimize the release of organics into the atmosphere as specified in 40 CFR 264.1086(d)(2). c. The Permittee shall ensure that all cover and closure devices on Level 2 containers shall be in closed position whenever hazardous waste is in a container. Opening of a closure device or cover is allowed if it meets the purposes and operates as provided in 40 CFR 264.1086(d)(3). d. Inspection: The Permittee shall inspect and repair all Level 2 containers, their covers and closure devices in accordance with 40 CFR 264.1086(d)(4). (3) Requirements for Level 3 Containers Standards a. A container using Level 3 controls shall meet the standards NEICVP1493E01 Appendix A Page 191 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut specified in 40 CFR 264.1086(e) and be one of the following: i. A container that is vented inside an enclosure which is exhausted through a closed-vent system to a control device, designed and operated in accordance with the requirements of 40 CFR 264.1087, or ii. A container that is vented inside an enclosure which is exhausted through a closed-vent system to a control device. The container enclosure shall be designed and operated in accordance with the criteria for a permanent total enclosure as specified in "Procedure T-Criteria for and Verification of a Permanent or Temporary Total Enclosure" under 40 CFR (52.741, Appendix B). The control device shall be designed and operated in accordance with the requirements of 40 CFR 264.1087. b. The Permittee shall ensure that the cover of the Level 3 container remains closed and secured at all times. c. The Permittee shall ensure that collected air stream from the organic capturing system or the closed-vent system of a Level 3 container is vented directly to the control device (carbon adsorption) and shall be designed and operated as specified in 40 CFR 264.1087. d. The Permittee shall inspect and monitor the closed-vent system and the control device of all Level 3 containers, as specified in 40 CFR 264.1087. e. The Permittee shall prepare and maintain the records as specified in 40 CFR 264.1089(d). f. The Permittee shall ensure that the transfer of hazardous waste in or out of a Level 3 container shall be conducted using an engineered method generally accepted and practiced by the industry, or its equivalent method to the extent practical, to minimize the release of organic pollutants into the atmosphere as required by 40 CFR 264.1086(e)(6). (4) The Permittee is not authorized to treat any hazardous waste in any container at the Facility. (5) An empty container, as defined in 40 CFR 261.7(b), may be open NEICVP1493E01 Appendix A Page 192 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut to the atmosphere at any time. a. The Permittee shall ensure that in the case when discrete quantities or batches of waste or other materials are removed from a container, in compliance with the terms and conditions of this Permit, but the container does not meet the conditions to be an empty container as defined in 40 CFR 261.7(b), the Permittee shall promptly secure the closure devices in the closed position and install covers upon the completion of a batch removal after which no additional waste or other materials shall be removed from the container within 15 minutes or the person performing the unloading operation leaves the immediate vicinity of the container, whichever condition occurs first. b. The Permittee shall open a safety device at any time conditions require doing so to avoid an unsafe condition. (6) Containers and Tank Exempt from Subpart CC Control Standards a. Under this permit, the Permittee must demonstrate by direct measurement or method that before use is approved by the Commissioner that for each container and tank the Permittee claims to be exempt under Subpart CC, the average VO concentration for hazardous waste, determined in accordance with 264.1083(a) and 265.1084(a)(2) and (3), is less than 500 ppmw. b. For each tank or container, the Permittee must review and update this determination in accordance with 264.1082(c)(1) at least once every 12 months following the date of the initial determination. For each container or tank, the Permittee shall prepare and maintain the records described in 264.1089(f). These records must be maintained as part of the operating record. (D) Tanks 11 and 14. The Permittee is prohibited from placing and shall NOT place any waste or other materials with a VO concentration of 500 parts per million and greater by weight (ppmw) in any tank at the Facility regulated by this Permit. (E) Miscellaneous (1) Roll-off Containers. NEICVP1493E01 Appendix A Page 193 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut a. The Permittee shall ensure that the capture efficiency of organic emissions from handling and storage of waste or other materials in the roll-off containers at the Facility complies with the following: i. When a roll-off container is not transferring solids or it is not actively receiving solids, it shall be properly covered; ii. Any roll-off container into which solids are placed shall be properly covered when it is not receiving wastes. (R) UNIVERSAL WASTES. The Permittee shall comply with all applicable requirements in Section 22a-449(c)-113 of the RCSA. (S) USED OIL. The Permittee shall comply with all applicable requirements in Section 22a-449(c)-119 of the RCSA. (T) APPLICABLE LAWS. Even if not specified in this Permit, the Permittee shall comply with all applicable federal, state, and local Laws. (U) LOCATION STANDARDS. The Permittee shall ensure that the Facility complies with the requirements of 40 CFR 264.18. If the Permittee determines that the Facility does not comply with these requirements, the Permittee shall immediately notify the Commissioner in writing who, based upon such notification, may take whatever action is deemed appropriate. NEICVP1493E01 Appendix A Page 194 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION V COMPLIANCE SCHEDULE COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 195 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION V COMPLIANCE SCHEDULE All documentation that is submitted pursuant to conditions of Section V of this Compliance Schedule shall be approved in writing by the Commissioner or the Commissioner's designee. If any item in this schedule cannot be met, the Permittee shall submit a 14-day written notification prior to the due date to the Department stating the reason for the delay with an alternate schedule to comply with the requirement. (1) Revised RCRA Hazardous Waste Part A Permit Application. On or before thirty (30) calendar days after issuance of this Permit, the Permittee shall submit for review and written approval by the Commissioner, a revised Part A Permit Application to incorporate the following comments: (a) The following wastes codes listed on page 3a-4, item 11, Description of Hazardous Wastes are not permitted at the Facility per Section II of the Permit. These wastes codes are: U002. U003, U007, U031, U037, U069, U112, U128, U136, U140, U144, U154, U161, U65, U169, U196, U220, and U239. Please be advised that any waste codes listed in the Part A and is not permitted for the Facility (See Section II of this Permit) shall be included in the Corrective Action Plan as a constituent of concern for remediation purposes. Please revise accordingly to minimize any future concerns. (b) Page 3 of 4, lists the following wastes codes: U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U092, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U112, U114, U116, U119, U120, U122, U126, however these wastes codes are not listed in Item 9 that starts on page 5 of 6. Please include these waste codes in Item 9. (c) The former Waste Pile or "S03" unit with a historical location at the formerly Spill Control is currently designated as the BULA. This location needs to remain listed in the Part A as an "S03" unit until it has been closed through a RCRA closure and certification process. Clean Harbors may add a comment on section 13, page 6 of 6, of the Part A, describing the historical background of the Waste Pile unit or "S03" at the Site. The S03 unit shall be shown in the Closure Plan Site Plan. Please revise the pages accordingly or Clean Harbors can initiate the formal RCRA closure of this unit to remove it from the Part A. (d) The Permittee shall revise the Process Codes and Design Capacities listed in Item 7 and 8, of the Part A to agree with the Permitted Activities and volume capacities of this Permit. For example, Tank Treatment should be a "TO4" process code with a capacity of 14,952 gallons, also the unite measure of "Y/Day' is not a valid unit of measure per the units listed in item C, Treatment. NEICVP1493E01 Appendix A Page 196 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (2) Waste Analysis Plan (hereinafter "WAP"). On or before forty-five (45) days after issuance of this Permit, the Permittee shall submit for review and written approval, a revised WAP addressing the comments below. To help in the preparation and revisions of the WAP, consult the EPA Guidance Document titled: Waste Analysis at Facilities that Generate, Treat, Store and Dispose of Hazardous Waste, dated April 2015, EPA document 530-R-12-001 (https://www.epa.gov/hwgenerators/guidance-manual-wasteanalysis-facilities-generate-treat-store-and-dispose-hazardous or https://www.epa.gov/sites/production/files/2015-04/documents/tsdf-wap-guide-final.pdf (select the appropriate URL). This manual includes WAP examples and provide guidance on how the WAP information should be presented along with key documentation areas on conducting waste analysis at TSDF facilities. (a) It appears that the WAP submitted with the application, dated revised 2/01/2017, is from the expired permit (DEP/HWM-017-004). The information presented in the plan is outdated containing numerous discrepancies. Please revise the WAP to address the content and organization to demonstrate compliance with the RCRA requirements of 40 CFR 264 and, the permitted activities of this Permit. In addition, revise the header to delete the old permit number and revise the page number in the footer by removing the numerical roman number "VI" to create consistency with the facility plans. As a suggestion, Page WAP-## could be more suitable pagination method. (b) As an overall comment, any Sampling Manuals and Standard Operating Procedures that is used in the WAP shall be included as Appendices. For example, the Quality Assurance/Quality Control (QA/AC) Plan shall be standalone Appendix in the WAP. (c) Please remove any duplicate information that exists elsewhere in the permit application (e.g., basic facility description) that are not pertinent to the WAP. Please delete, item 1.1.3, Description of Waste Management Areas, page VI-4 to page VI-10. The secondary containment description, volume capacity and activities description are not requirements of a WAP. (d) Page VI-1, item 1.1.1, Facility Processes and Activities, waste management process activity number 5, Special Wastes, shall be revised to comply with the solid waste definition and hazardous waste definition as "Special Wastes". The Department does not consider Lab Pack Container or Lab Pack, and RCRA-empty containers to be a special waste. In addition, Section I, of this Permit, defines "Other Material" or "Other Materials" that includes a variety of commercial chemicals. Special wastes as listed on pages VI-1, VI-3, VI-9, VI-28, VI-29, VI30, and other pages of the WAP are inaccurate. The Permittee shall remove the "Special Wastes" designation and shall align these items with the permitted hazardous waste activities of Section II of this Permit. (e) Page VI-1, item 1.1.1, Facility Processes and Activities, waste management process number 8, Other Activities. It was brought to our attention that Clean Harbors is co-storing DEA wastes in the Container Storage Area Building. Please NEICVP1493E01 Appendix A Page 197 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut provide a description of the nature of these wastes, how this type of waste is received and managed at the facility; and subsequent reshipment off-site. Also, provide the handling/storage requirements and procedures for this waste. (f) Page VI-1, item 1.1.1, Facility Processes and Activities, waste management process number 8, Other Activities. For the Disassembly of Used Electronics, what are the operating procedures for the handling of the dusts that are accumulated and collected from this operation? Please provide a copy of the operating procedures. This waste stream should be included as part of the Facility's Re-Evaluation Frequency for On-site Generated Wastes, an updated/revised plan shall be submitted. (g) Page VI-3, under the list of Hazardous Wastes. A clarification statement shall be included for the appropriate use of the waste code "D003" as defined in Section II of this Permit. Also, the metal hydroxide sludge "listing" shall be removed from the non-hazardous waste category. The metal hydroxide sludge should be categorized as a hazardous waste. (h) Page VI-10, item 1.2. Waste Analysis Parameters, subsection 1.2.2, Parameter Selection Process, states that "the selection of the waste analysis parameters is based on a review of generator-supplied information". However, the parameters in the Generator Waste Material Profile Sheet (GWMPS) do not match the parameters listed in this section of the WAP. Also, other discrepancies can be found in the listed supplemental testing parameters. However, the basis for the selection of the waste analysis parameters were not provided in the rationale section. It should be noted that the "volatile organic screen" for incoming bulk loads; item No. 10, Distillation, and the GC/MS Scan are not testing parameters. Also, the "specific gravity testing parameter" is missing in this section, it is required parameter and should be listed in the GWMPS. Please revise this section to accurately represent the rationale used for the selection of the parameters for the waste streams handled at the Facility. (i) Page IV-19, Sampling Equipment, states that "See Appendix I-11 for description of sampling equipment"; however, the information presented in Appendix I-11 present pages with cost/quote information from vendors, does not provide an understanding/rationale behind why a particular equipment is utilized at the Facility beyond cost. Please update this section in a readable format. The update should include the rationale/criteria that it is used in the selection of the appropriate equipment for the appropriate liquid or solid sampling scenarios. The rationale should be tailored for use at the Bristol Facility. Provide the updated information that demonstrates the applicability to the sampling equipment being selected for liquid and solid samples. Also, under "sampling solids" it is stated that the minimum required sample volume is 50 ml, also, revise the volume unit to a weight unit. NEICVP1493E01 Appendix A Page 198 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (j) Page VI-19, item 1.3.4, Sampling Preservation and Storage, and Page VI-32, item 1.6.2, both items states that the waste shall be analyzed "within five (5) days from the date the waste arrived at the facility" The sampling time frame provided are not acceptable, all sample waste shall be analyzed immediately upon arrival to confirm waste code and compatibility. Please revise accordingly. (k) Table 1.3, Sample Preservation and Storage, included on page IV-19, should either be a standalone Table or incorporated into the Table Section with the other Tabulated Information. (l) On Page IV-22, item 1.3.5, Sampling Quality Assurance/Quality Control (QA/QC) Procedures. It is stated that "appropriate QA/QC procedures" are followed. The QA/QC Procedures utilized by any laboratory shall be included as an Appendix to the WAP. Please, ensure that all the QA/QC procedures for each analytical procedure used are clearly identified. (m) On Page VI-24, Table 1.4, Testing and Analytical Methods, should either be a standalone Table or incorporate into the Table Section with the other Tabulated Information. In addition, there are some test methods missing from the table. These methods include Total Halogens; Paint Filter test; PCB; viscosity; Total Petroleum Organics (TPH); Total Organic Carbon (TOC); and the screening for volatile organics using the PID. These methods should be included in the revised Table. (n) On Page VI-27, item 1.5 Waste Re-Evaluation Frequencies, (waste streams received from off-site) states that "if the analysis reveals a change, a new waste code shall be provided, and the original code made inactive." Provide the procedures used to notify the off-site facility(ies) of changes in waste characterization. (o) On Page VI-27, Re-Evaluation Frequency for On-site Generated Wastes, there is a line item for Personal Protective Equipment (PPE) waste stream that notes on an annual frequency for reevaluation and the required demonstration of "process knowledge." What are the site-specific criteria used for the PPE waste reevaluation? Please provide the procedures and any site-specific criteria used in this evaluation. Also, are the PPE waste treated on-site prior to off-site disposal? (p) On Page VI-27, item 1.6 Special Procedural Requirements, second paragraph there is a line that states "The Central Profile Group (CPG) manages prequalification activities and maintains all necessary associated documentation" Has the CPG been trained in the types of wastes that can be accepted at the facility and the requirements of this Permit? Also, where is the CPG located in the hierarchy of the operations at the Bristol Facility? The Personnel Training Plan does not reference the CPG. Please provide information on the CPG's role in the waste streams prequalification and the management of wastes at the Bristol Facility. NEICVP1493E01 Appendix A Page 199 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut At a minimum, provide the following documentation or records regarding the CPG: (i) The training and documentation that has been provided on what wastes can be accepted and the Permit Conditions for the Bristol Facility. (ii) Information on how the CPG manages and maintains waste streams prequalification; and (iii) The hierarchy for the CPG in the waste acceptance process at the Bristol Facility. (q) On Page VI-28, there are several references to "prohibited waste code listed in Section II of the RCRA Part B Permit (Appendix 1-8)," however, Section II of this Permit does not have an Appendix 1-8. Please remove these inconsistencies. (r) On Page VI-28, under the Special Wastes headings, line 1, states that the generator shall complete and submit a GWMPS along with supporting documentation such as laboratory analyses ...". There seems to be a disconnect between this and the information presented on page VI-1, item 5, Special Wastes. For example, "(g) containers of hardened solids or highly viscous wastes, which cannot be sampled as "(h) RCRA empty containers as defined in 40 CFR 261.7"; explain the reasons and provide the rationale for the need to have a generator submit a GWMPS for empty containers. (i) Please be aware, that the Facility is only permitted to accept empty aerosol cans, with a maximum of 32 ounces capacity. (ii) On page VI-3, under Solid wastes received from off-site facilities include "asbestos containing materials and biomedical wastes and scrap metal" and on page VI-29, these wastes streams are considered Special Wastes along with pesticides and herbicides; isocyanates; off-specification commercial chemical products; and contaminated commercial products, etc. Please address these waste streams acceptance, characterization, verification and fingerprinting so that they are in accordance with the permitted activities described in Section II of this Permit. (s) On Page VI-33, item 1.6.3, Procedures for Ignitable, Reactive and Incompatible Wastes, states that "wastes are subject to ... evaluation ...based on the procedures delineated in the April 1994 TSDF WAP Guidance Document" please update this reference and use the April 2015 guidance (link provided above) for the evaluation. (t) On Page VI-36, item 1.6.7, RCRA Air Requirements, this paragraph should be revised to indicate that organic concentrations greater than 500 ppm are applicable for container storage only. Tank storage of organic concentrations greater than 500 ppmw are prohibited at the Facility because the tanks are not NEICVP1493E01 Appendix A Page 200 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut equipped with the appropriate air emission controls devices. In addition, Attachment I, Process Design and Operating Criteria of the permit renewal application does not include procedures to ensure compliance with BB and CC. Please include these compliances procedures as an Appendix to this WAP and the Inspection Plan. In addition, include the testing procedures in place to ensure that VO in excess of 500 ppmw are not stored in Tank 14 or commingle with other wastes streams in the Mix-Tub. (u) On page VI-36, item 1.6.8, Receiving and Handling Paint Waste from the PaintCare Program, states that "Upon arrival at the Facility the driver ... will check with the Facility's Compliance Guard to verify shipment information" but Appendix 8-1, Employee Development Record, and Appendix 8-3, Job Descriptions do not include a "Facility's Compliance Guard" as an employee at the Facility. Please address and correct the deficiency and inconsistency accordingly. (v) On Page VI-35, Table 1.1, Offsite Waste Characterization; and on page VI-36, Table 1.2, Waste Verification, indicates that BTU Value Testing is not conducted for any of the waste streams. However, the WAP narrative, page VI-15, Supplemental Testing Parameters states that BTU Value determines the heat value of the waste for fuel blending. There is a disconnect between the Tables and the narrative. Please correct this discrepancy/inconsistency. (x) On Page VI-35, Table 1.1, Offsite Waste Characterization; and on page VI-36, Table 1.2, Waste Verification, it is presented that testing for pesticides & herbicides (Endrin, Lindane, methocychlor, toxaphene, 2,4-D, 2,4,5-TP (Silvex), Chlordane, heptachlor (and its epoxide) is conducted for all the waste streams but it does not match the narrative in the WAP. Please explain and correct this discrepancy. (y) Table 1.1, Offsite Waste Characterization; and Table 1.2, Waste Verification, contains numerous testing inconsistencies that will require revisions. These revisions are for a better understanding of the waste sampling protocol at the Facility. For example, PCB's are being tested for hazardous constituents, but the concentrations of the PCB's are not tested. The concentration level of the PCB's can trigger compliance with TSCA requirements. The PCB's waste characterization and verification procedures should be revised, and a copy of the updated procedure should be incorporated into the updated WAP. (z) Appendix I-2, Outside Lab Chain of Custody Form, presents an Analytical Request Chain of Custody for Belmont Labs, located at 25 Holiday Drive, Englewood, Ohio, Is this laboratory a certified Connecticut Laboratory? (aa) Appendix I-3, Bulk Load QC Form, and Appendix I-4, Pre-acceptance Record Form are very similar in contents. Provide an explanation/clarification on the use/purpose of each form. NEICVP1493E01 Appendix A Page 201 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (bb) Appendix I-5, CHCI Vehicle Off-Loading Authorization Form (VOAF) has a heading of "Driver must check in with Compliance Guard (or shift manager after hours). A review of Appendix 8-3, Job Descriptions, of the Personnel Training Plan does not include a position and description of a "Compliance Guard" employee at the Bristol Facility nor does the Facility Description for a position and description of a "shift manager after hours." Please revise Appendix I-5 (VOAF) to include the correct information pertaining to the Bristol Facility. The Permittee shall ensure the employee positions are accurate and are properly crossreferenced in the all forms used at the Bristol Facility. (cc) Appendix I-6, Waste Receiving Report is dated 12/21/2005. Please submit a copy of the most current example of a waste receiving report being used for the Bristol Facility. Please note that Hazard Class 4.1, flammable solids are prohibited at the Bristol Facility. (dd) Appendix 1-8, Permitted Waste Codes - These codes shall be removed in its entirety from the WAP. The discrepancies with the Waste Codes are too numerous to list here. The Waste Codes that can be accepted at the Facility are listed in Section II of this Permit. (ee) There is a major deficiency in the WAP on how the Land Disposal Restrictions (LDR) requirements (40 CFR 268) are applied to the Mix-Tub waste streams that are either received from off-site and/or generated from this operation as well as with other wastes generated at the Facility. The WAP shall be revised to clearly demonstrate the procedures for the evaluation, sampling (including number of samples, type of samples (grab or composite), criteria used in its selection, etc.) testing, treatment performance, etc. Please refer to the April 2015, WAP guidance document to address this requirement. (3) Inspection Plan. On or before sixty (60) days after issuance of this Permit, the Permittee shall submit for review and written approval by the Commissioner a revised Inspection Plan to address the following comments: (a) Page 3, Table 1, Inspection list of Waste Management Areas and Facility Assets. Delete under "Subareas" the term "Proposed Temporary Parking Area". This area is not a permitted waste storage area. (b) Page 4, item 2.0, Inspection Methods and Use of Electronic Forms, second sentence states that "... certain non-RCRA inspection items can be included on the Inspection Forms." Remove from the narrative the line of "Such items can be added or deleted at the facility discretion." The use of this phrase is not acceptable nor accurate. (c) Page 4, item 2.0, Inspection Methods and Use of Electronic Forms, second paragraph refers to the WINWEB Electronic Inspection Management system developed by Cleans Harbors. Please, include in the Inspection Plan the NEICVP1493E01 Appendix A Page 202 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut WINWEB Standard Operating Procedures (SOPs) as utilized at the Facility to record and maintain the electronic inspection logs at the Facility. (d) Page, 6, Table 2., "Regulatory Framework of the Facility Inspection Program," fails to include the regulatory requirements for Tank Storage Inspections. Please revise Table 2 accordingly, to include regulatory requirements for Tank Storage and the minimum requirements for the Miscellaneous Operations such as the 10Day or Less Trailer Storage permitted activity at the Facility. (e) Appendix I of the Inspection Plan, under the Safety and Emergency Equipment Systems, states that the SCBA is inspected monthly but on page 31 of the Contingency Plan states that the SCBA is tested bi-monthly. Please clarify which statement is correct? Are these inspections and tests being logged? Please address the inconsistency accordingly. (f) Appendix 3, Tank Management Inspection Elements, Methods, and Inspection Frequency includes Volatile Organic (VO) Emissions Controls Inspections for Tank14; however, the Department was notified by Clean Harbors on December 31, 2018, that the facility cannot comply with the requirements of Subpart BB and CC for the storage of volatile organic with a concentration above 500 ppmw in the storage tanks and decided not to pursuit such waste storage. Please address and revise the discrepancy accordingly. (g) In Appendix 3, Tank Management Inspection Elements, Methods, and Inspection Frequency, please include a line item for the inspection and execution of "annual removal of tank bottoms (sludge residual)." (h) Appendix 4, Other Waste Management Inspection Elements, Methods, and Inspection Frequency, under the Inspection Parameter, Truck Parking revise the frequency for the inspection element of "Inspect secondary containment sumps for accumulated liquids and solid debris" from weekly inspection to "daily inspection." This area does not have roof and is susceptible to the weather elements such as precipitation, snow, and spills. (i) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. This Appendix shall include at a minimum, the Emergency Equipment quantity listed in the Contingency Plan, specifically: (1) Page 24, item 1.3.4, Fire Control Equipment; (2) Page 24, item 1.3.5, Spill Control Equipment; (3) Page 25, item 1.3.6, Safety and First Aid Equipment; (4) Page 25, item 1.3.7, Personal Protective Equipment; (5) Page 25, item 1.3.11, Emergency Stations, etc., to ensure that the items are stocked and in proper working order in the event of an emergency. Please correct and address the deficiencies. NEICVP1493E01 Appendix A Page 203 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (j) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. As a general comment, the secondary containment in the container storage areas located inside the Process Building and Container Storage Building are inspected for accumulated precipitation, but the storage areas are protected from the weather elements unless the building roof is leaking then a daily inspection item needs to be added to the Inspection Log such as check for "Leaking Roof". Add, a line to daily inspection to inspect for "accumulated liquids" in the secondary containment. (k) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. The Spill Control Area, secondary containment, add a line item to check for "accumulated liquids". This area is vulnerable to spills and releases. Also, under Pumps correct the typos "Equipnet", detrioration" should it read "Equipment", "deterioration"? Also, add an inspection line to check if the pumps are operational, and corrective measures to fix the problem. (l) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. Delete Inspection of Truck Parking Areas 2 - This area does not exist nor is permitted. (m) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. Under Truck Parking Area 1 and Truck Parking Area 3 secondary containment add an inspection line item to check for "accumulated precipitation/snow/debris" as well as to "whether it has been removed" since these areas are in the open with no roof coverage. (n) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. Under the Process Areas, Pour-off Station add an inspection line item to check for "accumulated liquids" as well as to "whether it has been removed". (o) Appendix 5, Monthly Inspection Logs. The Roll-off and Storage Area is inspected monthly for accumulated precipitation, this is not acceptable because this area does not have a roof and is located outdoors subject to the weather elements. Please add the roll-off storage area to the daily inspection log for "accumulated liquids" to ensure that the sump is capable to hold its design volumetric capacity as well as to "whether it has been removed." (p) Appendix 5. Daily, Weekly, Monthly and Annual Inspection Logs. Under the Two-way radils - Operational. Please explain what are "radils"? (q) Appendix 5. Annual Inspection Logs for Tanks 11 and 14. Include an inspection line item to check the tanks for the accumulation of sludge on the bottom of the tank or "tank bottom sludge removal" to prevent the tanks from overflowing. (r) Forms code 218 and 251, list a Truck Parking Area 2. This Area is not an approved permitted location as noted in Section II, Permitted Activities of this Permit. Please remove the reference to "Truck Parking 2." NEICVP1493E01 Appendix A Page 204 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (s) The Inspection logs for the Truck Parking Areas 1 and 3 states that trucks are staged for less than 5 days. Is Clean Harbors inspecting this 10-Day or Less Area daily every 5 days? There seems to be a discrepancy, please revise the inspection log or provide an explanation on how these vehicles are inspected. (t) Form Code 268, Tank Annual Inspection should include a line item on the removal of bottom sludges from the storage tanks on an annual basis to prevent any false or inaccurate volume storage capacity. (u) Include in the Inspection Plan and Log the Emergency Equipment and quantities maintained at the Facility listed in the Contingency Plan, "see item 1.3, pages 23 to 27." The Inspection logs should have a line item to note if any deficiencies (e.g., missing items) when discovered during the inspection and when corrective actions taken. Please revise accordingly. (v) The inspection frequency in the Inspection Plan and Contingency Plan should be in agreement. Please correct any discrepancies so the frequency is consistent in both plans. (x) Include in the Inspection Plan an inspection log checklist for the Air Monitoring Instrumentation and Controls listed in item 1.3.13 of the Contingency Plan (Page 27) to ensure proper operation of the equipment. Please update accordingly. (y) The Inspection Plan shall have a log checklist with a line item to determine if the Standard Operating Procedures (SOP) for activation of the Dispatcher Services is up to date for the Facility. Please update accordingly. (z) Once each calendar year after issuance of this Permit, the Permittee shall retain the services of a third-party qualified consultant to perform a hazardous waste compliance and operational safety audit. In addition to compliance with the facility permit, the consultant shall evaluate and report on the operational safety items listed in Section III of this Permit. Please maintain these evaluations with the Inspection Logs Operating Record at the Facility. (4) Personnel Training Plan. (a) On or before thirty (30) days after issuance of this Permit, the Permittee shall submit documentation to the Department that the Facility's Senior Management Personnel have been trained in the requirements and conditions specified in this Permit. (b) On or before sixty (60) days after issuance of this Permit, the Permittee shall submit for review and written approval, a revised Personnel Training Plan addressing the following comments: (i) Page 5, Table 8.1B - Required Training for Each Job Title, does not match what was provided in Appendix 8-3, Job Descriptions for the Facility. NEICVP1493E01 Appendix A Page 205 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Please correct any discrepancies, the job titles should be consistent in the documents. For example, Table 8.1.B, list a Laboratory Manager, Lab Chemist I and Receiving Chemist but Appendix 8.3 list only a Lab Chemist I, and a Lab Supervisor. (ii) Page 8, item 3.j; and page 9, item 4.c. states that employees are trained on the operation and activation of the SPOK, Inc. (formerly AMCOM) eNotify system, please update the Dispatcher Service provider with the one listed on Page 10 of the Contingency Plan (Rave Mobile Safety, Inc.) and make the appropriate correction on appropriate plan. (iii) Submit the Standard Operating Procedure (SOP) that Clean Harbors' Bristol Facility has in place for the Dispatcher Services. The SOP should list the roles and procedures for the Dispatcher Services and Clean Harbors' expectations for such Services. (iv) Appendix 8-1, Employee Development Record, presented an out-of-date training record that was completed by Bryan Campbell. Please include with the revised Appendix and provide a copy of the most recent training record for all the employees involved in the management of hazardous wastes at the Facility. (v) Appendix 8-2, Description of Additional Training, last paragraph describes a Truck-to-Truck Transfer Plan of the Permit that will be used to train personnel. Please submit the Truck-to-Truck Transfer Plan for review and approval by the Department along with the system tracking tools used for the training that was mentioned in the paragraph. (vi) There is a discrepancy with the employee named "Jose Vega." The Personnel Training Plan is listing him as an "WWT Operator Facility," while the Contingency Plan is listing him as an "Alternate Emergency Coordinator" with a title of "Facility Foreman." At the same time, Table 8.1B., Required Training for each Job Title, he has the title of "Plant Foreman." Please correct the noted inconsistencies and update the document with the correct name and title(s) for all employees. Please review the job titles and the designated personnel in both plans to ensure they are correct and consistent. Please note, at the time of an inspection, the inspector can request records for each employee handling hazardous wastes. (vii) During the review of the Waste Analysis Plan, specifically page VI-22, item 1.3.6, Sampling Health Protocol, it is was noticed that "all personnel must be properly trained ...as described in the Personnel Training Plan (Attachment D)", however, the Personnel Training Plan does not describe nor contains a description of such training. Please update the Personnel Training to include the required training. NEICVP1493E01 Appendix A Page 206 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (viii) During the review of the Waste Analysis Plan, specifically page VI-36, item 1.6.8, Receiving and Handling Paint Waste from the PaintCare Program, states that "Upon arrival at the Facility the driver ... will check with the Facility's Compliance Guard to verify shipment information" but Appendix 8-1, Employee Development Record, and Appendix 8-3, Job Descriptions of the Personnel Training do not include a "Facility's Compliance Guard" as an employee at the Bristol Facility. Please include the correct information as it pertains to the Bristol Facility. Also see "Item 2 (bb)" for similar situation. (ix) An evaluation of the adequacy of current staffing levels at the Bristol Facility shall be conducted by an Independent Contractor in such areas as training, preparedness, procedures, etc., to prevent the numerous spills and incidents as well as violations of CT DEEP regulations occurring at this Facility. This evaluation shall be conducted as part of the annual 3rd Party Audit. (5) Contingency Plan. On or before sixty (60) calendar days after issuance of this Permit, the Permittee shall submit for review and approval by the Commissioner a revised Contingency Plan to address the following: (a) Within thirty (30) calendar days of the Commissioner's written approval of the revised plan, the Permittee shall send by certified mail or electronic mail with a request for a return receipt or a reply confirmation, the transmittal of the approved Contingency Plan revisions to the police, fire department, hospital and emergency response teams in the vicinity of the facility. (b) Page 24, item 1.3.3 Public Address System, mentions reference to "administrative building" but the site plan for the Facility does not show any location of an Administrative building. Please revise accordingly. (c) Page 24, item 1.3.3, Public Address System, second paragraph, uses the term "Plant Supervisor's Office" but such a term is not included in the Personnel Training, Table 8.1B, Required Training for Each Job Title. Please revise the discrepancy accordingly to reflect the correct location or employee. (d) Page 24 of the Contingency Plan lists a 250-pound portable Aqueous Film Forming Foam (AFFF) extinguisher. Is this PFAS or PFOA-based? If it is PFAS or PFOA based, Clean Harbors should look for an alternative fire extinguisher. Please provide an explanation and address accordingly. (e) Page 25, of the Contingency Plan, item 1.3.7 lists "Two (3) SCBA" please revise accordingly. (f) Page 26, of the Contingency Plan, item 1.3.11 lists "Two (3) SCBA" please revise accordingly. NEICVP1493E01 Appendix A Page 207 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (g) Page 28, of the Contingency Plan, item 1.4.2, On-site Evacuation Procedures, third paragraph refers to "visitor log kept in the Administration Office, as well as the one maintained at the facility entrance" but the site plan does not show the location of an "administration office" and the facility does not have guarded facility entrance. Please explain and revise the discrepancy accordingly. (h) Page 28, of the Contingency Plan, item 1.4.2, On-site Evacuation Procedures, third paragraph refers to "department supervisors" but this title is not included in the Personnel Training, Table 8.1B, Required Training for Each Job Title. Please revise the discrepancy accordingly. (i) Page 31, of the Contingency Plan, states that "The SCBA units maintained on-site are tested bi-monthly ..." Are these inspections being logged, if not they should be included as part of the inspection schedule? (j) Appendix 6, Waste Management Areas, of the Contingency Plan should be revised to reflect the correct activities, wastes types and quantities per Section II, Permitted Activities, of this Permit. For example, revise "9-40 cubic yard rolloffs to 7-40 cubic yard rolls; this area is limited in space due to the mix-tub activities for solidification and stabilization and the Vactor Trucks unloading area. and revise the line item for Tank No. 14, volatile organic waste stream since the tank is not fitted to accept volatile organic wastes with a concentration above 550 ppmw. (6) Closure Plan. On or before ninety (90) calendar days after issuance of this Permit, the Permittee shall submit for review and written approval by the Commissioner a revised Closure Plan to address the following comments: (a) As a general comment, revise Item 9.3, Description of Regulated Units, to match the permitted language. For example, the MBSTA description states "... removal of free draining solids - Provide a description of this free draining solid? (b) Item 5, Container Storage Area C, states that storage of flammable prior to treatment onsite. The facility is not permitted to treat flammable wastes. Please revise accordingly. (c) Item 6, BULA. The fourth item regarding "the disassembly and consolidation of Lab packs containers" at this location, is not a permitted activity. (d) Item 7, CSA. Please remove from the description the following items: (i) second item, loading /unloading of non-bulk containers ... from the trailers located in front of the Container Storage Building; (ii) third item storage of frozen bulk containers (i.e., roll-offs) (this is not a permitted activity); NEICVP1493E01 Appendix A Page 208 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut (iii) fifth item, resampling containers is not a permitted activity in this area. (e) Delete from the description any mentioning of "PCB containing prior to treating onsite." The facility is not authorized to treat PCB containing wastes onsite. (f) Item 10, Former Waste Pile. This unit that has not undergone a RCRA closure. Provide a historical background description for this unit. Also, provide the procedures that will be used for the RCRA closure of this unit. The procedures shall comply with the 40 CFR 264 Subpart G and Connecticut closure requirements and the closure requirements of this Permit. A schedule for the formal closure of this unit shall be provided to the Commissioner for review and approval within thirty (30) calendar days of the issuance of this Permit. (g) Page 8, Table 9-1, Permitted Management Units Requiring Closure, shall be updated to reflect the Permitted Activities listed in Section II of this Permit. The quantity for Area "A" shall read 2,750 gallons. The citation under the maximum storage capacity for the Solidification and Stabilization Area is not accurate. Provide a description of the alaklines waste in this activity. Please revise the discrepancies accordingly. (h) Page 23, Table 9-5, Required Sampling for Waste Management Areas, shall be updated to incorporate the Truck-to-Truck Transfer Area (5 Bays) and the Waste Pile (S03 unit) as a separate line item. Revise the required sampling to reflect the Permitted Activities described in Section II of this Permit. (i) Page 25, item 9.2, Closure Performance Standard. The citation "40 CFR 265.111" is only applicable to Interim Status Facility. Please revise the citation to read "40 CFR 264.111". (7) On or before November 1st, 2021, the Permittee shall submit for review and approval a revise Drawing 62WC-7100-205, Titled -Permitted Storage Areas A, B, D, E, F, G & J, with the correct volume capacity for Area "A", it shall read 2,750 gallons instead of 5,500 gallons. (8) On or before November 1st, 2021, the Permittee shall submit for review and approval by the Commissioner a Drawing for the permitted Bulk Unloading and Loading Area (BULA), such a drawing shall show the locations of all the connectors for the unloading/loading of wastes, pumps and any other equipment utilized in the transferring of waste to the Facility Wastewater Treatment, and Tank Storage. (9) On or before November 1st, 2021, the Permittee shall submit for review and approval by the Commissioner a Drawing for the permitted Mix-Tub, Bulk Storage and Transfer Area (MBSTA) showing the location of the Mix-Tub Area, the roll-off delineation layout and the Vacuum Vehicle Unloading/Loading Area. (10) On or before November 1st, 2021, the Permittee shall submit for review and approval by the Commissioner a Drawing for the Miscellaneous Processing Areas (Drum Rinsing NEICVP1493E01 Appendix A Page 209 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Station, Drum Crushing Station and Lab Pack Pour-Off Area). At a minimum it shall the locations in the Operations Building with respect to the other activities. (11) On or before December 1st, 2021, the Permittee shall submit for review and approval by the Commissioner a schedule for the procurement, and selection process of the thirdparty auditor and the implementation of the audit as specified in Section III (44)(b). (12) Failure to submit an approval Plan. (a) The Permittee shall address, to the satisfaction of the Commissioner, all comments provided by the Commissioner regarding the Personnel Training Plan, Facility Inspection Plan, and Contingency Plan submitted pursuant to Section V of the Permit. If for any of the aforementioned Plans the Permittee fails to satisfactorily address all such comments within thirty (30) after receipt of the Commissioner's comments, the Permittee shall cease receiving waste or other materials at the Facility and shall close the Facility in accordance with terms and conditions of this Permit. There shall be no extension to this thirty (30) day-time Period. (b) The Permittee shall address, to the satisfaction of the Commissioner, all comments provided by the Commissioner regarding the Closure Plan and the Waste Analysis Plan submitted pursuant to Section V of this Permit. If for any of the aforementioned Plans the Permittee fails to satisfactorily address all such comments within sixty (60) days after receipt of the Commissioner's comments, or upon a demonstration of good-cause by the Permittee, such longer time that the Commissioner approves in writing, the Permittee shall cease receiving waste or other materials at the Facility and shall close the Facility in accordance with terms and conditions of this Permit. (13) Miscellaneous. The Proposed Concrete Truck Staging Pad included in the Waste Management Areas - Site Plan, was not included in this Permit because the Permittee failed to submit supporting documentation for this activity. If the Permittee wish to have this area permitted, the Permittee shall submit to the Commissioner for review and approval a detailed Drawing of this Area along with all the documentation associated with the usage of such area. Supporting documentation includes but is not limited to inspection items, documentation on how the Personnel will be trained in the Operation of the Area, the Contingency Plan; and Closure Plan (closure cost estimates and closure procedures) will need to be addressed for this Area as well as a Standard Operating Procedures (SOP) for the Operation of this Area. Upon review of the above listed documents, the Department will decide if such management activity meets regulatory requirements for inclusion in this Permit. NEICVP1493E01 Appendix A Page 210 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENTS CLEAN HARBORS OF CONNECTICUT, INC. EPA ID No. CTD000604488 All the attachments included in the Draft RCRA Part B Permit Renewal are from Clean Harbors of Connecticut, Inc. - Permit Application submitted to the Department in March 2017, and as amended. The Draft Permit list of Attachments as: A. WASTE ANALYSIS PLAN B. INSPECTION PLAN C. PERSONNEL TRAINING PLAN D. CONTINGENCY PLAN E. CLOSURE PLAN Please note the List of Attachments cited above differs from what was provided in the Clean Harbors' Permit Application. The table below is a crosswalk between the Attachments contained in this Permit and where they can be found in the Permit Application. PERMIT APPLICATION NUMBER OF PAGES Attachment A: The Documentation in Attachment J - Waste 108 Waste Analysis this attachment can be Analysis Plan - Section Plan found in 5 Attachment B: The Documentation in Attachment K - 37 Inspection Plan this attachment can be Inspection Schedule found in and Log - Section 6 Attachment C: The Documentation in Attachment N - 53 Personnel Training this attachment can be Personnel Training Plan found in Plan - Section 8 Attachment D: The Documentation in Attachment L - 47 Contingency Plan this attachment can be Emergency Plan and found in Preparedness - Section 7 Attachment E: The Documentation in Attachment P - Closure 101 Closure Plan this attachment can be Plan and Cost Estimate found in - Section 9 NEICVP1493E01 Appendix A Page 211 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT A WASTE ANALYSIS PLAN (Submitted with the RCRA Part B Permit Application in March 2017) (Revised February 1, 2017) Clean Harbors of Connecticut, Inc. Waste Analysis Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 212 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Attachment J RCRA Hazardous and Non-RCRA Hazardous Wastes Permit Waste Analysis Plan Clean Harbors of Connecticut, Inc. EPA ID # CTD000604488 Permit # DEP/HWM-017-004 NEICVP1493E01 Appendix A Page 213 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE OF CONTENTS - ATTACHMENT A COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT CLEAN HARBORS OF CONNECTICUT, INC. WASTE ANALYSIS PLAN (Submitted with the RCRA Part B Permit Application in March 2017) Clean Harbors of Connecticut, Inc. Waste Analysis Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit NEICVP1493E01 Appendix A Page 214 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Table of Contents Section 1.1 1.1.1 1.1.2 1.1.3 1.2 1.2.1 1.2.2 1.2.3 1.3 1.3.1 1.3.2 1.3.3 1.3.4 1.3.5 1.3.6 1.3.7 1.4 1.5 1.6 1.6.1 1.6.2 1.6.3 1.6.4 1.6.5 1.6.6 1.6.7 1.6.8 1.6.9 Title Facility Description Facility Processes and Activities Identification/ Characterization of Wastes Managed Onsite Description of Waste Management Areas Waste Analysis Parameters Criteria for Parameter Selection Parameter Selection Process Rationale for Parameter Selection Sampling Procedures Sampling Strategies Sampling Equipment Sampling Equipment Decontamination Sampling Preservation and Storage Sampling Quality Assurance/ Quality Control Procedures Sampling Health and Safety Protocols Sampling Frequency Testing and Analytical Methods Waste Re-Evaluation Methods Special Procedural Requirements Procedures for Characterizing Wastes Received from Off-site Procedure for Receiving Wastes Generated Off-site Procedures for Ignitable, Reactive and Incompatible Wastes Non Bulk Container Storage Compatibility Testing Rejected Wastes Complying with LDR Requirements RCRA Air Requirements Receiving and Handling Paint Waste from the PaintCare Program Rinsing Operations of Non-Bulk Containers, Bulk Containers, Roll-Offs, Bulk Vehicles and Other Washing or Rinsing Operations Related to Permitted Waste Management Activities Page 1 1 2 4 10 10 10 12 17 17 18 18 19 21 21 21 23 26 26 26 30 32 32 33 34 36 36 36 Tables Table 1.1 Table 1.2 Table 1.3 Table 1.4 Off-Site Waste Characterization Table Waste Verification Table Sample Preservation and Storage CHCI Testing and Analytical Methods NEICVP1493E01 Appendix A Page 215 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendices Appendix I-1 Appendix I-2 Appendix I-3 Appendix I-4 Appendix I-5 Appendix I-6 Appendix I-7 Appendix I-8 Appendix I-9 Appendix I-10 Appendix I-11 Appendix I-12 Generator Waste Material Profile Sheet (GWMPS) Outside Lab Chain of Custody Form Bulk Load QC Form Pre-Acceptance Record CHCI Vehicle Off-Loading Authorization Form (VOAF) Waste Receiving Report Waste Type and Associated Personal Protective Equipment Permitted Waste Codes Land Disposal Restriction Forms High Hazard Procedures Sampling Equipment PaintCare Processing Standard Operating Procedure Number 62WC-125-000 NEICVP1493E01 Appendix A Page 216 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Waste Analysis Plan 1.1 Facility Description 1.1.1 Facility Processes and Activities Clean Harbors of Connecticut, Inc. (CHCI) is a permitted RCRA hazardous and non-RCRA hazardous waste treatment, storage and recycling facility. The facility generates, treats and stores RCRA and non-RCRA hazardous wastes, and is an indirect discharger of pretreated wastewater under the Clean Water Act (CWA). The facility has a RCRA Part B permit and a permit issued under Section 22a-454 of the CGS. CHCI manages all wastes that are accepted or generated at the facility by one or more of the waste management processes/activities described below: 1. Wastewater Treatment System: The CWA wastewater treatment system treats aqueous RCRA hazardous and non-RCRA hazardous wastes. The wastewater treatment system is comprised of units for: primary physical and chemical treatment (i.e., chemical precipitation, coagulation and filtration of inorganic-based aqueous streams); and specialized pretreatment prior to the primary treatment (i.e., neutralization, chemical oxidation and reduction, chelation, air stripping, carbon adsorption and oil recovery). Treatment residuals (i.e., sludge) generated from the CWA process may be solidified/stabilized on-site and shipped off-site for disposal. Treated effluent is discharged under a permit issued by the DEP to the publicly owned treatment works (POTW) operated by the City of Bristol. 2. Solidification/Stabilization: RCRA hazardous and non-RCRA hazardous wastes are generated on-site or received from off-site sources. These wastes are treated by a solidification/stabilization process (i.e., mixing the waste with agents such as diatomaceous earth, cement kiln dust and ash) to meet applicable Land Disposal Restrictions (LDR) treatment standards (40 CFR Part 268) and the disposal facility's specifications. 3. Hazardous Debris Treatment: Hazardous debris is defined as "debris that contains a hazardous waste listed in 40 CFR 261 Subpart D or that exhibits a characteristic of hazardous waste identified in 40 CFR 261 Subpart C. Any deliberate mixing of prohibited hazardous waste with debris that changes its treatment classification (i.e., from waste to hazardous debris) is not allowed under the dilution prohibition in 40 CFR 268.3", pursuant to 40 CFR 268.2. Debris is consolidated and stored on-site prior to being shipped off-site to an approved TSDF for treatment by non-thermal, non-vapor phase treatment technologies (reference 40 CFR 268.45 Table 1). 4. Storage in Tanks and Containers: RCRA hazardous and non-RCRA hazardous wastes are accepted, stored, consolidated, and either treated on-site or shipped to an off-site treatment, disposal, or reuse facility. 5. Special Wastes: These wastes are comprised of identifiable, unused commercial chemical products, which are not mixed with other characteristic or listed hazardous wastes. In most cases, special wastes are "lab packs" of materials in their pure commercial form and original container (e.g., a bottle of acid from a laboratory cleanout). Special wastes also include, but are not limited to: (a) commercial NEICVP1493E01 Page VI- 1 Appendix A Page 217 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 chemical product containers, which are empty as defined in 40 CFR 261.7; (b) single-substance spill material (e.g., absorbent, debris); (c) off-specification or outdated commercial chemical products; (d) contaminated commercial products; (e) asbestos waste from demolition or cleaning; (f) intact manufactured articles which contain a hazardous waste; (g) containers of hardened solids or highly viscous wastes, which cannot be sampled; (h) "RCRA-empty" (per 40 CFR 261.7) containers, drums, barrels, cans, bags, liners, etc. from waste commercial products or chemicals; and (i) aerosol cans which are in good exterior condition and which have an original label, or a label, which accurately reflects the generator's knowledge and/or testing of the contents of the container. 6. Truck-to-Truck Transfer: RCRA hazardous, non-RCRA hazardous, universal and solid wastes (i.e., asbestos-containing materials and biomedical wastes) are accepted and shipped to an off-site treatment, disposal, or reuse facility in their "asreceived" form. 7. Polychlorinated biphenyls (PCBs): CHCI operates a commercial PCB storage facility in accordance with interim status approval issued by US EPA pursuant to TSCA regulations for PCB storage (40 CFR Part 761). CHCI is only authorized to store PCBs in containers. No treatment or disposal activities are performed on-site. 8. Other Activities: Disassembly of Solid Waste (i.e., appliances containing chlorofluorocarbon (CFC) liquid) Disassembly of Used Electronics Collection and storage of Universal Wastes 1.1.2 Identification/Classification of Wastes Managed On-Site The waste streams are managed at the Bristol Facility as follows: Non-RCRA hazardous wastes received from off-site facilities are: (1) bulked and shipped off-site for energy recovery, disposal, or further recycling; (2) treated on-site in the wastewater treatment system and discharged to the local POTW; (3) for solid and semi-solid wastes containing free liquids, solidified and consolidated into bulk containers (i.e., roll-off containers or trailers) and shipped off-site for disposal; (4) stored on-site for later shipment to approved TSD facilities; (5) involved in truck-totruck activities; and/or (6) decanted of free draining liquids. RCRA hazardous wastes received from off-site facilities are: (1) bulked and shipped off-site for energy recovery, disposal, or further recycling; (2) treated on-site in the wastewater treatment system and discharged to the local POTW; (3) for solid and semisolid wastes containing free draining liquids, stabilized and consolidated into bulk containers (i.e., roll-off containers or trailers) for off-site disposal; (4) stored on-site for later shipment to approved TSD facilities; (5) decanted of free draining liquids; and/or (6) involved in truck-to-truck activities. RCRA hazardous wastes generated from on-site treatment operations include: filter debris, tank bottom sludge, metal hydroxide sludge, spill clean-up equipment and personal protective equipment. Such wastes are shipped off-site to approved TSD NEICVP1493E01 Page VI- 2 Appendix A Page 218 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 facilities for disposal. Whenever possible, free draining liquids are either decanted or processed through the filter press. Non-RCRA hazardous wastes generated from on-site treatment operations include: (1) solids and semi-solids managed in the Stabilization/Solidification Area where free draining liquids are solidified and bulked into bulk containers (i.e., roll-off containers or dump trailers) for off-site disposal at approved TSD facilities; (2) spill clean-up and personal protective equipment; (3) decanted liquid from bulk containers; and (4) metal hydroxide sludge generated from on-site wastewater treatment, which is stored prior to shipment to an off-site facility. PCBs received from off-site facilities are stored on-site for later shipment to approved TSD facilities and/or are involved in truck-to-truck activities. PCBs resulting from the disassembly of used electronics or scrap metal appliances are stored on-site awaiting shipment to an off-site facility. Universal wastes received from off-site facilities are stored on-site for later shipment to approved TSD facilities. Universal wastes classified as used electronics are disassembled on-site. The materials resulting from disassembly (i.e., plastic, scrap metal) are stored on-site for later shipment to approved recycling or reclamation facilities. Solid wastes received from off-site facilities include: o Asbestos-containing materials and biomedical wastes, which are involved in truck-to-truck activities. o Scrap metal stored on-site for later shipment to approved recycling or reclamation facilities. o Scrap metal appliances containing CFC liquid. The CFC liquid is removed and the appliance is disassembled on-site. The resulting materials are stored on-site for later shipment to approved recycling or reclamation facilities. The following RCRA hazardous and non-RCRA hazardous waste codes are authorized to be managed at the Bristol facility. These waste codes are assigned to the waste streams received from off-site and generated on-site at the facility: Hazardous Wastes D001-043 F001-019, F028-039 K001, K161 P001, P002, P007, P010-012, P016, P021, P023, P024, P026, P027, P029, P030, P034, P036042, P044-046, P049-051, P057, P059, P060, P066, P070, P072, P075, P077, P082, P085, P087089, P093, P094, P097, P099, P108, P109, P111, P113-116, P118-121, P123, P127, P128, P185, P189-192, P194, P196, P197-199, P201, P202-205 U002-007, U010, U011, U014-016, U018, U021, U022, U024, U026-028, U030, U031, U034039, U042, U047-051, U058-064, U066-069, U071-074, U079-082, U085-091, U093-095, U097, U101, U102, U105-107, U109, U111, U112, U114, U116, U119, U120, U122, U126, U128, U129, U132, U136, U137, U140-145, U148-152, U155, U157, U158, U161, U163-170, U172181, U183, U185-187, U191-193, U196, U197, U200-211, U214, U215, U217, U218-227, U235U240, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 NEICVP1493E01 Page VI- 3 Appendix A Page 219 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Non-RCRA Hazardous Wastes CR01, CR02, CR03, CR04, CR05 In general, the waste streams managed by the facility include: Acidic Solutions and Materials Lab Packs Aerosol Cans Mercury-Containing Wastes Alkaline Solutions and Materials Non-Hazardous Materials Aqueous Solutions Non-PCB Materials Asbestos-Containing Wastes Oil and Water Mixtures Biomedical Wastes Organic Materials Characteristically Hazardous Wastes Oxidizing Solutions and Materials Chrome-Containing Solutions Paint Related Materials Corrosive Solutions and Materials PCB-Containing Wastes Cyanide Sulfide Solutions Pharmaceutical Wastes Cyanide-Containing Solutions and Scrap Metal Materials Specification Oils Dioxins Spent Solvents Flammable Liquids and Materials Solid Wastes Fuel (gasoline) Solvent and Water Mixtures Hazardous Waste Debris Stabilization Wastes High Hazard Materials Universal Wastes Glycols Used Oil Isocyanates 1.1.3 Description of Waste Management Areas CHCI operates the following eleven RCRA hazardous and non-RCRA hazardous waste management areas at the Bristol facility: 1. Rinsing, Crushing and Lab Pack Pour-off Stations: CHCI is authorized to engage in the following waste management activities: 1) the rinsing of empty non-bulk containers at the drum rinse stations; 2) the crushing of non- bulk metal containers in the drum crusher; and 3) the pour-off of lab packs at the lab pack pour-off station. The rinse station is located to the west of the facility's wastewater treatment system; the crushing station is located in the western corner of the Operations Building and the lab pack pour-off station is located on the mezzanine above Wastewater Treatment Tank No. 4, inside the Operations Building, as shown on Figure 104-C-01. 2. Container Storage Areas H, K, L, M1 and M2 Container Storage Area H is used for the temporary storage of non-bulk containers of permitted wastes prior to on-site treatment; the staging of outbound shipments; and the disassembly of lab packs, for a time period not to exceed five (5) calendar days from the date the waste was placed in this area. This area is located to the east and west of the facility's wastewater treatment system inside the Operations Building as identified on Figure 104-C-01. The maximum capacity of non-bulk containers of permitted waste or NEICVP1493E01 Page VI- 4 Appendix A Page 220 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 other material allowed in this area is 160, 55-gallon drums or a maximum of 8,800 gallons. Container Storage Area K is used for the storage of non-bulk containers of permitted wastes classified as acidic, for a time period not to exceed one year prior to treating onsite and/or preparing such waste for shipment to an off-site facility. This area is located along the eastern wall inside the Operations Building as identified on Figure 104-C-01. This area consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 60 feet long, 2.6 feet wide and 2 feet deep with a steel grate cover and a 6 inch high epoxy coated concrete berm along three sides of its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 98, 55-gallon drums or a maximum of 5,390 gallons. Container Storage Area L is used for the storage of non-bulk containers of permitted wastes classified as PCB-containing or non-acidic for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. This area is located along the southern wall inside the Operations Building as identified on Figure 104-C-01. This area consists of an epoxy coated concrete floor, incorporating a contained 6 inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 18, 55-gallon drums or a maximum of 990 gallons. Container Storage Area M1 is used for the temporary storage of non-bulk containers of permitted wastes classified as acidic during waste verification activities for a time period not to exceed five (5) calendar days from the date such waste arrived at the facility. Area M1 is also used for the temporary storage of paint waste associated with the PaintCare Program; however, this paint waste may only be temporarily stored in Area M1 on dedicated secondary containment pallets and only in the event that repairs are needed to Area M2. This area is located northeast of the Loading/Unloading Dock inside the Operations Building as identified on Figure 104-C-01. This area consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 25 feet long, 1.15 feet wide and 1.375 feet deep with a steel grate cover, a 6 inch high epoxy coated concrete berm along the eastern side, an 8 inch high metal curb along the back and western sides and a 27 feet long, 1.5 feet wide and 3 inch high concrete barrier ramp for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 124, 55gallon drums or a maximum of 6,820 gallons. Container Storage Area M2 is used for the temporary storage of non-bulk containers of permitted wastes classified as alkaline during waste verification activities for a time period not to exceed five (5) calendar days from the date such waste arrived at the facility. This area is located northeast of the Loading/Unloading Dock inside the Operations Building as identified on Figure 104-C-01. This area consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 25 feet long, 1.15 feet wide, and 1.25 feet deep with a steel grate cover, a 6 inch high epoxy coated concrete berm along its western side, an 8 inch high metal curb along its back and eastern sides and a 27 foot long, 1.5 foot wide and 3 inch high concrete barrier ramp for secondary containment purposes. The maximum capacity of non-bulk NEICVP1493E01 Page VI- 5 Appendix A Page 221 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 containers of permitted waste or other material allowed in this area is 90, 55-gallon drums or a maximum of 4,950 gallons. 3. RCRA Waste Storage Tank Nos. 11 and 14 The Waste Storage Tanks are located inside the Operations Building as shown on Figure 104-C-01. This area consists of a 65.5 feet long, 55.5 feet wide, and 2.75 feet deep vault constructed of concrete sealed with an epoxy coating providing support and secondary containment for Tank Nos. 11 and 14 and the facility's wastewater treatment tanks. The maximum capacity of the Waste Storage Tanks is 4,116 gallons for Tank No. 11 and 10,836 gallons for Tank No. 14. 4. Bulk Unloading and Loading Area (BULA) or (Spill Control) Areas The Spill Control Area is used for the following waste management activities: 1) the loading/unloading of bulk and non-bulk containers of permitted waste; 2) the temporary storage of bulk containers of wastewater treatment sludge generated on-site; 3) the transfer of waste from bulk and non-bulk containers to other bulk and non-bulk containers; 4) the disassembly and consolidation of lab pack containers which contain spilled or leaking wastes; and 5) the solidification of leaking bulk containers.6) the temporary storage of uncharacterized and pre-characterized wastes from Clean Harbors Emergency Response Services. The Spill Control Area is located adjacent to the Operations Building as shown on Figure 104-C-01. This area is provided with a roof and is constructed of a concave concrete floor, incorporating a 6 inch high epoxy coated concrete berms along its perimeter (exclusive of vehicle access and egress areas) and a contained epoxy coated concrete trench approximately 10 feet long, 1 foot wide and 1.3125 feet deep with a steel grate cover for secondary containment purposes. The area is capable of concurrently staging two transport vehicles for the purposes of loading/unloading waste. The area is equipped with three strainers and four tanker discharge pipe receptacles. Three tanker discharge receptacles are piped to the facility's new wastewater treatment system (Tank Nos. 4, 5, 6 and 7) and are dedicated for acidic, high hazardous and alkaline wastes. The fourth tanker discharge receptacle is piped to the facility's older wastewater treatment system (Tank No.2,) and is dedicated for alkaline wastes. The maximum capacity of permitted waste or other material allowed in this area is two, 6,600-gallon capacity bulk containers or 92, 55-gallon drums of waste or a total of 13,200 gallons of waste (in Bulk Area). For purposes of determining compliance with the capacity limit, each container or transport vehicle shall be assumed to be full. 5. Container Storage Area C Container Storage Area C is used for the storage of non-bulk containers of permitted wastes classified as flammable for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. This area is located along the northwestern edge of the Spill Control Area as identified on Figure 104- C-01. This area consists of an epoxy coated concrete floor, incorporating a 6 inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 42, 55-gallon drums or a maximum of 2,310 gallons. For the purpose of determining compliance with the capacity limit, each container in this area shall be assumed to be full. 6. Mix-Tub, Bulk Storage and Transfer Area NEICVP1493E01 Page VI- 6 Appendix A Page 222 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 The Mix-Tub, Bulk Storage and Transfer Area is used for: 1) the stabilization of RCRA hazardous liquid and semi-solid waste by means of mixing such wastes with stabilization agents (i.e., lime, cement kiln dust, fly ash) to render such waste non-RCRA hazardous (passes toxicity levels for leachable metals pursuant to 40 CFR 261.24); 2) the solidification of non-RCRA hazardous liquid and semi-solid waste by means of mixing such wastes with solidification agents (i.e., diatomaceous earth, cement kiln dust, ash) to render such waste more amenable for off-site treatment or disposal; 3) the transferring of RCRA and non-RCRA hazardous waste from the stabilizing tubs into bulk containers (i.e. roll-off containers) for storage in this area and/or off-site shipment; 4) the rinsing of bulk or non-bulk containers and associated equipment over the stabilization tub; 5) the consolidation of bulk and non-bulk containers; 6) the removal of free draining liquid resulting from the transportation of the containers prior to stabilization or solidification; and 7) the storage of roll-off containers or transportation vessels containing debris and other materials not destined for on-site treatment for no longer than thirty (30) days from the date such waste arrived at the facility. The cure time for the waste will vary to allow sufficient cure time, so the waste meets the RCRA LDR standards The Mix-Tub, Bulk Storage and Transfer Area is located northwest of the Spill Control Area as shown on Figure 104-C-01 of this permit. This area is constructed of a sloped concrete base pad, a 4.4 cubic yard steel tub, a 28.8 cubic yard steel tub and a contained 4 foot long, 3 foot wide and 2.5 foot deep concrete sump located along the wall of the Spill Control Area for secondary containment purposes. The Solidification/Stabilization Area has a minimum secondary containment volume of 20,033 gallons plus additional capacity equivalent to the negative containment volume of any device or structure within the area (e.g., containers, equipment, or pallets) and includes the volume of run-on and/or accumulated precipitation from a twenty-five (25) year, twenty-four (24) hour storm event. The maximum capacity of permitted waste or other material allowed in this area is 490 cubic yards including no more than nine (9), 40-cubic yard roll-off containers; seven (7) vehicle trailers or a combination of seven (7) units at any one time. The maximum daily through put of the solidification/stabilization process is 540 cubic yards per day. Vehicles could be but are not limited to: Cusco's, Tankers, Guzzlers, Roll Offs, Roll Off Frames, Dump trailers, etc. 7. Container Storage Building - Container Storage Areas A, B, D, E, F, G, J The Permittee is authorized to engage in the following waste management activities in the Container Storage Building: 1) the temporary storage of non-bulk containers of permitted wastes awaiting shipment to an off-site facility or on-site treatment; 2) the loading/unloading of non-bulk containers of universal and solid wastes from the trailers located in front of the Container Storage Building; 3) the temporary storage of bulk containers (i.e. roll-off containers) containing frozen waste/material; 4) the collection/storage of empty non-bulk containers in transport vehicles located adjacent to the container storage building for off-site shipment; and 5) the storage of non-bulk containers of permitted waste. The Container Storage Building is located southwest of the Operations Building as shown on Figure 104-C-01 of this permit. The Container Storage Building is divided into seven distinct sections (Areas A, B, D, E, F, G, J) each separated by a 6-inch high epoxy coated concrete berm to facilitate the separated storage of incompatible waste streams. Container Storage Area A is used for the storage of non-bulk containers of permitted wastes classified as acid-reactive for a time period not to exceed one NEICVP1493E01 Page VI- 7 Appendix A Page 223 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 year, prior to treating on-site and/or preparing such waste for shipment to an offsite facility. Container Storage Area A is located along the eastern wall of the Container Storage Building, and consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 24 feet long, 1.6 feet wide, and 2 feet deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along three sides of its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 50, 55 -gallon drums or a maximum of 2,275 gallons. Container Storage Area B is used for the storage of non-bulk containers of universal wastes, solid wastes and wastes resulting from the disassembly of such wastes (e.g., cathode ray tubes, plastic, metal) in Rows 8, 9 and 10 prior to treating on-site and/or preparing such waste for shipment to an off-site facility, for a period not to exceed one year. The storage of non-bulk containers of permitted wastes classified as alkaline is allowed in Rows 1 through 7 for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area B is located along the western wall of the Container Storage Building, and consists of an epoxy coated concrete floor, a 6 inch wide x 6 inch high concrete berm located between rows 7 and 8 and a contained epoxy coated concrete trench approximately 74.625 feet long, 1.6 feet wide, and 2.12 feet deep with a steel grate cover and a 6 inch high epoxy coated concrete berm along two sides of its perimeter and the back wall of the Container Storage Building for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in Rows 1 -7 is 336, 55-gallon drums or a maximum of 18,480 gallons. Container Storage Area D is used for the storage of non-bulk containers of permitted wastes classified as toxic or PCB-containing for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area D is located north of Container Storage Area B in the Container Storage Building, and consists of an epoxy coated concrete floor, incorporating a 6-inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 48, 55-gallon drums or a maximum of 2,640 gallons. Container Storage Area E is used for the storage of non-bulk containers of permitted wastes classified as toxic or PCB-containing for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area E is located north of Container Storage Area A in the Container Storage Building, and consists of an epoxy coated concrete floor, incorporating a 6 inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 120, 55-gallon drums or a maximum of 6,600 gallons. NEICVP1493E01 Page VI- 8 Appendix A Page 224 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Container Storage Area F is used for the storage of non-bulk containers of permitted wastes classified as acidic for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area F is located north of Container Storage Area D in the Container Storage Building. This area consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 11.6 feet long, 1.6 feet wide, and 2 feet deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along two sides of its perimeter and the back wall of the Container Storage Building for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 50, 55-gallon drums or a maximum of 2,750 gallons. Container Storage Area G is used for the storage of non-bulk containers of permitted wastes classified as acidic for a time period not to exceed one year, prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area G is located north of Container Storage Area F in the Container Storage Building. This area consists of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 11.6 feet long, 1.6 feet wide, and 2.2 feet deep with a steel grate cover and a 6 inch high epoxy coated concrete berm along two sides of its perimeter and the back wall of the Container Storage Building for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 54, 55-gallon drums or a maximum of 2,970 gallons. Container Storage Area J is used for: 1) the disassembly of waste classified as used electronics; 2) the extraction of CFC liquid from appliances containing CFC liquid; and/or 3) the disassembly of waste classified as solid waste (i.e. appliances containing CFC liquid). Container Storage Area J is located in the southeast corner of the Container Storage Building. This area is constructed of an epoxy coated concrete floor and shares the epoxy coated concrete trench with Container Storage Area B for secondary containment. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 40,cubic yards or a total of 10 gaylords 8. Truck-To-Truck Transfer Area The Truck-To-Truck Transfer Area is used for the following waste management activities: 1) the transferring of non-bulk containers of permitted waste from one transportation vehicle to another transportation vehicle; 2) the loading of non-bulk containers of permitted waste from the facility onto transportation vehicles for off-site shipment; 3) the unloading of non-bulk containers of permitted waste from transportation vehicles into the facility; and 4) the collection/storage of empty non-bulk containers onto a transport vehicle for off-site shipment. The Truck-To-Truck Transfer Area is located outside the Operations Building as shown on Figure 104-C-01 of this permit. The dock is provided with a roof and consists of a slightly concave concrete floor that is sloped gradually towards a containment drain, located in the center of the dock, that drains into trailer bay number three for secondary containment purposes. The dock is provided with five trailer bays, each 56 ft long x 12 ft NEICVP1493E01 Page VI- 9 Appendix A Page 225 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 wide. Each bay is separated by a 8 inch high x 12 inch wide concrete berm and that provides 549 gallons of secondary containment by a blind sump 7 feet long, 3.5 feet wide and 3 feet deep epoxy coated concrete sumps that are covered with steel grates. The Permittee shall not, at any one time, allow more than five (5) transportation vehicles to be placed at the Loading/Unloading Dock Area or a maximum of 25,300 gallons of waste or other materials in the Loading/Unloading. The maximum capacity of permitted waste or other material allowed in this area no more then five transportation vehicles and no more than a total of 25,300 gallons of waste or other materials. 9. Truck Parking Areas The Truck Parking Areas are used for the following waste management activities: 1) temporary staging of transportation vehicles containing permitted wastes, which are destined for the facility, and 2) temporary staging of transportation vehicles containing wastes for off-site shipment for a time period not to exceed ten (10) calendar days from the date such waste arrived at the facility. Existing Design: Existing Truck Parking Area #1 consists of four (4) sloped concrete trailer bays and Truck Parking Area #3 consists of one (1) sloped concrete trailer bay. Each bay is 55 feet long and 12 feet wide. The bays in Area #1 are separated by 12 inch wide concrete berms and each is provided with 4,846 gallons of individual secondary containment by concrete berms and 2 foot long, 2 foot wide and 4 inch deep concrete sumps. The bay in Area #3 is provided with 4,728 gallons of secondary containment by concrete berms and a 2 foot long, 2 foot wide and 4 inch deep concrete sump. The Permittee shall not, at any one time, place or allow in excess of five (5) full length transportation vehicles (a rack truck or half-length box van counts as half a full length transportation vehicle) or more than 25,300 gallons of permitted waste or other material in the Existing Truck Parking Areas. 10. Proposed Temporary Parking Area The proposed temporary parking area is designed to facilitate staging up to 10 incoming trailer equivalents. Staged trailer equivalents may remain in this area until 11:59PM on the date of arrival at the facility. Containers will not be opened in this area at any time. This area will only be used as a staging location for empty trailer equivalents or trailer equivalents waiting to be off loaded at the facility. 1.2 Waste Analysis Parameters 1.2.1 Criteria For Parameter Selection Waste analysis parameters are selected to represent those characteristics necessary to ensure safe and effective waste management. Waste identification (i.e., characterization) is a requisite step in proper waste management. Generators and TSDFs must determine, through testing or acceptable knowledge of the process generating the waste, if the waste is hazardous in accordance with 40 CFR Part 261 Subparts C and D and/or the waste is in compliance with LDR requirements. The waste analysis parameters must identify incompatible/inappropriate wastes for the facility. CHCI is capable of treating a variety of permitted waste streams. However, there are wastes that are not authorized for treatment at the facility and pose a hazard if managed on-site. The waste analysis parameters must also take into consideration the process and design capabilities of the facility. NEICVP1493E01 Page VI- 10 Appendix A Page 226 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 CHCI will obtain the required information on each waste stream through a combination of the sources listed below. It is important that a full characterization of each candidate waste stream be obtained to satisfy the criteria listed in this section. Manufacturer Information First-hand data is obtained from the manufacturers pertaining to the raw materials, products or similar materials that may be used when appropriate. This shall include, but is not limited to, material specifications and safety data sheets (SDSs). This data shall support and document the information required by the specified characterization parameters. Process Information First-hand knowledge of the process generating the waste may be used when appropriate. This shall include published or documented data on the process generating the hazardous waste. This shall include laboratory analysis that is performed using approved EPA methods. This data shall support and document the information required by the specified characterization parameters. Waste Profile Sheets CHCI shall require and maintain the process information provided by the generator on the Generator Waste Material Profile Sheet (GWMPS) for each waste stream. An electronic copy of each GWMPS shall be available on-site. 1.2.2 Parameter Selection Process The selection of the waste analysis parameters is based on a review of generator-supplied information on the properties and constituents of the waste stream (40 CFR 261 Appendix VII), the identification of "key indicator properties" which indicate any change in the waste (i.e., waste verification), and a comparison of the analytical data with the requirements of the treatment process design and the trial treatment results, to ensure compliance with all permits, effluent discharge limits and off-site disposal acceptance criteria. Required testing parameters: 1. Physical Appearance/ Description 2. pH 3. Compatibility 4. Water Solubility/Reactivity 5. Flash Point/ Ignitability 6. Free and Reactive Cyanide 7. Free and Reactive Sulfide 8. Oxidizer 9. Radioactivity Screen Supplemental testing parameters: 1. Volatile Organics Screen (incoming bulk loads) NEICVP1493E01 Page VI- 11 Appendix A Page 227 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 2. Absorbent Reactivity 3. Applicable Land Disposal Treatment Standards 4. BTU Value 5. Chemical Oxygen Demand 6. Chlorides 7. Chlorine 8. Cyanide-Peroxide Amenability 9. Cyanide-Chlorination Amenability 10. Distillation 11. GC/MS* Scan 12. Heat Phase Separation 13. Heavy Metals 14. Hexavalent Chrome 15. Miscellaneous Parameters 16. Neutralization Equivalent 17. Nitrates 18. pH Spectrum 19. Paint Filter Test 20. PCBs 21. Percentage of Oil 22. Pesticides & Herbicides 23. Phenols 24. Phosphates 25. Soluble Sulfides 26. Sulfate Screen 27. Sulfide-Peroxide Amenability 28. Specific Gravity 29. Specific Organic Compounds 30. Sulfates 31. Total Halogens 32. Total Organic Carbon 33. Total Petroleum Hydrocarbons 34. Total Solids / Suspended Solids 35. Toxicity Characteristics 36. Viscosity * Gas Chromatograph/Mass Spectrum 1.2.3 Rationale for Parameter Selection The following section describes the waste analysis parameters, the rationale for their selection and how each analysis is performed. Required testing parameters: 1. Physical Appearance/Description - Determines if the physical characteristics of the waste (e.g. color, odor, viscosity, layering/phases, physical state, other observations) matches the approved waste profile (GWMPS). A sample of the waste is placed in a clear sample container and visually inspected for color, layering and/or number of phases, and physical state. 2. pH - Indicates the corrosive nature of the waste. This test applies to liquids soluble in water, solids and sludges. The test is performed using pH paper with a color scale ranging from red to blue that corresponds to the pH range of 2 through 12. The color red NEICVP1493E01 Page VI- 12 Appendix A Page 228 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 indicates a pH of 2 (acidic), while the color blue indicates a pH of 12 (alkaline or basic). A pH of less than 3.0 indicates very acidic material, while a pH greater than 12 indicates a very alkaline material. If the waste is off-specification, the pH will be verified using a pH meter. a) Liquids: The pH range shall be determined using pH paper or a portable pH meter. b) Solids: A 10% solution must be made by adding 10 grams of the sample to a beaker with 100 ml of distilled waster. The pH of the solution is determined by using full range pH paper or a portable pH meter. 3. Compatibility - Determines if the waste is incompatible with another waste or material and upon contact or when mixed, a reaction occurs which: Generates excessive heat or pressure, fire or explosion or violent reactions; Produces toxic mists, fumes, dusts or gases in sufficient quantities to threaten human health or the environment; Produces flammable fumes or gases in sufficient quantities to pose risk of fire or explosion; Damages the structural integrity of its container, containment structure, or any other structure or equipment; and/or Threatens human health or the environment. Refer to Section 1.6.1 Pre- and Post-Processing Analytical for the procedures to be used to perform compatibility testing. 4. Water Solubility/Reactivity - Determines: 1) if the waste is miscible in water; 2) the waste stream has the potential to vigorously react with water and/or form gases or other products; and/or 3) upon contact with water will generate significant heat. [This test does not apply to wastes already in contact with water or for which significant analytical data exists to indicate no potential reactivity with water]. a) Liquids: Add 10 to 30 ml of the sample to a test tube or beaker filled a third of the way with reagent water and mix well. b) Solids: Add 5 to 10 grams of the sample to 10 ml of reagent water and mix well. If the waste is insoluble in water, it will float or sink in the reagent water. Continually observe the sample for five (5) minutes for the generation of heat or gas to determine if the sample reacts with water. For bulk loads, this test shall be documented on the QC Load Form for bulk loads (Appendix 1-3); for non-bulk loads, this test shall be documented on the Waste Receiving Report (Appendix 1-6). 5. Flash Point / Ignitability - Determines the minimum temperature at which the waste will give off enough vapor to achieve the right mixture with air such that the waste would ignite if an ignition source exists. The flash point also determines the appropriate storage conditions and the applicable requirements to treat, deactivate or separately manage ignitable wastes to ensure compliance with 40 CFR 264.198 for liquid wastes. This test applies to liquids, semi-solids and solids (excluding material that burns easily such as paper or sawdust). NEICVP1493E01 Page VI- 13 Appendix A Page 229 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 The following screening test is used to determine if the sample is ignitable. If the result does not match the profile, additional testing (i.e., closed cup flash test) shall be performed. To determine the sample flashpoint, place 0.5 grams of the sample in an aluminum dish and observe 5 to 10 seconds. Without touching the sample directly with a match, place the match near the sample. If the fumes ignite, record the flash point as less than 70 degrees Fahrenheit. If there is no fume ignition, touch the sample directly with the match. If the sample ignites, record the flash point as greater than 100 degrees Fahrenheit but less than 140 degrees Fahrenheit. If the sample does not ignite, record the flash point as greater than 140 degrees Fahrenheit. 6. Free and Reactive Cyanide - Determines if the waste will produce hydrogen cyanide gas upon acidification below a pH of 7 and quantifies the concentration of reactive cyanides. This method is to be used for all samples to detect the presence of hydrocyanic acid and cyanides. An EM Quant Cyanide Test can also be performed. DO NOT perform this test if the sample has been determined to contain strong reducing or oxidation agents or a violent reaction may occur (for example, if the waste contains sodium hydrosulfite, sodium hypochlorite or sodium chlorate). Liquids: place 5 to10 ml of the sample in an appropriately sized beaker. Semi-solids and solids: add 1-gram sample to 10 ml of reagent water. Add 3 to 4 drops of concentrated sulfuric acid to the beaker and mix. Caution: Concentrated acid can cause a violent heat reaction. Agitate the sample immediately and place the cyanide test paper in the beaker in the area of the gas zone (above the liquid level) and cover the beaker. Let the beaker sit for a minimum of 15 minutes. If the test paper color changes to a deep blue, cyanide may be present. If the results of this test do not match the waste profile, then additional sampling shall be performed (i.e. cyanide distillation). The sensitivity of the test is 0.2 mg/l of cyanide. 7. Free and Reactive Sulfide - Determines if the waste will produce hydrogen sulfide gas upon acidification below a pH of 2 and quantifies the concentration of sulfides. [This analysis is not required if the pH of the waste is less than 6 and the waste is not watersoluble]. This test method is to be used for all samples to detect the presence of sulfides. Liquids: place 5 to 10 ml of the sample in an appropriately sized beaker. Semi-solids and solids: add 1-gram of the sample to 10 ml of reagent water. Slowly add enough concentrated sulfuric acid to lower the pH to between 1 and 2. Immediately after reaching the desired pH, hold a strip of lead acetate paper (approximately one-inch long) that has been wetted with de-ionized water over the beaker. If the paper turns from white to brown or black, sulfides may be present. If no color change is observed, the test is negative. 8. Oxidizer - Determines if the waste is an oxidizer by the use of potassium iodide litmus paper. NEICVP1493E01 Page VI- 14 Appendix A Page 230 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Liquids: place 5 to 10 ml of the sample in an appropriately sized beaker. Semi-solids or solids: add 1-gram sample to 10 ml of reagent water. Place a one-inch strip of potassium iodide starch paper in the sample. If the paper turns from white to purple, an oxidizer is present and the sample shall be tested with hydrogen peroxide (H2O2), nitrate/nitrite and/or colorimetric indicator papers. 9. Radioactivity Screen - Determines if the waste contains radioactive materials. A sample of waste is placed under a Geiger counter to determine if the waste has a radioactivity level above the background level. If the sample is determined to have a radioactivity level twice that of the background level, the waste is analyzed to determine if the source of the radioactivity is naturally occurring. Supplemental testing parameters: 1. Absorbent Reactivity - Determines if the waste stream is amenable to solidification/stabilization and the quantity of absorbent required. 2. Applicable Land Disposal Treatment Standards - Proper notification and recordkeeping is identified and recorded in accordance with the treatment standards under 40 CFR 268. 3. BTU Value - Determines the heat value of the waste for fuel blending. 4. Chemical Oxygen Demand - Determines the amount of oxygen required to stabilize organic waste through the use of a strong oxidizer. 5. Chlorides - Determines if the major acid component of the waste is hydrochloric acid or hydrochloric salts. 6. Chlorine: Determines the amount of chlorine present in the waste. This test is accurate up to approximately 1% chlorine content. For fuels or used oils: Heat approximately 2 to 5ml of the sample in an aluminum dish until it either boils or ignites; Place a one-inch strip of pH test paper above the sample; If chlorine is present the pH paper will turn a shade of red. The deeper the shade of red, the higher the concentration of chlorine. COLOR CHANGE CHLORINE CONCENTRATION No color change None Slightly Pink <1% Pink 1% Red/Dark Red 2-5% Purple Red >5% A screening kit (CLOR-D-Tect Q4000 or similar) can be used to determine the total chlorine present in fuels or used oil. For wastewaters: NEICVP1493E01 Page VI- 15 Appendix A Page 231 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Add 1to 2 drops of silver nitrate to a 2 to 5 ml sample. If chlorine is present, it will precipitate out of the sample. 7. Cyanide-Peroxide Amenability - Determines the effectiveness of cyanide treatment by the use of peroxides. 8. Cyanide-Chlorination Amenability - Determines the effectiveness of various cyanide treatments involving the use of chlorine. 9. Gas Chromatography/Mass Spectrum Scan - Identifies and separates the organic compounds present in the waste. 10. Heat Phase Separation - Determines the behavior of the different phases of the waste with respect to temperature fluctuations. 11. Heavy Metals - Quantifies the concentrations, using the Toxicity Characteristic Leaching Procedure (TCLP), of the heavy metals (wastes with EPA hazardous waste codes D004011) present in the waste to determine if the concentrations exceed the regulatory levels pursuant to 40 CFR 261.24 Table 1 (Maximum Concentration of Contaminants for the Toxicity Characteristic). 12. Hexavalent Chrome - Quantifies the concentration of hexavalent chrome present in the waste. 13. Miscellaneous Parameters - Determines the potential of metal salt precipitation for the following metals: Other Metals: (total concentration) aluminum, antimony, arsenic, beryllium, boron, calcium, cobalt, copper, cadmium, chromium, lead, mercury, magnesium, manganese, molybdenum, nickel, potassium, selenium, silicon, silver, sodium, thallium, tin, titanium, vanadium, and zinc Non-Metals (percent by weight): sulfur, bromine, chlorine, flourine, iodine; (parts per million, ppm): ammonia, sulfide, cyanide, nitrate, biochemical oxygen demand, total suspended solids. 14. Neutralization Equivalent - Determines the quantity of an acid or a base required to neutralize the waste for wastewater treatment. 15. Nitrates - Determines if the major component of the waste is nitric acid or nitric salts. 16. PCB - Determines the concentration of PCBs present in the waste. This test is done using a spot test kit from HACH or a similar kit, or GC method 608/8082 can be used as a spot check. 17. pH Spectrum - Determines the behavior of the waste over a range of pH. 18. Paint Filter Test - Determines if free liquid is present in solid and semi-solid wastes 19. Percentage of Oil - Determines the concentration of oil present in the waste in order to determine proper treatment. Concentrated sulfuric acid is mixed with a measured amount of the sample. After 10 minutes, the sample is checked to determine if the oil has NEICVP1493E01 Page VI- 16 Appendix A Page 232 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 separated out of the mixture. If the oil does not separate out after 10 minutes, heat will be applied via a hot plate for an additional 5 to10 minutes. If the above methods do not work, the sample will be gravity separated using a centrifuge. 20. Pesticides and Herbicides: Quantifies the concentrations, using the TCLP, of the pesticides and herbicides (wastes with EPA hazardous waste codes D012-017, D020 or D031) present in the waste to determine if the concentrations exceed the regulatory levels pursuant to 40 CFR 261.24 Table 1 (Maximum Concentration of Contaminants for the Toxicity Characteristic) 21. Phenols - Quantifies the concentration, in ppm, of phenols present in the waste. 22. Phosphates - Determines if the major acid component of the waste is phosphoric acid or phosphoric salts. 23. Soluble Sulfides - Provides the quantitative analysis to the Free and Reactive Sulfide screening. 24. Sulfate Screen - Determines the presence of sulfates. 25. Sulfide-Peroxide Amenability - Determines the effectiveness of the use of peroxide in sulfide treatment. 26. Specific Gravity - Indicates the density of the waste. 27. Specific Organic Compounds: Volatile Organic Compounds (wastes with EPA hazardous waste codes D018, 019, 021, 022, 028, 029, 035, 039, 040 and/or 043): Quantifies the concentrations, using the TCLP, of volatile compounds present in the waste to determine if the concentrations exceed the regulatory levels pursuant to 40 CFR 261.24 Table 1 (Maximum Concentration of Contaminants for the Toxicity Characteristic). Semi-Volatile Organic Compounds (wastes with EPA hazardous waste codes D023-027, 030, 032-34, 036-38, 041and/or 042): Quantifies the concentrations, using the TCLP, of semi-volatile compounds present in the waste to determine if the concentrations exceed the regulatory levels pursuant to 40 CFR 261.24 Table 1 (Maximum Concentration of Contaminants for the Toxicity Characteristic). 28. Sulfates - Determines if the major acid component of the waste is sulfuric acid or sulfuric salts. 29. Total Halogens - Determines the concentration of total halogens present in the waste. See the test for Chlorine. 30. Total Organic Carbon - Determines the concentration of total organic carbon of the waste. 31. Total Petroleum Hydrocarbons - Determines the concentration of total petroleum hydrocarbons present in the waste. This is required prior to shipping the waste to an authorized landfill. NEICVP1493E01 Page VI- 17 Appendix A Page 233 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 32. Total Solids/ Suspended Solids - Quantifies the concentrations of settled, suspended and dissolved solids present in the waste, in conjunction with determining the moisture content, the amount of free water and filtration requirements. 33. Toxicity Characteristics - Determines the concentrations of metals and/or organics listed in 40 CFR 261 Subpart D, using the TCLP. 34. Viscosity - Determines if the waste is suitable for transfer via pumping. 1.3 Sampling Procedures 1.3.1 Sampling Strategies All first time waste streams, with the exception of Special Wastes, shall be sampled. Prior to any waste being sent to the facility, the generator shall submit a sample to CHCI for appropriate analysis in accordance with Table 1.1, "Waste Characterization", and the parameters indicated on the GWMPS. For wastes managed at the facility, CHCI personnel shall collect the samples for waste verification in accordance with the following procedures: All sampling procedures shall conform to the American Society for Testing Materials (ASTM) and US EPA Test Methods for Evaluation of Solid Wastes SW-846 version 2005. Each non-bulk container shall be sampled. For non-bulk containers of waste with the same profile received in the same shipment from the same generator, a maximum of four (4) non-bulk container samples may form a composite sample for waste verification purposes. All samples shall be placed in a polyethylene container unless otherwise noted in Table 1.3, "Sample Preservation and Storage". Sampling Liquids and Semi-solids 1. Use a clean coliwasa sampler, bacon bomb or Sludge Judge (see Appendix 1-11 for descriptions of sampling equipment). 2. Coliwasa: Once the coliwasa is in the drum, place thumb over the top of the tube and remove. Place coliwasa in sample jar and remove thumb releasing the sample into the sample jar. Bacon Bomb: A bacon bomb is used to sample tanks at varying depths. Slowly lower the device into the tank to be sampled using the string attached at the top of the device (the string is knotted at one foot intervals to identify the depth of the sample taken). Either: 1) open the device with the second string at the desired sample depth and release the string to obtain a sample, or 2) lower the device to the bottom of the tank and the weight will open the device and allow a sample to be obtained. Sludge Judge: This sampler is a plastic tube marked at one foot increments with a valve on the bottom used to obtain samples from across a cross section of the waste. Lower the tube into the waste to the desired depth. This will cause the valve to open and sample the waste. Raise the unit up to close the valve and retain a cross sectional sample. NEICVP1493E01 Page VI- 18 Appendix A Page 234 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 All samplers must be slowly lowered into the waste at a rate that allows the level of the liquid inside and outside the sampler to remain the same. If the level of the waste in the tube is lower than the level outside, the sampling rate is too fast and will produce an unrepresentative sample. 3. The minimum required sample volume is 100 ml. 4. Preserve the sample in accordance with Table 1.3 in Section 1.3.4. Sampling Solids 1. Use a sample scoop or Thief Sampler. 2. Sample the waste as follows: a. Take a "core" sample vertically through the center of the material with a thief sampler; or b. If a core sample cannot be obtained, a composite sample from the top, middle, and bottom of the waste may be taken with a sample scoop. 3. The minimum required sample volume is 50 ml. 4. Preserve the sample per Table 1.3 in Section 1.3.4. 1.3.2 Sampling Equipment Liquid and semi-solid samples shall be taken with a coliwasa sampler, bacon bomb or Sludge Judge, and solid samples will be taken with a Thief Sampler or sample scoop. All sampling devices obtain a representative cross-sectional sample of the waste. Samples shall be deposited in polyethylene jars ranging in size from 200 ml to 1000 ml. 1.3.3 Sampling Equipment Decontamination Most sampling equipment utilized at the facility (with the exception of coliwasa and bacon bombs) is disposable. Those items that are not disposable will be washed, in the laboratory sink, in a detergent solution and rinsed with clean water until all residual waste is removed. Equipment in which the waste can't be removed by the above means will be disposed of bearing the waste codes of the waste contents. All sample jars and lids will be disposed of bearing the waste codes of the waste contents. 1.3.4 Sampling Preservation and Storage Samples of waste taken at the facility shall be analyzed on the same operating day that the sample was taken or within five (5) days from the date the waste arrived at the facility. Samples requiring off-site certified analysis (e.g., storm-water run-off, discharge holding tank parameters, and specific waste constituents) must be stored and preserved in accordance with Table 1.3 below. Table 1.3 Sample Preservation and Storage Organic Analysis by GC/MS Parameter Container Type Volatile Organics G, Teflon lined septum or cap Water or Solid/Waste Water Solid/waste Preservative Cool to 4 C, Na2S2O35 or HCl to pH 2 Cool to 4 C Preserv. Volume (2) 40ml Holding Time 14 days 4 oz 14 days NEICVP1493E01 Page VI- 19 Appendix A Page 235 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Base/Neutral & Acid Extractables G, amber, Teflon lined cap Organic Analysis by GC Parameter Container Type Purgeable Hydrocarbons Purgeable Aromatics G, Teflon lined septum or cap G, Teflon lined septum or cap Purgeable Hydrocarbons & Aromatics Organochlorine PCB G, Teflon lined septum or cap G, Teflon lined cap Water Solid/Waste Water or Solid/Waste Water Solid/Waste Water Solid/Waste Water Solid/Waste Water Solid/Waste Cool to 4 C, Na2S2O35 Cool to 4 C Preservative Cool to 4 C, Cool to 4 C Cool to 4 C, HCl to pH 2 Cool to 4 C Cool to 4 C, HCl to pH 2 Cool to 4 C Cool to 4 C, to pH 5-9 Cool to 4 C Na2S2O35 Na2S2O35 Na2S2O35 NaOH or or or H2SO4 1 L (1) 16 oz Preserv. Volume (2) 40 ml (1) 4 oz (2) 40ml 4 oz (2) 40ml 4 oz 1 L (1) 16 oz 7 days 14 days Holding Time 14 days 14 days 14 days 14 days 14 days 14 days 7 days 14 days Organochlorine Pesticides G, Teflon lined cap Chlorinated Herbicides G, Teflon lined cap Trace Metals Analysis Mercury (cold P,G vapor) Hexavalent P, G Chromium Total Metals P, G Dissolved Metals P, G Suspended Metals P, G Water Solid/Waste Water Solid/Waste Water Solid/Waste Water Water Solid/Waste Water Solid/Waste Water Solid/Waste Cool to 4 C, NaOH or H2SO4 to pH 5-9 Cool to 4 C Cool to 4 C, pH 5-9 Cool to 4 C 1 L (1) 16 oz 1 L (1) 16 oz HNO3 to pH<2 Cool to 4 C Cool to 4 C 500 ml (1) 4 oz 500 ml HNO3 to pH<2 Cool to 4 C Filter, HNO3 to pH<2 Cool to 4 C Filter Cool to 4 C 1 L (1) 4 oz 1 L (1) 4 oz 1 L (1) 4 oz 7 days 14 days 7 days 14 days 28 days 28 days 24 hours 6 months 6 months 6 months 6 months 6 months 6 months Inorganic Analysis by GC Acidity (to pH 8.2) P, G Alkalinity (to pH P, G 4.5) Bacteria (fecal P, G coliform) Bacteria (fecal P, G streptococci) Total Coliform P, G Biochemical P, G Oxygen Demand Bromide P, G Chemical Oxygen P, G Water Water Water Water Water Water Water Water Cool to 4 C Cool to 4 C Cool to 4 C, Na2S2O35 Cool to 4 C, Na2S2O35 Cool to 4 C, Na2S2O35 Cool to 4 C N/A Cool to 4 C, H2SO4 to pH < 250 ml 500 ml 250 ml 250 ml 250 ml 1 L 500 ml 100 ml 14 days 14 days 6 hours 6 hours 6 hours 48 hours 28 days 28 days NEICVP1493E01 Page VI- 20 Appendix A Page 236 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Demand Chloride Chlorine (total residual) Color Conductance Cyanide (total and amenable to chlorination) Detergents Flouride Hardness Halogens (total) Halogens (organic) Nitrogen (ammonia) P, G P, G P, G P, G P,G P, G P P, G G, Teflon lined cap G, amber, Teflon lined cap P, G Water Water Water Water Water Solid/Waste Water Water Water Solid/Waste Water Water 2 N/A N/A Cool to 4 C Cool to 4 C Cool to 4 C, NaOH to pH > 12, 0.6 g ascorbic acid Cool to 4 C Cool to 4 C N/A HNO3 to pH<2, H2SO4 to pH<2 Cool to 4 C Cool to 4 C, H2SO4 to pH<2 Cool to 4 C, H2SO4 to pH<2 500 ml 500 ml 500 ml 500 ml 1 L (1) 16 oz 500 ml 500 ml 250 ml (1) 16 oz 1 L 1 L 28 days 0 48 hours 28 days 14 days 14 days 48 hours 28 days 6 months 0 28 days 28 days Parameter Nitrogen (kjeldahl) Nitrogen (nitrate) Nitrogen (nitrite) Nitrogen (organic) Oil & Grease (total and petroleum hydrocarbon) Infrared (total & petroleum hydrocarbon) pH Phenols (total) Phosphorous (total) Phosphorous (Orthophosphate) Solids (total) Solids (total dissolved) Solids (settleable) Solids (total volatile) Sulfate Sulfide (total) Container Type P, G P, G P, G P, G G Water or Solid/Waste Water Water Water Water Water Solid/Waste G Water Solid/Waste P,G Water Solid/Waste G Water P, G Water P, G Water P, G Water Solid/ Waste P, G Water P, G Water P, G Water Solid/Waste P, G Water P, G Water Preservative Cool to 4 C, Cool to 4 C Cool to 4C Cool to 4 C, Cool to 4 C, to pH<2 Cool to 4 C Cool to 4 C, to pH<2 Cool to 4 C N/A N/A Cool to 4 C, Cool to 4 C, H2SO4 H2SO4 HCl or HCl or H2SO4 H2SO4 to pH<2 to pH<2 H2SO4 H2SO4 to pH<2 to pH<2 Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C Cool to 4 C, add zinc acetate and sodium Preserv. Volume 1 L 250 ml 250 ml 1 L 1 L (1) 16 oz 1 L (1) 16 oz 500 ml (1) 14 oz 500 ml 250 ml 250 ml 1 L (1) 4 oz 1 L 1 L 1 L (1) 4 oz 500 ml 250 ml Holding Time 28 days 48 hours 48 hours 28 days 28 days 28 days 28 days 28 days 24 hours 24 hours 28 days 28 days 48 hours 7 days 7 days 7 days 48 hours 7 days 7 days 28 days 7 days NEICVP1493E01 Page VI- 21 Appendix A Page 237 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Sulfite P, G Total Organic P, G Carbon Turbidity P, G Tritium P, G P = Plastic G = Glass Water Water Solid/Waste Water Water hydroxide to pH> 9 N/A Cool to 4 C, HCl or H2SO4 to pH<2 Cool to 4 C Cool to 4 C N/A 500 ml (2) 40 ml (1) 4 oz 500 ml 1 L 0 28 days 28 days 48 hours 6 months 1.3.5 Sampling Quality Assurance/Quality Control (QA/QC) Procedures Appropriate QA/QC procedures, including the use of chain of custody forms (provided in Appendix 1-2) and compatible sample containers, shall be followed for all sampling. Only qualified CHCI personnel shall perform all sampling. For vehicles with multiple compartments (i.e., tankers), sampling personnel shall use dedicated samplers or will decontaminate the sampler after each use, in accordance with Section 1.3.3. 1.3.6 Sampling and Health Protocols All personnel must be properly trained in the safety and handling techniques of the various waste streams managed at the facility, as described in the facility's Personnel Training Plan (Attachment D). Appropriate personal protective equipment, including safety glasses, chemical suits and chemically protective gloves shall be worn during all sampling. Respiratory protection is required when sampling or handling highly volatile organic waste streams, as indicated on the GWMPS and the Vehicle Off-Loading Authorization Form (VOAF) (Appendix 1-5). The required respiratory protection is based on the OSHA permissible exposure limits (PELs). Refer to Appendix 1-7 for a list of the chemical action levels and associated personal protective equipment. CHCI accepts wastes which the facility designates as a high hazard (i.e., wastes that contain one or more constituents in sufficient quantities requiring special handling procedures). Refer to Appendix 1-10, "High Hazard Procedures", for safety and handling requirements of these waste streams. 1.3.7 Sampling Frequency Prequalification Procedures (i.e., Waste Characterization) These procedures shall be followed prior to the initial shipment of the waste to the facility and repeated when: 1) the generator notifies CHCI that the process generating the waste has changed, or 2) CHCI has reason to suspect that the composition of the waste received is different than represented in the prequalification documentation. At a minimum, the prequalification procedures shall be repeated at a once a calendar year. Verification Testing Each bulk and non-bulk container shall be sampled and analyzed, with the exception of special wastes, truck-to-truck wastes, lab packs, bulk truck-to-truck loads in the Truck Transfer Area and Stabilization Area and debris. Bulk loads will undergo a PID screen for VOC analysis and GC analysis if over 400 ppm. Pre-Processing Pre-processing analyses shall be performed prior to the movement of any non-bulk container of waste from Container Storage Areas M1 or M2, or any bulk container of NEICVP1493E01 Page VI- 22 Appendix A Page 238 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 waste from the Spill Control Area, into another waste management area authorized to store/treat such waste at the facility. NEICVP1493E01 Page VI- 23 Appendix A Page 239 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 1.4 Testing and Analytical Methods The analytical methods used for waste characterization and verification analyses are listed below in Table 1.4. Only methods specified in SW846 shall be used at the facility Parameter Test Analytical Method(s) Method Arsenic 1311 TCLP D004 6010 B Inductively Coupled Plasma-Atomic Emission Spectrometry 6020 Inductively Coupled Plasma-Mass Spectrometry 7061A Atomic Adsorption, Gaseous Hydride 7062 Atomic Adsorption, Borohydride Reduction 7063 Arsenic in Aqueous Samples and Extracts by ASV Barium 1311 TCLP D005 6010B Inductively Coupled Plasma - Atomic Emission Spectrometry 6020 Inductively Couples Plasma - Mass Spectrometry Benzene 8260 B VOC's by GC/MS D018 8021 B Aromatic and Halogenated Volatiles by GC using Photoionization Cadmium 6010 B Inductively Coupled Plasma - Atomic Emission Spectrometry D006, F006 6020 Inductively Coupled Plasma - Mass Spectrometry Carbon Tetrachloride 8021B Aromatic and Halogenated Volatiles by GC using Photoionization D019 8026 B VOC by GC/MS Chlordane 8270 C Semi- VOCs by GC/MS D020 8260B VOCs by GC/MS Chlorobenzene 8021 Aromatic and Halogenated Volatiles by GC using Photoionization D021 8260 B VOC by GC/MS Chloroform 8021 Aromatic and Halogenated Volatiles by GC using Photoionization D022 8260 B VOC by GC/MS Chromium (Total 6010 B Inductively Coupled Plasma-Atomic Emission Spectrometry D007, F006, F019, 6020 A Inductively Coupled Plasma-Mass Spectrometry U032 Copper 6010 B Inductively Coupled Plasma-Atomic Emission Spectrometry 6020 A Inductively Coupled Plasma-Mass Spectrometry Cresol 8270 C Semi - VOCs by GC/MS D026 Cyanide 9010 C Total and Amendable Cyanide: Distillation 9012 B Total and Amendable Cyanide: Automated Colorimetric Flash Point 1010A Pensky Martens Closed Cup for Ignitability 1020B Setaflash Closed Cup Method for Ignitability Fluorides 9056 Determination of Inorganic Anions by Ion Chromatography 9214 Potentiometric Determination in Aqueous Samples Heptachlor 8081 A Organochloride Pesticides by GC D031 8270 C Semi- VOC's by GC/MS Hexachlorobenzene 8081 A Organochloride Pesticides by GC D032 8121 Chlorinated Hydrocarbons by GC: Capillary Column Tech. 8270 C Semi-VOCs by GC/CM 8275 A Semi-VOCs in soils/sludges and solid wastes by TE?GC?MS 8410 GC/FT-IR for Semi -VOCs; Capillary Column Hexachlorobutadine 8081A Organochloride Pesticides by GC D033 8121 Chlorinated Hydrocarbons by GC Capillary Column Tech. 8260B VOCs by GC/MS 8270C Semi-VOC by GC/MS 8410 GC/FT-IR for Semi-VOCs: Capillary Column NEICVP1493E01 Page VI- 24 Appendix A Page 240 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Parameter Hexachloroethane D034 Hexavalent Chromium D017, F006, F019 U032 Lead D008, U144, U145 U146 Mercury D009 Methyl Ethyl Ketone D035 Nickel F006 Nitrobenzene D036 o-Cresol D023 p-Cresol D025 pH Pentachlorophenol D037 Phenol Pyridine D038 Selenium D010 Silver D011 Table 1.4 CHCI Testing and Analytical Methods Test Method 8121 8260B 8270C 8410 7195 7196A 7197 7198 7199 6010B 6020 Analytical Method(s) Chlorinated Hydrocarbons by GC: Capillary Column Tech. VOCs by GC/MS Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column Coprecipitation Colorimetric Chelation/Extraction Differential Pulse Polarography Determination in drinking water, ground water and effluents by Ion Chromatography Inductively Coupled Plasma-Atomic Emission Spectrometry Inductively Coupled Plasma-Mass Spectrometry 7470A 7471A 7472 8021B 8260B 6010B 6020 8091 8260B 8270C 8330 8410 8270C Liquid Waste: Manual Cold-Vapor Technique Solid or Semi-solid: Manual Cold-Vapor Technique Aqueous samples and extracts by ASV Aromatic and Halogenated Volatiles by GC using PhotoionizationVOC by GC/MS Inductively Coupled Plasma-Atomic Emission Spectrometry Inductively Coupled Plasma-Mass Spectrometry Nitroaromatics and Cyclic Ketones by GC VOCs by GC/MS Semi-VOCs by GC/MS Nitroaromatics and Nitramines by HPLC GC/FT-IR for Semi-VOCs:Capillary Column Semi-VOCs by GC/MS 8270C Semi-VOCs by GC/MS 9040C 9041A 9045D 8041 8151A 8270C 8410 8041 8270C 8410 9067 8015B 8260B 8270C 6010B 6020 7741A 7742 6010B 6020 pH Electrometric Measurement pH Paper Method Soil and Waste pH Phenols by GC Chlorinated herbicides by GC using Methylation Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column Phenols by GC Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column Phenolics (Spectrophotometric, MBTH with Distillation Nonhalogenated organics using GC/FID VOCs by GC/MS Semi-VOCs by GC/MS Inductively Coupled Plasma-Atomic Emission Spectrometry Inductively Coupled Plasma-Mass Spectrometry Atomic Absorption, Gaseous Hydride Atomic Absorption, Borohydride Reduction Inductively Coupled Plasma-Atomic Emission Spectrometry Inductively Coupled Plasma-Mass Spectrometry NEICVP1493E01 Page VI- 25 Appendix A Page 241 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Table 1.4 continued ... Parameter Test Method Sulfide 9030B 9031 9034 9215 Tetrachloroethylene D039 Trichloroethylene D040 Various Compounds (Phenols, phthalate esters, cyclic ketones, nitro-aromatics, polynuclear aromatic hydrocarbons, chlorinated hydrocarbons Vinyl Chloride D043 Volatile Organic Compounds F001, F002, F024 U Wastes Zinc U246 1,4-Dichlorobenzene D027 1,2-Dichloroethane D028 1,1-Dichlorethylene D029 2,4-Dinitrotoluene D030 2,4,5-Trichlorophenol D041 2,4,6-Trichlorophenol D042 8021B 8260B 8021B 8260B 8091 8100 8260B 8021B 8260B 8015B 8260B 6010B 6020 8021B 8121 8270C 8410 8260B 8021B 8121 8260B 8270C 8410 8021B 8260B 8091 8270C 8330 8410 8041 8270C 8410 8041 8270C 8410 Analytical Method(s) Acid-Soluble and Acid-Insoluble Sulfides: Distillation Extractable Sulfides Titrimetric Procedure for Acid-Soluble and Insoluble Potentiometric Determination in Aqueous Samples and Distillates with Ion Selective Electrode Aromatic and Halogenated Volatiles by GC using Photoionization VOCs by GC/MS Aromatic and Halogenated Volatiles by GC using Photoionization VOCs by GC/MS Nitroaromatics and Cyclic Ketones by GC Polynuclear Aromatic Hydrocarbons VOCs by GC/MS Aromatic and Halogenated Volatiles by GC using Photoionization VOCs by GC/MS Nonhalogenated Organics Using GC/FID VOCs by GC/MS Inductively Coupled Plasma-Atomic Emission Spectrometry Inductively Coupled Plasma-Mass Spectrometry Aromatic and Halogenated Volatiles by GC using Photoionization Chlorinated Hydrocarbons by GC: Capillary Column Tech Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column VOCs by GC/MS Aromatic and Halogenated Volatiles by GC using Photoionization Chlorinated Hydrocarbons by GC: Capillary Column Tech VOCs by GC/MS Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column Aromatic and Halogenated Volatiles by GC using PhotoionizationVOC by GC/MS Nitroaromatics and Cyclic Ketones by GC Semi-VOCs by GC/MS Nitroaromatics and Nitramines by HPLC GC/FT-IR for Semi-VOCs:Capillary Column Phenols by GC Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column Phenols by GC Semi-VOCs by GC/MS GC/FT-IR for Semi-VOCs:Capillary Column NEICVP1493E01 Page VI- 26 Appendix A Page 242 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 1.5 Waste Re-Evaluation Frequencies Waste streams received from off-site shall be re-evaluated, at a minimum, on an annual basis (i.e., once every 12 months). CHCI shall use the following procedure for re-evaluating wastes: CHCI shall notify the generator that the waste stream is due for re-evaluation. The generator may certify that the waste stream has not changed, based on their knowledge of process. If the generator cannot certify that the waste stream has not changed, a new sample and GWMPS shall be provided to perform a new characterization, as described in Section 1.7, "Procedures for Characterizing Wastes Generated Off-Site". If analysis reveals that the waste stream has not changed, the waste stream shall retain its original approval code. If the analysis reveals a change, a new waste code shall be provided and the original code made inactive. CHCI shall re-evaluate each waste stream generated on-site in accordance with the following schedule: Re-Evaluation Frequency for On-site Generated Wastes Waste Stream Frequency Required Demonstration Metal Hydroxide Sludge, F006 Quarterly Process Knowledge and TCLP Personal Protective Equipment Annual Process Knowledge Tank Bottom Sludge Annual Process Knowledge Spent Carbon Quarterly Process Knowledge and TCLP Non-RCRA Wastewater Treatment Quarterly Process Knowledge and TCLP Solids Rainwater accumulated in the As needed Waste verification parameters Trailer Bay Areas 1.6 Special Procedural Requirements 1.6.1 Procedures for Characterizing Wastes Received From Off-site CHCI has developed the following procedures to be used to determine the acceptability of waste streams and other materials intended for storage, treatment or transfer at the facility. The candidate waste streams shall be analyzed for the waste parameters specified in Table 1.1, "Waste Characterization". No waste shall be accepted at the facility unless its arrival has been scheduled in advance, the waste stream has an approved GWMPS and all prequalification procedures specified below have been completed. Pre-qualification Procedures (i.e., Waste Characterization) Pre-qualification procedures shall be conducted prior to the initial receipt of any shipment of waste at CHCI, to determine the acceptability of the waste stream pursuant to the RCRA Part B permit, the pretreatment permit (State No. SP0000109) and operational capabilities. The Central Profile Group (CPG) manages pre-qualification activities and maintains all necessary associated documentation. Each New Waste Stream: 1. The generator shall complete and submit a GWMPS along with supporting documentation such as laboratory analyses, SDSs or product literature. The generator NEICVP1493E01 Page VI- 27 Appendix A Page 243 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 may supply SDSs for unused commercial chemical products only and may demonstrate knowledge of process for virgin materials only. This may be done electronically or by hard copy. 2. The generator must supply a representative sample of each waste stream to CHCI's CPG for analyses. 3. The sample shall be analyzed for the required parameters listed in Table 1.1, "Waste Characterization". Analysis for the supplemental parameters listed shall be performed at the discretion of CHCI's Laboratory Manager, or an equivalent position. 4. The CPG shall review the GWMPS, the supporting documentation provided by the generator and the analytical results to determine if the waste stream is acceptable for storage, treatment and handling at the facility. Each Lab Pack Container: 1. CHCI shall only accept lab pack containers packed by qualified CHCI staff. Pre- qualification procedures shall be conducted at the site of generation. CHCI shall ensure that: a) the containers are inspected, b) the accuracy of the packing slip has been verified, c) the lab pack contains no prohibited wastes, and d) the proper packing techniques have been followed. During the packing process, personnel shall compare the EPA hazardous waste codes of the material proposed for handling with the prohibited waste codes listed in Section II. of the RCRA Part B Permit (Appendix 1-8). Any waste codes that are not authorized for acceptance at the facility shall be rejected. 2. The generator shall receive pre-shipment authorization of the packing list from CHCI prior to the shipping of the lab pack container. 3. A packing slip or inventory of each drum must accompany the hazardous waste manifest or appropriate shipping documents (e.g., bill of lading) and a copy shall be attached to the outside of the lab pack container. Wastes Destined for Truck-to-Truck Activities: 1. The generator shall complete and submit a GWMPS along with supporting documentation such as laboratory analyses, SDSs or product literature to the CPG. The generator may demonstrate knowledge of process for virgin materials only. 2. The CPG shall review the GWMPS form, the supporting documentation provided by the generator and the EPA hazardous waste codes of the material proposed for handling with the prohibited waste codes listed in Section II. of the RCRA Part B Permit (Appendix1-8). Any waste codes that are not authorized for acceptance at the facility shall be rejected. 3. CHCI shall obtain written approval from the ultimate receiving facility indicating authorization to accept the waste stream. Special Wastes: 1. The generator shall complete and submit a GWMPS along with supporting documentation such as laboratory analyses, SDSs or product literature to the CPG. The generator may demonstrate knowledge of process for virgin materials only. 2. The CPG shall review the GWMPS form, the supporting documentation provided by the generator and the EPA hazardous waste codes of the material proposed for handling with the prohibited waste codes listed in Section II. of the RCRA Part B Permit (Appendix 1-8). Any waste codes that are not authorized for acceptance at the facility shall be rejected. NEICVP1493E01 Page VI- 28 Appendix A Page 244 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 The following wastes are considered Special Wastes: Empty commercial chemical product containers (40 CFR 261.7) Spill materials (i.e., absorbent, debris) containing a single substance Off-specification commercial chemical products Contaminated commercial chemical products Asbestos-containing materials Intact manufactured articles RCRA-empty containers Aerosol cans in good exterior condition, with the original label Biomedical wastes Universal wastes Pesticides and herbicides Isocyanates Debris that is to receive no treatment Containers of hardened solids or highly viscous wastes that can't be sampled Uncharacterized Wastes from Emergency Services: 1. Emergency wastes shall only be received from Clean Harbors Environmental Services (CHES). 2. During the clean-up/response to emergency situations, CHES shall containerize all wastes. 3. Once these wastes arrive at the facility, CHCI shall generate a GWMPS based on information provided by CHES. 4. CHCI shall obtain a representative sample of each waste stream for waste characterization analyses. 5. The sample shall be analyzed for the required parameters listed in the GWMPS in addition to the parameters listed in Table 1.1, "Waste Characterization". Analyses for the supplemental parameters listed shall be performed at the discretion of CHCI's Laboratory Manager, or an equivalent position. 6. The CPG shall review the GWMPS, the supporting documentation provided by CHES and the analytical results to determine if the waste stream is acceptable for storage, treatment and handling at the facility. Pre-characterized Wastes from Emergency Services: 1. Pre-characterized emergency wastes from clean-up/response emergency situations shall only be received from CHES. Such wastes shall be received only in bulk containers. 2. CHCI shall obtain a representative sample of each waste stream for waste characterization analyses. 3. The sample shall be analyzed for the required parameters listed in the GWMPS in addition to the required testing parameters listed in Table 1.1. Analysis for supplemental parameters listed shall be performed at the discretion of CHCI's Laboratory Manager, or equivalent position. 4. The CPG shall review the GWMPS, the supporting documentation provided by CHES and the analytical results to determine if the waste stream is acceptable for storage, treatment and handling at the facility. Verification Testing NEICVP1493E01 Page VI- 29 Appendix A Page 245 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 Verification testing and visual inspections shall be conducted upon receipt of all waste streams (except for wastes classified as Special Wastes, which shall only be visually inspected) to: a) verify that the waste received has been properly characterized in accordance with the accompanying manifest/shipping papers and the pre-qualification documentation, b) determine the proper waste management area in the facility in which to place the waste, and c) verify that the waste meets the facility's compatibility and acceptability criteria. For bulk loads, the results of the visual inspections and verification testing shall be documented on the CHCI Bulk Load QC Forms (provided in Appendix 1-3). For nonbulk loads, the analytical results shall be documented on the Waste Receiving Report (provided in Appendix 1-6). Refer to Table 1.4, "Testing and Analysis Methods", for a complete list of all analytical methods available for use during waste verification. Qualified CHCI personnel shall obtain a representative sample in accordance with the guidelines described in Section 1.3.1. The samples shall be analyzed in accordance with the procedures set forth in Section 1.2.3 and Table 1.2, "Waste Verification". Pre- and Post- Processing Analyses Pre-processing analyses shall be performed to determine the proper treatment chemicals and the associated mixing ratios of all wastes to be treated on-site. Pre-processing compatibility testing shall be performed for the following waste management activities: Wastewater Treatment / Bulking: A sample of the waste stream shall be mixed with a new sample of waste from the batch-mixing tank that the waste stream will be going into, in ratios respective to their volumes. Mixing shall take place under a hood in the laboratory. The mixture shall be observed for a minimum of five (5) minutes for reactivity, solidification, release of noxious gas, liquid phase separation or other reactions. Bulk load samples shall be observed for twenty (20) minutes and non-bulk load samples observed for three (3) hours for any sign of incompatibility (e.g., evolution of gas, exothermic reactions) during compatibility testing. If no signs of incompatibility are observed within the specified time frames the wastes shall be deemed compatible. The results of such tests (i.e., times, observations) shall be documented on the CHCI Bulk Load QC Forms for bulk loads; and on the Waste Receiving Report (provided in Appendix 1-6) for non-bulk loads. If the waste stream is found to be acceptable for on-site treatment, the appropriate treatment protocol is then developed. Such protocols are developed in accordance with the wastewater treatment throughput routings, which are included in Appendix 1-13. Solidification/Stabilization: A new sample container shall be set-up for each batch of waste to be solidified/stabilized. For a sample in which a sufficient amount of water is not present, sufficient quantities of water will be added to form slurry. The pH of the slurry shall be determined. The sample is then mixed with the required stabilization agent in the proportions respective to those to be utilized in the final treatment and observed for five (5) minutes for any signs of reactivity. If the waste is to be added to an existing batch, compatibility with the batch waste must also be tested. The waste shall be considered incompatible NEICVP1493E01 Page VI- 30 Appendix A Page 246 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 when any generation of excess heat or gases, phase separation or other reactions are observed. Bulking: All wastes shall be tested for compatibility prior to the consolidation, bulking or mixing with other wastes at the facility. A minimum of a 10 ml sample will be collected from each container and/or tank containing waste to be consolidated. Samples will be mixed in a 1-liter container in ratios proportional to the volume of each material to be bulked. Bulk load samples shall be observed for twenty (20) minutes and non-bulk load samples observed for three (3) hours for any sign of incompatibility (e.g., evolution of gas, exothermic reactions) during compatibility testing. If no signs of incompatibility are observed within the specified time frames, the wastes shall be deemed compatible. The results of such tests (i.e., times, observations) shall be documented on the CHCI Bulk Load QC Form for bulk loads, and on the Waste Receiving Report for non-bulk loads. Lab Pack Pour-offs: Prior to pouring lab pack containers into the wastewater treatment system, the following sampling and analyses shall be performed: A new representative sample shall be obtained from the receiving treatment tank in which the waste is going to be disposed into. As the inner containers of the lab pack are opened, a representative sample from each inner container shall be taken and added to the tank sample. The combined sample shall be observed for three (3) hours for any sign of incompatibility (e.g., evolution of gas, exothermic reactions) and analyzed for changes in pH and temperature. If no signs of incompatibility or changes in pH or temperature are observed within the specified time frames, the wastes shall be deemed compatible. The results of such tests (i.e., times, observations) shall be documented on the CHCI Waste Receiving Report (provided in Appendix 1-6). Post-processing analyses shall be performed on the treated effluents to ensure that the limits set by the Bristol Sewer Authority and State No. SP0000109 have been met. Pre-and post-processing analyses performed at the facility shall be documented on the forms provided in Appendices 1-3 and 1-6, and shall be maintained in the facility's Operating Record. 1.6.2 Procedures for Receiving Waste Generated Off-site After completing the pre-qualification (i.e., waste characterization) procedures, CHCI shall perform waste verification in accordance with the following procedures to verify the identity of all waste streams received at the facility. Prior to the transfer of the waste to the appropriate waste management area of the facility, CHCI shall evaluate the waste in accordance with this section to confirm that the waste stream: 1) is as indicated on the manifest/shipping paper; 2) matches the GWMPS obtained through the prequalification process; and 3) is compatible with other materials located in the waste management area. All waste received from off-site shall be sampled in accordance with Section 1.3.1, and the samples analyzed in accordance with Table 1.2, "Waste Verification", within five (5) days such waste arrived on-site, and either accepted or rejected. If CHCI determines that recharacterization NEICVP1493E01 Page VI- 31 Appendix A Page 247 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 is necessary, such procedures shall be done in accordance with the procedures for "Rejected Wastes" and completed within five (5) days such waste arrived on-site. Bulk Loads: CHCI shall review the accompanying manifest/shipping papers and the associated LDR documentation for each bulk container upon its arrival at the facility, and generate a VOAF (Appendix 1-5) identifying the hazards of the waste stream and a CHCI Bulk Load QC Form for each waste stream. Once received, all containers shall be sampled and inspected to verify the waste received matches the approved GWMPS. Verification testing shall be performed in accordance with Table 1.2 "Waste Verification" and compared to the prequalification data. All bulk loads will be screened with a PID for VOC concentrations. If detected over 400ppm, the waste will be analyzed using the laboratory GC. Once the identity of the waste has been verified the waste shall be deemed acceptable and unloaded. Any discrepancies must be resolved before the waste can be accepted at the facility. Non-Bulk Loads: CHCI shall review the accompanying manifest/shipping papers and the associated LDR documentation for each non-bulk container upon its arrival at the facility, and generate a VOAF identifying the hazards of each waste stream, and a Waste Receiving Report (Appendix 1-6) for each waste stream. Once received, all containers shall be inspected for proper labeling and marking and to ensure that the containers are in good condition. The container piece count and identification information on each container (EPA waste codes, description) shall be compared to the information on the accompanying manifest/shipping papers and LDR documentation. Any discrepancies must be resolved before the waste can be accepted at the facility. All containers shall be sampled and inspected to verify that the waste received matches the approved GWMPS. CHCI shall place all non-bulk containers of acidic waste in Container Storage Area M1 and non-bulk containers of alkaline waste in Container Storage Area M2. Once in Container Storage Area M1 or M2 the containers shall be opened, the waste sampled, and a visual inspection of the sample performed to verify that the waste matches the approved GWMPS. Verification testing shall be performed in accordance with Table 1.2, "Waste Verification", and compared to the pre-qualification analyses. When the identity of the waste has been verified, the waste shall be deemed acceptable and moved to the proper waste management area. Lab Pack Containers: CHCI shall review the accompanying manifest/shipping papers and the associated LDR documentation for each non-bulk container upon arrival at the facility, and generate a VOAF identifying the hazards of each waste stream, and a Waste Receiving Report for each waste stream. Once received, all containers shall be inspected for proper labeling and marking to ensure that the containers are in good condition. The container piece count and identification information on each container (EPA waste codes, description) shall be compared to the information on the accompanying manifest/shipping papers and LDR documentation. Any discrepancies must be resolved before the waste can be accepted at the facility. CHCI shall place all non-bulk containers of acidic waste in Container Storage Area M1 and nonbulk containers of alkaline waste in Container Storage Area M2. Upon review of the above information CHCI shall confirm if the waste is authorized for acceptance. Wastes Destined for Truck-to-Truck Activities: NEICVP1493E01 Page VI- 32 Appendix A Page 248 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 CHCI shall review the accompanying manifest/shipping papers and the associated LDR documentation for each non-bulk container upon its arrival at the facility, and generate a VOAF identifying the hazards of each waste stream, and a Waste Receiving Report for each waste stream. Once received, all containers shall be inspected for proper labeling and marking, and to ensure that the containers are in good condition. The container piece count and identification information on the container (EPA waste codes, description) shall be compared to the information on the accompanying manifest/shipping papers and LDR documentation. Based on the review of the manifest and/or GWMPS data, CHCI shall confirm if the waste is authorized for acceptance. Information concerning all waste destined for truck-to-truck activities shall be recorded on a Truck-to-Truck Receiving/Shipping Log. 1.6.3 Procedures for Ignitable, Reactive and Incompatible Wastes All waste accepted at the facility shall be evaluated against applicable hazardous waste characteristics to determine the presence of potentially ignitable, reactive or incompatible wastes. Such wastes are subject to a compatibility evaluation that is based on the procedures delineated in EPA Guidance Manual "Waste Analysis at Facilities that Generate, Treat, Store and Dispose of Hazardous Wastes", April 1994. Results of this testing shall yield a reactivity group number that is compared against the compatibility matrix, Figure 5.1 in the guidance manual, to determine which wastes are compatible with each other. CHCI shall maintain a record of the reactivity group number for each waste stream destined for treatment on the GWMPS or the Waste Receiving Report. All wastes will be tested for compatibility prior to consolidation, bulking or mixing with other wastes at the facility. A minimum of a 10 ml sample will be obtained from each container and/or tank containing waste to be consolidated, and placed in a 1-liter container. For bulk loads, the sample shall be observed for twenty (20) minutes, and for non-bulk loads, observed for three (3) hours, for signs of incompatibility (e.g., evolution of gas, exothermic reactions). If no signs of incompatibility are observed within the specified time frames, the wastes shall be deemed acceptable. 1.6.4 Non-Bulk Container Storage Compatibility Testing A minimum of one sample per waste stream, excluding Special Wastes, shall be tested to determine storage compatibility. CHCI shall prepare one composite sample for each Waste Management Area (WMA) as follows. Composites shall be formed by placing 10 ml of each waste stream located in the WMA into a 1liter composite container (the minimum composite sample volume is 0.5 liters). When a 1-liter composite has been obtained, half of the sample shall be removed to begin a new composite sample for the WMA. New composites shall be started at a minimum of once a month or whenever the WMA is empty or contains only solids and lab pack containers. Such samples shall be maintained in the facility laboratory by the lab chemists. On a weekly basis, 100 ml of the composite sample for each WMA shall be retrieved. To determine if a new waste stream is compatible for storage in the WMA: 5ml of the 100 ml composite sample and 5 ml of the new waste stream are mixed together and observed for 20 minutes for any sign of incompatibility (e.g., evolution of gas, exothermic reaction). If the mixture is deemed compatible for storage: a 5 ml portion of the 10 ml mixture is added to the WMA's weekly 100 ml composite sample for the next compatibility test and 10 ml of the waste stream added to the WMA's composite sample. NEICVP1493E01 Page VI- 33 Appendix A Page 249 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 If the mixture is deemed incompatible: the compatibility test sample shall be placed in a suitable container for proper disposal with other laboratory generated wastes. CHCI shall identify an alternate WMA for the storage of the new waste stream and perform a new compatibility test. If an alternate WMA can't be identified the waste shall be rejected pursuant to the "Rejected Waste" procedures described below. 1.6.5 Rejected Wastes The generator shall be contacted pursuant to 40 CFR 264.72 for waste or shipments of waste(s) that have been deemed unacceptable or in nonconformance for any of the following reasons: 1. The waste does not match the approved GWMPS, manifest and/or pre-qualification results; 2. The waste meets the description of an EPA code that is not authorized for acceptance at the facility; 3. Analytical results have identified the presence of unanticipated contaminants or characteristics precluding treatment; 4. The waste is a liquid (other than waste oil) with a flash point of less than 140 degrees and was not stated as ignitable on the profile sheet; 5. The waste is incompatible with other materials stored and treated at the facility; 6. Waste that has been classified as debris does not meet the definition of debris pursuant to 40 CFR 268.2(g). If the waste received does not match the GWMPS or the accompanying manifest/shipping papers, the generator shall be contacted to try to resolve the discrepancy. CHCI may elect to recharacterize the waste stream in accordance with Section 1.6 rather than rejecting the waste. If after recharacterization the waste stream has been deemed acceptable for treatment/storage at the facility, CHCI shall consult the generator regarding the nature of the change in the waste stream. If it has been determined that the change in the waste stream is an isolated occurrence, the original profile shall remain unchanged and the discrepancy shall be marked on the VOAF, Waste Receiving Report and Bulk Load QC Form provided in Appendices 1-5, 1-6, and 1-3 respectively. If the change in the waste stream is permanent, the GWMPS shall be amended or a new profile created. In either case, the accompanying manifest shall be corrected with the proper waste codes and DOT shipping information and the reason for the change clearly marked in the discrepancy section of the manifest. If the waste stream was shipped as non-hazardous and the results of the recharacterization indicate that the waste stream is hazardous, an un-manifested waste report shall be filed with the CT DEP and the appropriate state agency in the generator's state. If after recharacterization the waste is not acceptable, the waste shall be rejected. CHCI shall arrange for the return of the waste to the generator or to an alternate TSDF. A copy of the rejected manifest shall be retained in the facility's Operating Record. Discrepancies in the volume of the waste received (a difference of more than 10% in bulk loads and an inaccurate piece count for non-bulk containers) shall be addressed with the generator and noted in the discrepancy section of the manifest. In cases where there is a difference between the analytical results obtained through verification analysis by CHCI and the generator's analytical results, CHCI shall arrange for analysis by a third laboratory and continue to resolve the discrepancy with the generator with the additional results. NEICVP1493E01 Page VI- 34 Appendix A Page 250 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 If the generator disagrees with the regulatory status of the disputed waste stream, the waste stream shall be managed at CHCI using the most conservative level (i.e., hazardous) obtained, not withstanding the generator's hazardous waste determination result. Such discrepancy shall be noted on the Bulk Load QC Form, Waste Receiving Report, and/or GWMPS and a copy kept in the facility's Operating Record. 1.6.6 Complying with LDR Requirements In accordance with 40 CFR 268.7(a), all waste streams received at CHCI that do not meet the applicable treatment standards set forth in 40 CFR 268 Subpart D must be accompanied by a written notice. Such notice shall be provided with the initial shipment of the waste stream. If the waste stream changes, the generator must provide a new notice to CHCI that includes the following: The appropriate treatment standards set forth in 40 CFR 268 Subpart D; Any additional prohibition level set forth in 40 CRR 268.32; All applicable EPA Hazardous Waste Numbers; The corresponding treatment standards and if applicable, the five-letter treatment code found in Table 1 of 40 CFR 268.42; The manifest number associated with the shipment of waste; and If available, the waste analysis data. If the generator determines that the restricted waste can be land disposed without further treatment, a notice and certification statement must be provided with each shipment of waste. Such notice information and the wording of the certification statement must comply with 40 CFR 268.7(a)(2). In accordance with 40 CFR 268.7(b) CHCI shall ensure the following: 1. For wastes received with the treatment standards expressed by the waste extract (TCLP), CHCI shall analyze an extract of the treatment residue using EPA test method 1311 to confirm that the treatment residue extract meets the applicable treatment standards in accordance with 40 CFR 268.7(b)(1). 2. For wastes with treatment standards expressed as concentrations, CHCI shall analyze the treatment residue to confirm the treatment residue meets the applicable treatment standards. 3. A one-time notice shall be sent with the initial shipment of the waste to the land disposal facility, and a copy of this notice maintained in the Operating Record for a minimum of five (5) years. If the waste changes or is sent to a new facility, a new notice shall be sent and a copy maintained on-site. Such notice shall include: a. The EPA hazardous waste codes and manifest number of the first shipment b. If subject to the LDRs, the constituents of concern for F001 to F005, and F039 wastes and the underlying hazardous constituents in characteristic wastes, unless the waste is to be treated and monitored for all constituents. c. Applicable wastewater/non-wastewater categories (40 CFR 268.2(d) and (f)) and subdivisions made within a waste code. d. Waste analysis data e. For contaminated soil subject to LDRs: the constituents subject to treatment as described in 40 CFR 268.49(d) and the following statement, "this contaminated soil [does/does not] exhibit a characteristic of hazardous waste and is [subject to/complies with] the soil treatment standards as provided by 268.49(c)." NEICVP1493E01 Page VI- 35 Appendix A Page 251 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 f. Certification in accordance with 40 CFR 268.7 4. CHCI shall ensure compliance with all certification requirements pursuant to 40 CFR 268.7. The waste analysis procedures defined under this plan will be carried out to verify the acceptability of the waste streams and ensure that the proper land ban disposal notices have been completed. Copies of all received notices, certifications and waste analysis data shall be maintained on-site for at least five (5) years from the date the waste was received. A copy of the land disposal restriction form, LDR-1, is provided in Appendix 1-9. 1.6.7 RCRA Air Requirements CHCI accepts waste streams with volatile organic concentrations greater than 500 ppm for storage only. Such wastes are subject to the RCRA Air Emission Standards of 40 CFR 264 Subparts BB and CC. Procedures to ensure compliance with Subparts BB and CC are detailed in Attachment I - Process Design and Operating Criteria of the permit renewal application. 1.6.8 Receiving and Handling Paint Waste from the PaintCare Program Upon arrival at the Facility the driver of the vehicle will check in with the Facility's Compliance Guard to verify shipment information. Once verified, the load will be inspected and received by the facility at the Truck-to-Truck dock. Upon receipt, the load will be moved to Area M2 or Area H, if there is no available capacity in M2, to be sorted based on type of paint. Latex based paint will be consolidated with other latex paint to be shipped to recycling outlets. Similarly, oil based paint will be consolidated with other oil based paints to be shipped to recycling outlets. 1.6.9 Rinsing Operations of Non-Bulk Containers, Bulk Containers, Roll-Offs, Bulk Vehicles and Other Washing or Rinsing Operations Related to Permitted Waste Management Activities CHCI rinsing operations consist of two general conventional processes after containers have been emptied or vehicles off-loaded of waste contents. These are: (1) Physical removal of containerized waste solids and, (2) Utilization of rinsing methods to remove remaining residual waste solids adhered to container surfaces. Further details are provided below. (1) Physical Removal of Containerized Waste Solids. Physical removal of containerized waste solids consists of common practices utilized to separate material that are appropriate for a particular type of container, roll-off, vehicle or waste management area. These commonly employed physical methods will use direct removal or remote insertion of equipment to remove surface layers and hazardous contaminants from structural surfaces. Under special circumstances, intrusive confined space entry techniques applying strict safety protocols may be necessary to remove accumulated bottom residues from inaccessible areas in vehicles. These removal practices consist of removing an inner container liner, poring, pumping, aspirating, sweeping, shoveling, power washing or hose washing that effectively separate, dislodge and mobilize the residual waste solids from the container, roll-off, vehicle or waste management area into a consistent physical state for alternative management. The effectiveness NEICVP1493E01 Page VI- 36 Appendix A Page 252 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Waste Analysis Plan EPA ID No. CTD000604488 Permit No. DEP/HWM-017-004 of achieving removal of residual waste solids from the container, roll-off, vehicle or waste management area is based on a physical inspection of surfaces using safe work practices. (2) Utilization of Rinsing Methods to Remove Remaining Adhered Residual Waste Solids. Rinsing practices technically begin after all containerized waste solids have been removed using practicing described above and residual solids remain adhered to surfaces. If required, a series of wash/rinse cycles may be applied to achieve objectives based on regulatory criteria, customer requests or best management practices. Based on a physical inspection, rinsing may be achieved through a single or combination of methods. These methods include low-pressure water hose application, high-pressure water spray application, surfactant solution application or a liquid phase solvent extraction procedures to achieve removal of residual solids or viscous contaminants from surfaces and surface pores. These methods will serve to mobilize adhered surface solids or viscous contaminants to enter a liquid phase and enhance flow characteristics of the wastestream. Enhanced flow characteristics allow for flushing residual debris into physical states for vacuum and/or pump removal into collection sumps, trucks or containers. Following wash/rinse methods, surfaces of non-bulk containers, bulk containers, roll-offs, bulk vehicles and waste management activity surfaces will be visually inspected to ensure that no observable residue remains within the units. If necessary for purposes of verification, quality control or regulatory requirements, representative final rinsate samples will be submitted for laboratory analysis for determination of constituents of concern. Basis of Rinsing Procedures Applications 1. Surfaces in contact with hazardous wastes that will be re-used with compatible hazardous wastes will not be rinsed. 2. Surfaces in contact with hazardous wastes that will be re-used with incompatible hazardous wastes will be rinsed. 3. Surfaces in contact with hazardous wastes that will be re-used with non-hazardous wastes will be rinsed. 4. Surfaces in contact with acute hazardous wastes and polychlorinated biphenyls will be triplerinsed, unless intended for re-use with the same waste types. NEICVP1493E01 Page VI- 37 Appendix A Page 253 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLES NEICVP1493E01 Appendix A Page 254 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1.1 Off Site Waste Characterization Table NEICVP1493E01 Appendix A Page 255 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 256 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1.2 Off Site Waste Verification Table NEICVP1493E01 Appendix A Page 257 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 258 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDICES NEICVP1493E01 Appendix A Page 259 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-1 GENERATOR WASTE MATERIAL PROFILE SHEET (GWMPS) NEICVP1493E01 Appendix A Page 260 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut WASTE MATERIAL PROFILE SHEET Clean Harbors Profile No. CH480725 A. GENERAL INFORMATION GENERATOR EPA ID #/REGISTRATION # GENERATOR CODE (Assigned by Clean Harbors) ADDRESS 1501 Washington Street CUSTOMER CODE (Assigned by Clean Harbors) ADDRESS 1501 Washington Street MAD999999999 ECOMT1 ECOMT1 GENERATOR NAME: CITY Braintree CUSTOMER NAME: CITY Braintree E Commerce Test Account 1 STATE/PROVINCE MA ZIP/POSTAL CODE PHONE: (803) 691-3525 E Commerce Test Account 1 STATE/PROVINCE MA ZIP/POSTAL CODE 02184 02184 B. WASTE DESCRIPTION WASTE DESCRIPTION: PROCESS GENERATING WASTE: IS THIS WASTE CONTAINED IN SMALL PACKAGING CONTAINED WITHIN A LARGER SHIPPING CONTAINER ? C. PHYSICAL PROPERTIES (at 25C or 77F) PHYSICAL STATE SOLID WITHOUT FREE LIQUID POWDER MONOLITHIC SOLID LIQUID WITH NO SOLIDS LIQUID/SOLID MIXTURE % FREE LIQUID % SETTLED SOLID % TOTAL SUSPENDED SOLID SLUDGE GAS/AEROSOL NUMBER OF PHASES/LAYERS 1 2 3 TOP % BY VOLUME (Approx.) MIDDLE BOTTOM 0.00 0.00 0.00 ODOR NONE MILD STRONG Describe: BOILING POINT F (C) <= 95 (<=35) 95 - 100 (35-38) 101 - 129 (38-54) >= 130 (>54) VISCOSITY (If liquid present) 1 - 100 (e.g. Water) 101 - 500 (e.g. Motor Oil) 501 - 10,000 (e.g. Molasses) > 10,000 COLOR MELTING POINT F (C) < 140 (<60) 140-200 (60-93) > 200 (>93) TOTAL ORGANIC CARBON <= 1% 1-9% >= 10% FLASH POINT F (C) < 73 (<23) 73 - 100 (23-38) 101 -140 (38-60) 141 -200 (60-93) > 200 (>93) pH <= 2 2.1 - 6.9 7 (Neutral) 7.1 - 12.4 >= 12.5 SPECIFIC GRAVITY < 0.8 (e.g. Gasoline) 0.8-1.0 (e.g. Ethanol) 1.0 (e.g. Water) 1.0-1.2 (e.g. Antifreeze) > 1.2 (e.g. Methylene Chloride) ASH < 0.1 0.1 - 1.0 1.1 - 5.0 5.1 - 20.0 > 20 Unknown BTU/LB (MJ/kg) < 2,000 (<4.6) 2,000-5,000 (4.6-11.6) 5,000-10,000 (11.6-23.2) > 10,000 (>23.2) Actual: D. COMPOSITION CHEMICAL (List the complete composition of the waste, include any inert components and/or debris. Ranges for individual components are acceptable. If a trade name is used, please supply an MSDS. Please do not use abbreviations.) MIN -- MAX UOM DOES THIS WASTE CONTAIN ANY HEAVY GAUGE METAL DEBRIS OR OTHER LARGE OBJECTS (EX., METAL PLATE OR PIPING >1/4" THICK OR >12" YES NO LONG, METAL REINFORCED HOSE >12" LONG, METAL WIRE >12" LONG, METAL VALVES, PIPE FITTINGS, CONCRETE REINFORCING BAR OR PIECES OF CONCRETE >3")? If yes, describe, including dimensions: DOES THIS WASTE CONTAIN ANY METALS IN POWDERED OR OTHER FINELY DIVIDED FORM? YES NO DOES THIS WASTE CONTAIN OR HAS IT CONTACTED ANY OF THE FOLLOWING; ANIMAL WASTES, HUMAN BLOOD, BLOOD PRODUCTS, BODY FLUIDS, MICROBIOLOGICAL WASTE, PATHOLOGICAL WASTE, HUMAN OR ANIMAL DERIVED SERUMS OR PROTEINS OR ANY OTHER POTENTIALLY INFECTIOUS MATERIAL? I acknowledge that this waste material is neither infectious nor does it contain any organism known to be a threat to human health. This certification is based on my knowledge of the material. Select the answer below that applies: YES NO The waste was never exposed to potentially infectious material. Chemical disinfection or some other form of sterilization has been applied to the waste. I ACKNOWLEDGE THAT THIS PROFILE MEETS THE CLEAN HARBORS BATTERY PACKAGING REQUIREMENTS. YES NO YES NO YES NO I ACKNOWLEDGE THAT MY FRIABLE ASBESTOS WASTE IS DOUBLE BAGGED AND WETTED. YES NO SPECIFY THE SOURCE CODE ASSOCIATED WITH THE WASTE. SPECIFY THE FORM CODE ASSOCIATED WITH THE WASTE. NEICVP1493E01 Report Printed On : Monday, January 17, 2011 Appendix A Page 261 of 612 /WINWEB/Profile\Waste Profile.rdl Clean Harbors Environmental Services, Inc. Bristol, Connecticut Page 1 of 3 Clean Harbors Profile No. CH480725 E. CONSTITUENTS Are these values based on testing or knowledge? Knowledge Testing If constituent concentrations are based on analytical testing, analysis must be provided. Please attach document(s) using the link on the Submit tab. Please indicate which constituents below apply. Concentrations must be entered when applicable to assist in accurate review and expedited approval of your waste profile. Please note that the total regulated metals and other constituents sections require answers. RCRA REGULATED METALS D004 ARSENIC 5(*8/$725< /(9(/PJO 5.0 7&/3 PJO TOTAL UOM NOT APPLICABLE D005 BARIUM 100.0 D006 CADMIUM 1.0 D007 CHROMIUM 5.0 D008 LEAD 5.0 D009 MERCURY 0.2 D010 SELENIUM 1.0 D011 SILVER 5.0 D018 D019 D021 D022 D028 D029 D035 D039 D040 D043 D023 D024 VOLATILE COMPOUNDS BENZENE CARBON TETRACHLORIDE CHLOROBENZENE CHLOROFORM 1,2-DICHLOROETHANE 1,1-DICHLOROETHYLENE METHYL ETHYL KETONE TETRACHLOROETHYLENE TRICHLOROETHYLENE VINYL CHLORIDE SEMI-VOLATILE COMPOUNDS o-CRESOL m-CRESOL 0.5 0.5 100.0 6.0 0.5 0.7 200.0 0.7 0.5 0.2 200.0 200.0 OTHER CONSTITUENTS BROMINE CHLORINE FLUORINE IODINE SULFUR POTASSIUM SODIUM AMMONIA CYANIDE AMENABLE CYANIDE REACTIVE CYANIDE TOTAL SULFIDE REACTIVE MAX UOM NOT APPLICABLE D025 D026 D027 D030 D032 D033 D034 p-CRESOL CRESOL (TOTAL) 1,4-DICHLOROBENZENE 2,4-DINITROTOLUENE HEXACHLOROBENZENE HEXACHLOROBUTADIENE HEXACHLOROETHANE 200.0 200.0 7.5 0.13 0.13 0.5 3.0 HOCs NONE < 1000 PPM >= 1000 PPM PCBs NONE < 50 PPM >=50 PPM IF PCBS ARE PRESENT, IS THE WASTE REGULATED BY TSCA 40 CFR 761? D036 D037 NITROBENZENE PENTACHLOROPHENOL 2.0 100.0 YES NO D038 PYRIDINE 5.0 D041 2,4,5-TRICHLOROPHENOL 400.0 D042 2,4,6-TRICHLOROPHENOL 2.0 PESTICIDES AND HERBICIDES D012 ENDRIN 0.02 D013 LINDANE 0.4 D014 METHOXYCHLOR 10.0 D015 TOXAPHENE 0.5 D016 2,4-D 10.0 D017 2,4,5-TP (SILVEX) 1.0 D020 CHLORDANE 0.03 D031 HEPTACHLOR (AND ITS EPOXIDE) 0.008 ADDITIONAL HAZARDS DOES THIS WASTE HAVE ANY UNDISCLOSED HAZARDS OR PRIOR INCIDENTS ASSOCIATED WITH IT, WHICH COULD AFFECT THE WAY IT SHOULD BE HANDLED? YES NO (If yes, explain) CHOOSE ALL THAT APPLY DEA REGULATED SUBSTANCE POLYMERIZABLE EXPLOSIVE RADIOACTIVE FUMING REACTIVE MATERIAL OSHA REGULATED CARCINOGENS NONE OF THE ABOVE NEICVP1493E01 Report Printed On : Monday, January 17, 2011 Appendix A Page 262 of 612 /WINWEB/Profile\Waste Profile.rdl Clean Harbors Environmental Services, Inc. Bristol, Connecticut Page 2 of 3 Clean Harbors Profile No. CH480725 F. REGULATORY STATUS YES NO USEPA HAZARDOUS WASTE? YES NO DO ANY STATE WASTE CODES APPLY? YES Texas Waste Code NO DO ANY CANADIAN PROVINCIAL WASTE CODES APPLY? YES NO IS THIS WASTE PROHIBITED FROM LAND DISPOSAL WITHOUT FURTHER TREATMENT PER 40 CFR PART 268? LDR CATEGORY: VARIANCE INFO: YES YES YES NO IS THIS A UNIVERSAL WASTE? NO IS THE GENERATOR OF THE WASTE CLASSIFIED AS CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR (CESQG)? NO IS THIS MATERIAL GOING TO BE MANAGED AS A RCRA EXEMPT COMMERCIAL PRODUCT, WHICH IS FUEL (40 CFR 261.2 (C)(2)(II))? YES YES YES YES NO DOES TREATMENT OF THIS WASTE GENERATE A F006 OR F019 SLUDGE? NO IS THIS WASTE STREAM SUBJECT TO THE INORGANIC METAL BEARING WASTE PROHIBITION FOUND AT 40 CFR 268.3(C)? NO DOES THIS WASTE CONTAIN VOC'S IN CONCENTRATIONS >=500 PPM? NO DOES THE WASTE CONTAIN GREATER THAN 20% OF ORGANIC CONSTITUENTS WITH A VAPOR PRESSURE >= .3KPA (.044 PSIA)? YES NO DOES THIS WASTE CONTAIN AN ORGANIC CONSTITUENT WHICH IN ITS PURE FORM HAS A VAPOR PRESSURE > 77 KPA (11.2 PSIA)? YES YES NO IS THIS CERCLA REGULATED (SUPERFUND ) WASTE ? NO IS THE WASTE SUBJECT TO ONE OF THE FOLLOWING NESHAP RULES? Hazardous Organic NESHAP (HON) rule (subpart G) Pharmaceuticals production (subpart GGG) YES NO IF THIS IS A US EPA HAZARDOUS WASTE, DOES THIS WASTE STREAM CONTAIN BENZENE? YES NO Does the waste stream come from a facility with one of the SIC codes listed under benzene NESHAP or is this waste regulated under the benzene NESHAP rules because the original source of the waste is from a chemical manufacturing, coke by-product recovery, or petroleum refinery process? YES NO Is the generating source of this waste stream a facility with Total Annual Benzene (TAB) >10 Mg/year? What is the TAB quantity for your facility? Megagram/year (1 Mg = 2,200 lbs) The basis for this determination is: Knowledge of the Waste Or Test Data Knowledge Testing Describe the knowledge : G. DOT/TDG INFORMATION DOT/TDG PROPER SHIPPING NAME: H. TRANSPORTATION REQUIREMENTS ESTIMATED SHIPMENT FREQUENCY ONE TIME WEEKLY MONTHLY QUARTERLY YEARLY OTHER CONTAINERIZED 0-0 CONTAINERS/SHIPMENT STORAGE CAPACITY: CONTAINER TYPE: CUBIC YARD BOX PALLET TOTE TANK OTHER: DRUM DRUM SIZE: BULK LIQUID GALLONS/SHIPMENT: 0 Min -0 Max GAL. BULK SOLID SHIPMENT UOM: TON TONS/YARDS/SHIPMENT: 0 Min - 0 Max YARD I. SPECIAL REQUEST COMMENTS OR REQUESTS: GENERATOR'S CERTIFICATION I hereby certify that all information submitted in this and attached documents is correct to the best of my knowledge. I also certify that any samples submitted are representative of the actual waste. If Clean Harbors discovers a discrepancy during the approval process, Generator grants Clean Harbors the authority to amend the profile, as Clean Harbors deems necessary, to reflect the discrepancy. AUTHORIZED SIGNATURE NAME (PRINT) TITLE DATE NEICVP1493E01 Report Printed On : Monday, January 17, 2011 Appendix A Page 263 of 612 /WINWEB/Profile\Waste Profile.rdl Clean Harbors Environmental Services, Inc. Bristol, Connecticut Page 3 of 3 APPENDIX I-2 OUTSIDE LAB CHAIN OF CUSTODY FORM NEICVP1493E01 Appendix A Page 264 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Belmont Labs The Environmental Service Company. Purchase Order No. Name Company Client Project ANALmCAL REQUEST CHAIN OF CUSTODY Name Company Mailing Address Internal Lab Order Number. ANALYSIS REQUESTED (Enter an "X" in the box below to indicate request and circle preservative) Address City, State, Zip City, State, Zip Phone No. Fax No. Date Results Req: Special Instructions: Rush Charges Authorized? D Yes D No a Fax Results Additional QC Requirements: Level 2, Level 3, Level 4 (Charges Applyl CLIENT SAMPLE IDENTIFICATION Regulatory Type D NPDES D DoD D RCRA D SDWA a VAP a Other Collected in State of Date Sampled DW - Drinking Water . GW - Ground Water S - Soil/Solid SL - Sludge -g WW - Waste Water Specify Other Time Comp Grab Matrix CHAIN OF CUSTODY (if required! Relinquished by: Relinquished by: Method of Shipment: Date/Time Date/Time Received by: Received at lab by: Cooler Temp. Custody Seals Date/Time Date/Time D Yes D No Sampled by:- Date . Client Comments NEICVP1493E01 Appendix A Clean HarDbISoTrRsIBEUnWTvIHOirITNoE:n-mLeanbtoaral tSoreyrvices, Inc. Please return completed form and samples to Belmont Labs 25 Holiday Drive EnglewoPoadg,eO2H654o5f362122 937.832.8242 Fax 937.832.2868 YELLOW -BArcisctoouln, tCinognnecticut Houston Rusinfiss Forms - Form 314374 1/11 APPENDIX I-3 BULK LOAD QC FORM NEICVP1493E01 Appendix A Page 266 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 267 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-4 PRE-ACCEPTANCE RECORD NEICVP1493E01 Appendix A Page 268 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 269 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 270 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-5 CHCI VEHICLE OFF-LOADING AUTHORIZATION FORM (VOAF) NEICVP1493E01 Appendix A Page 271 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 272 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-6 WASTE RECEIVING REPORT NEICVP1493E01 Appendix A Page 273 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 274 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-7 WASTE TYPE AND ASSOCIATED PERSONAL PROTECTIVE EQUIPMENT NEICVP1493E01 Appendix A Page 275 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 276 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 277 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-8 PERMITTED WASTE CODES NEICVP1493E01 Appendix A Page 278 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Waste Management Area Operations Building: Rinse, Crushing and Lab Pack Pour-off Stations Permitted Waste Stream Codes EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Container Storage Area H Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04 EPA Hazardous Waste Codes: D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, NEICVP1493E01 Appendix A Page 279 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Container Storage Area K Acidic Waste Waste Management Area Container Storage Area L Non-acidic or PCB-containing waste U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 Permitted Waste Stream Codes EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, NEICVP1493E01 Appendix A Page 280 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Container Storage Area M1 Acidic Wastes Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001-043 F001-019, F028-039 K001, K062 P001, P002, P007, P008, P010-012, P016, P021, P023, P026, P027, P029, P030, P034, P036-041, P044-046, P049-051, P057, P059, P060, P066, P070, P072, P075, P077, P082, P085, P087-089, P093, P094, P097, P099, P108, P109, P111, P113-116, P118-121, P123, P127, P128, P185, P189-192, P194, P196, P197-199, P202-205 U004-006, U008, U010, U011, U014-016, U018, U021, U022, U024, U026-028, U030, U034, U035, U038, U039, U042, U047-051, U058-064, U066-068, U071-074, U079-082, U085-091, U093-095, U097 U101, U102, U105-107, U109, U111, U114, U116, U119-120, U123, U126, U128, U129, U132, U134, U136, U137, U141-145, U148-152, U155, U157, U158, U163, U164, U166-170, U172-181, U183, U185-187, U191-193, U197, U200-211, U214, U215, U218, U219, U221-223, U225-227, U235238, U240, U243, U244, U247, U248, U271, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Container Storage Area M2 Alkaline and Paint Care Program Wastes Non-RCRA Hazardous Waste Codes: CR01, CR02, CR03 CR04, CR05 EPA Hazardous Waste Codes: D001-043 F001-019, F028-039 K001, K062 P010-012, P029, P072, P075, P099, P108, P119-121, P201 U022, U049, U067, U072, U128, U132, U134, U136, U144, U167-169, U174, U197, U208, U209, U211, U217, U218, U240 Non-RCRA Hazardous Waste Codes: CR04, CR05 NEICVP1493E01 Appendix A Page 281 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Waste Management Area Waste Storage Tank No. 11 Permitted Waste Stream Codes Non-RCRA Hazardous Waste Codes: CR04 Waste Storage Tank No. 14 EPA Hazardous Waste Codes: D002, D004, D005, D006, D007, D008, D009, D010, D011, D018, D019, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F032, F034, F035, F037, F038, F039 P001, P002, P007, P010, P021, P026, P030, P036, P037, P039, P040, P041, P044, P045, P046, P049, P057, P059, P066, P070, P072, P082, P085, P087, P088, P089, P093, P094, P097, P111, P113, P114, P115, P116, P118, P119, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U005, U010, U014, U015, U016, U018, U021, U024, U026, U035, U038, U039, U047, U049, U051, U058, U059, U060, U061, U062, U063, U067, U068, U073, U081, U082, U087, U089, U090, 091, U094, U095, U101, U114, U116, U119, U122, U129, U141, U142, U143, U145, U148, U150, U151, U155, U157, U164, U166, U167, U168, U172, U173, U174, U177, U178, U179, U180, U181, U183, U185, U187, U192, U193, U197, U200, U202, U203, U214, U215, U218, U219, U221, U222, U225, U235, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410 Bulk Unloading and Loading Area Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04 D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: NEICVP1493E01 Appendix A Page 282 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Container Storage Area C Flammable Wastes CR02, CR03, CR04 EPA Hazardous Waste Codes: D001-043 F001-019, F028-039 K001, K062 U122, U278 Mix-Tub, Bulk Transfer Area Storage Non-RCRA Hazardous Waste Codes: CR04, CR05 and EPA Hazardous Waste Codes: D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, U034, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U213, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Container Storage Building: Container Storage Area A Acid-reactive waste Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D002-043 F001-019, F028-039 K001, K062 P011, P012, P072, P119-121, P201 U021, U022, U049, U067, U167-169, U174, U197, U217, U218 Container Storage Area B Rows 1 thru 7 (B#1): Alkaline wastes Rows 8 thru 10 B (#2): Universal and Solid Wastes Non-RCRA Hazardous Waste Codes: CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, NEICVP1493E01 Appendix A Page 283 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Container Storage Area D Toxic waste PCB-containing waste F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, NEICVP1493E01 Appendix A Page 284 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Container Storage Area E Toxic waste PCB-containing waste Container Storage Area F Toxic waste U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, NEICVP1493E01 Appendix A Page 285 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Container Storage Area G Acidic waste Container Storage Area J U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 NEICVP1493E01 Appendix A Page 286 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Loading/Unloading Dock Area P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 NEICVP1493E01 Appendix A Page 287 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Analysis Plan Appendix I-8 Permitted Waste Codes Truck Parking Areas Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 EPA Hazardous Waste Codes: D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011, D012, D013, D014, D015, D016, D017, D018, D019, D020, D021, D022, D023, D024, D025, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037, D038, D039, D040, D041, D042, D043 F001, F002, F003, F004, F005, F006, F007, F008, F009, F010, F011, F012, F019, F028, F032, F034, F035, F037, F038, F039 K001 P001, P002, P007, P010, P016, P021, P023, P026, P027, P030, P034, P036, P037, P038, P039, P040, P041, P044, P045, P046, P049, P050, P051, P057, P059, P060, P066, P070, P072, P075*, P077, P082, P085, P087, P088, P089, P093, P094, P097, P099, P109, P111, P113, P114, P115, P116, P118, P119, P123, P127, P128, P185, P189, P190, P191, P192, P194, P196, P197, P198, P199, P201, P202, P203, P204, P205 *P075 - for nicotine and salts in lab pack quantities, only. U004, U005, U006, U010, U011, U014, U015, U016, U018, U021, U024, U026, U027, U028, U030, UO34, U035, U036, U038, U039, U042, U047, U048, U049, U050, U051, U058, U059, U060, U061, U062, U063, U064, U066, U067, U068, U071, U073, U074, U079, U080, U081, U082, U085, U086, U087, U088, U089, U090, U091, U093, U094, U095, U097, U101, U102, U105, U106, U107, U109, U111, U114, U116, U119, U120, U122, U126, U129, U137, U141, U142, U143, U145, U148, U149, U150, U151, U152, U155, U157, U158, U163, U164, U166, U167, U168, U170, U172, U173, U174, U175, U176, U177, U178, U179, U180, U181, U183, U185, U186, U187, U191, U192, U193, U197, U200, U201, U202, U203, U204, U205, U206, U207, U210, U214, U215, U217, U218, U219, U221, U222, U223, U225, U226, U227, U235, U236, U237, U238, U243, U244, U247, U248, U271, U278, U279, U280, U364, U367, U372, U373, U387, U389, U394, U395, U409, U410, U411 Non-RCRA Hazardous Waste Codes: CR02, CR03, CR04, CR05 NEICVP1493E01 Appendix A Page 288 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-9 LAND DISPOSAL RESTRICTION FORMS NEICVP1493E01 Appendix A Page 289 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. CONTINUATION SHEET FOR USE WITH LAND DISPOSAL RESTRICTION NOTIFICATION FORM LDR-1 MANIFEST NO_____________________________ SECTION IV. OTHER LISTED WASTES (F006-12, F019-F028, F037-38, F039, K-, U-, AND P-CODES) CONTINUED FROM PAGE 3 OF FORM LDR-1 COLUMN 1: LINE ITEM SEE MANIFEST COLUMN 2: WASTE CODE / SUBCATEGORY COLUMN 3: WASTEWATER/ NON-WASTEWATER COLUMN 4: HANDLING CODE _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ ________________________________________________________ [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 NEICVP1493E01 Form LDR-1 Continuation Sheet, Page_____ of _____ [Revised 2/24/95] Appendix A Clean Harbors Environmental Services, Inc. Page 290 of 612 Bristol, Connecticut SECTION I. WASTE CODES ELIGIBLE FOR ALTERNATIVE TREATMENT STANDARD [ ] Check here if the lab pack contains only those hazardous wastes codes which are NOT listed in 40 CFR Appendix IV (see Key Terms below), and which is intended for incineration in accordance with the alternative treatment standard in 40 CFR 268.42(c). If checked, complete the lab pack certification statement in Section II. [ ] Check here if the lab pack contains one or more hazardous waste codes identified in 40 CFR Part 268 Appendix IV (see Key Terms below). If checked, the lab pack IS NOT eligible for the alternative lab pack treatment standard. SECTION II. GENERATOR CERTIFICATION AND SIGNATURE (REQUIRED) I CERTIFY UNDER PENALTY OF LAW THAT I PERSONALLY HAVE EXAMINED AND AM FAMILIAR WITH THE WASTE AND THAT THE LAB PACK CONTAINS ONLY WASTES THAT HAVE NOT BEEN EXCLUDED UNDER APPENDIX IV TO 40 CFR PART 268 AND THAT THIS LABPACK WILL BE SENT TO A COMBUSTION FACILITY IN COMPLIANCE WITH THE ALTERNATIVE TREATMENT STANDARDS FOR LABPACKS AT 40 CFR 268.42(c). I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING A FALSE CERTIFICATION, INCLUDING THE POSSIBILITY OF FINE OR IMPRISONMENT. Authorized Signature: ____________________________________________________ Date: ___________________________ KEY TERMS/DEFINITIONS LAB PACK means waste materials classed as US DOT Class or Division 3, 4.1, 4.2, 4.3, 5.1, 6.1, 8, or 9. Outer packaging must be either open head steel, aluminum, fiber, plastic or plywood drum, meeting at least packing group III performance levels. Each outer packaging must contain only one class of hazardous material. Inner containers may be glass not exceeding 1 gallon capacity, or metal or plastic not exceeding 5.3 gallons capacity. Gross weight of the container may not exceed 452 pounds. Inner packagings containing liquids must have sufficient absorbent material to absorb all liquid contents. [See 49 CFR 172.13] PART 268 APPENDIX IV means the following waste codes identified in 40 CFR 268 Appendix IV which are not eligible for treatment using the alternative lab pack treatment standard in 40 CFR 268.42(c): D009, F019, K003, K004, K005, K006, K062, K071, K100, K106, P010, P011, P012, P076, P078, U134, and U151. NEICVP1493E01 Appendix A Page 291 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION FORM LDR-1 MANIFEST NO_____________________________ THE HAZARDOUS WASTES IDENTIFIED ON THE HAZARDOUS WASTE MANIFEST IDENTIFIED ABOVE AND BEARING THE EPA HAZARDOUS WASTE CODES LISTED BELOW ARE RESTRICTED WASTES WHICH ARE PROHIBITED FROM LAND DISPOSAL WITHOUT FURTHER TREATMENT UNDER THE LAND DISPOSAL RESTRICTIONS, 40 CFR PART 268 .7 (a)(2), AND RCRA SECTION 3004(D). IN ACCORDANCE WITH 40 CFR 268.7(a), THE EPA WASTE CODE, WASTE SUBCATEGORY, AND TREATABILITY GROUPS, AS APPLICABLE, ARE INCLUDED BELOW. INSTRUCTIONS -- COMPLETE ALL SECTIONS. REFER TO PAGE 3 OF THIS FORM FOR KEY TERMS/DEFINITIONS. Column 1 - Line Item: Enter the manifest line item number (e.g., 11a) that corresponds to the waste code(s). Column 2 - Waste Codes/Subcategory: Check off all applicable waste codes. For D001 through D043, also check applicable subcategory; for F001 through F005, check applicable constituents. Column 3 - Wastewater/Non-wastewater: Check off "WW" for wastewater and "Non-WW" for non-wastewaters. Column 4 - LDR Handling Code: Circle the appropriate handling code, as follows: 1 = The waste is a characteristic hazardous waste D001, D002, D003, D004-D011, or D018-43 which is intended for treatment/disposal in a CWA system, CWA-equivalent system, or Class I SDWA system. Underlying Hazardous Constituents (UHC's) are NOT required to be identified. 1A = The waste is a characteristic hazardous waste D001 High TOC Ignitable Liquids Subcategory (i.e., greater than or equal to 10% TOC). Pursuant to 40 CFR 268.40, the waste must be treated using organic recovery (RORGS) or combustion (CMBST) technology. UHC's are NOT required to be identified. 2 = The waste is a characteristic hazardous waste D001 (other than High TOC Ignitable Liquids), D002, D003 Explosive, Water Reactive or Other Reactive subcategory, D004-D011, D012-17 non-wastewater, or D018-43 which is intended for treatment/disposal in a non-CWA system, non-CWA-equivalent system, or non-Class I SDWA system located in the United States. All UHC's which are reasonably expected to be present must be identified, except for D001 waste that is intended to be treated using organic recovery (RORGS) or combustion (CMBST) technologies. Identify UHC's by completing Sections I and IV of CHI Form LDR-1 Addendum and attach completed Addendum to this form. 3 = The waste is a characteristic (i.e., D-code) or listed (i.e., F-, K-, U-, or P-code) hazardous waste which is intended for export and treatment/disposal at a facility located outside the United States. LDR treatment standards do not apply to hazardous waste treated/disposed in a foreign country, and per USEPA guidance, the identification of UHC's (if applicable) is not required for hazardous waste that is intended to be exported. Note however that if the exported waste is subsequently returned for treatment/disposal in the United States, all applicable LDR regulations would apply and a revised LDR notification would be required. 4 = The waste meets the definition of hazardous debris pursuant to 40 CFR 268.2(h) and is intended for treatment/ disposal in compliance with the alternate debris treatment technologies of 40 CFR 268.45. In accordance with the requirements of 40 CFR 268.7(a)(2) : the contaminants subject to treatment (CSTT's) must be identified as part of this notification. Identify CSTT's by completing Section III and IV of the CHI Form LDR-1 Addendum and attach completed Addendum to this form. These constituents are being treated to comply with 40 CFR 268.45. 5 = The waste is a characteristic waste D003 Reactive Sulfide, Reactive Cyanide, or Unexploded Ordnance subcategory, a characteristic waste D012- 17 wastewater, or a listed (i.e., F-, K-, U-, or P-code) hazardous waste. UHC's are NOT required to be identified. 6 = The waste is a lab pack that is intended for incineration using the alternative lab pack treatment standard under 40 CFR 268.42(c). UHC's are NOT required to be identified; however, the generator must complete and attach the lab pack certification statement on CHI Form LDR-LP. Note that in accordance with 40 CFR Part 268 Appendix IV, lab packs which contain waste codes D009, F019, K003, K004, K005, K006, K062, K071, K100, K106, P010, P011, P012, P076, P078, U134, and U151 are not eligible for alternative lab pack treatment standard. *** NOTE: IF THE WASTE IS A SOIL CONTAMINATED WITH A LISTED OR CHARACTERISTIC WASTE AND THE GENERATOR WANTS TO USE THE ALTERNATE TREATMENT STANDARD FOR SOILS, CONTACT CORPORATE COMPLIANCE FOR THE APPROPRIATE LDR NOTIFICATION FORM. SECTION I. CHARACTERISTIC WASTES D001 THROUGH D043 COLUMN 1: LINE ITEM SEE MANIFEST COLUMN 2: WASTE CODE / SUBCATEGORY COLUMN 3: WASTEWATER/ NON-WASTEWATER COLUMN 4: HANDLING CODE __________ __________ __________ __________ ___________ [ ] D001 Ignitables, except High TOC subcategory [ ] WW [ ] Non-WW [ ] D001 High TOC Ignitable Liquids Subcategory [ ] Non-WW only (Greater than or equal to 10% TOC) [ ] D002 Corrosives [ ] WW [ ] Non-WW [ ] D003 [ ] Reactive Sulfide, per 261.23 (a)(5) [ ] WW [ ] Non-WW [ ] Reactive Cyanide, per 261.23(a)(5) [ ] WW [ ] Non-WW [ ] Explosive, per 261.23(a)(6), (7) & (8) [ ] WW [ ] Non-WW [ ] Water Reactive, per 261.23(a)(2), (3) & (4) [ ] Non-WW only [ ] Other Reactive, per 261.23(a)(1) [ ] WW [ ] Non-WW [ ] Unexploded Ordnance, Emergency Response [ ] WW [ ] Non-WW [ ] D004 Arsenic [ ] WW [ ] Non-WW 1 2 3 4 6 1A 3 6 1 2 3 4 6 1 3 4 5 6 1 3 4 5 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 3 4 5 6 1 23 4 6 ___________ [ ] D005 Barium [ ] WW [ ] Non-WW 123 4 6 ___________ ___________ ___________ NEICVP1493E01 [ ] D006 [ ] Cadmium [ ] Cadmium Containing Batteries [ ] D007 Chromium [ ] D008 [ ] Lead [ ] Lead Acid Batteries Appendix A Page 292 of 612 [ ] WW [ ] Non-WW [ ] Non-WW only [ ] WW [ ] Non-WW 1 2 3 4 6 2 3 6 1 2 3 4 6 [ ] WW [ ] Non-WW [ ] Non-WW only 1 2 3 4 6 2 3 6 Clean Harbors Environmental Services, Inc. CHI Form LDR-1, Page 1 of 3 Bris[tEolf,feCcotinvnee1c2ti/c0u7t/05] CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION NOTIFICATION FORM LDR-1 ADDENDUM Manifest No.______________________ SECTION I. UNDERLYING HAZARDOUS CONSTITUENTS (UHC'S) [ ] Check here if one or more of the constituents listed in Section IV below are reasonably expected to be present as an "Underlying Hazardous Constituent" in the waste. Then in Section IV, check off each constituent. Note that per the definition of UHC in 40 CFR 268.2, fluoride, selenium, sulfides, vanadium and zinc are NOT regulated as UHC's. [ ] Check here if NONE of the UHC constituents listed in Section IV are expected to be present in the waste. SECTION II. MULTI-SOURCE LEACHATE (WASTE CODE F039) [ ] Check here if one or more of the constituents listed in Section IV are present as a constituent in the multi-source leachate (F039) waste. Then in Section IV below, check off each constituent. Note that constituents which are identified by an asterisk (*) are NOT regulated as F039 constituents. [ ] Check here if NONE of the F039 constituents listed in Section IV are present in the waste. SECTION III. HAZARDOUS DEBRIS CONTAMINANTS SUBJECT TO TREATMENT (CSTT) [ ] Check here if one or more of the constituents listed in Section IV is a CSTT for hazardous debris that is intended for treatment using the alternate treatment technologies in 40 CFR 268.45. To identify CSTT's, refer to the "Regulated Hazardous Constituent" column in the Treatment Standard Table in 40 CFR 268.40. Then, in Section IV below, check off the constituents that appear for each waste code used to identify the debris. [ ] Check here if the entry in the "Regulated Hazardous Constituent" column in the Treatment Standard Table in 40 CFR 268.40 is "Not Applicable" , i.e. D001, D002, and D003 (non-cyanides subcategories only). SECTION IV. LIST OF CONSTITUENTS - INCLUDE MANIFEST LINE ITEM 34._____ [ ] 35._____ [ ] 36._____ [ ] 37._____ [ ] 38._____ [ ] 39._____ [ ] 40._____ [ ] 41._____ [ ] 42._____ [ ] 251.____ [ ] 43._____ [ ] 44._____ [ ] 45._____ [ ] 46._____ [ ] 47._____ [ ] 48._____ [ ] 49._____ [ ] 50._____ [ ] 51._____ [ ] 52._____ [ ] 53._____ [ ] 252.____ [ ] 54._____ [ ] 253.____ [ ] 255.____ [ ] 55._____ [ ] 56._____ [ ] 57._____ [ ] 58._____ [ ] from 59._____ [ ] from 60._____ [ ] 61._____ [ ] 62._____ [ ] 63._____ [ ] 64._____ [ ] 65._____ [ ] 66._____ [ ] 256.____ [ ] 67._____ [ ] 68._____ [ ] 69._____ [ ] 257.____ [ ] 258.____ [ ] 259.____ [ ] Acenaphthylene Acenaphthene Acetone Acetonitrile Acetophenone 2-Acetylaminofluorene Acrolein Acrylamide (*) Acrylonitrile Aldicarb sulfone (*) Aldrin 4-Aminobiphenyl Aniline Anthracene Antimony Aramite Arsenic alpha-BHC beta-BHC delta-BHC gamma-BHC Barban (*) Barium Bendiocarb (*) Benomyl (*) Benzene Benz(a)anthracene Benzal chloride (*) Benzo(b)fluoranthene (difficult to distinguish Benzo(k)fluoranthene) Benzo(k)fluoranthene (difficult to distinguish Benzo(b)fluoranthene) Benzo(g,h,i)perylene Benzo(a)pyrene Berylium Bromodichloromethane Bromomethane (Methyl bromide) 4-Bromophenyl phenyl ether n-Butyl alcohol Butylate (*) Butyl benzyl phthalate 2-sec-Butyl-4,6-dinitrophenol (Dinoseb) Cadmium Carbaryl (*) Carbendazim (*) Carbofuran (*) 260.____ [ ] 70. ______ [ 71. ______ [ 261. _____ [ 72. ______ [ 73. ______ [ 74. ______ [ 75. ______ [ 76. ______ [ 77. ______ [ 78. ______ [ 79. ______ [ 80. ______ [ 81. ______ [ 82. ______ [ 83. ______ [ 84. ______ [ 85. ______ [ 86. ______ [ 87. ______ [ 88. ______ [ 89. ______ [ 90. ______ [ 91. ______ [ 92. ______ [ 93. ______ [ 262. _____ [ 94. ______ [ 95. ______ [ 263. _____ [ 96. ______ [ 97. ______ [ 98. ______ [ 99. ______ [ 100. _____ [ 101. _____ [ 102. _____ [ 103. _____ [ 104. _____ [ 105. _____ [ 106. _____ [ 107. _____ [ 108. _____ [ 109. _____ [ 110. _____ [ 111. _____ [ Carbofuran phenol (*) ] Carbon disulfide ] Carbon tetrachloride ] Carbosulfan (*) ] Chlordane (alpha and gamma isomers) ] p-Chloroaniline ] Chlorobenzene ] Chlorobenzilate ] 2-Chloro-1,3-butadiene ] Chlorodibromomethane ] Chloroethane ] bis(2-Chloroethoxy)methane ] bis(2-Chloroethyl)ether ] Chloroform ] bis(2-Chloroisopropyl)ether ] p-Chloro-m-cresol ] 2-Chloroethyl vinyl ether (*) ] Chloromethane (Methyl Chloride) ] 2-Chloronaphthalene ] 2-Chlorophenol ] 3-Chloropropylene ] Chromium (Total) ] Chrysene ] o-Cresol ] m-Cresol (difficult to distinguish from p-Cresol) ] p-Cresol (difficult to distinguish from o-Cresol) ] m-Cumenyl methylcarbamate (*) ] Cyanides (Total) ] Cyanides (Amenable) ] Cycloate (*) ] Cyclohexanone ] 1,2-Dibromo-3-chloropropane ] 1,2-Dibromoethane (Ethylene dibromide) ] Dibromomethane ] 2,4-Dichlorophenoxyacetic acid (2,4-D) ] o,p'-DDD ] p,p'-DDD ] o,p'-DDE ] p,p'-DDE ] o,p'-DDT ] p,p'-DDT ] Dibenz(a,h)anthracene ] Dibenzo(a,e)pyrene ] m-Dichlorobenzene ] o-Dichlorobenzene ] p-Dichlorobenzene NEICVP1493E01 CHI Form LDR-1 Addendum, Page 1 of 3 [REVISED 02/29/00] Appendix A Clean Harbors Environmental Services, Inc. Page 293 of 612 Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION NOTIFICATION FORM LDR-1 ADDENDUM Manifest No.______________________ 112. _____ [ ] 113. _____ [ ] 114. _____ [ ] 115. _____ [ ] 116. _____ [ ] 117. _____ [ ] 118. _____ [ ] 119. _____ [ ] 120. _____ [ ] 121. _____ [ ] 122. _____ [ ] 123. _____ [ ] 124. _____ [ ] 125. _____ [ ] 126. _____ [ ] 127. _____ [ ] 128. _____ [ ] 129. _____ [ ] 130. _____ [ ] 131. _____ [ ] 132. _____ [ ] 133. _____ [ ] 134. _____ [ ] 135. _____ [ ] 136. _____ [ ] 137. _____ [ ] from 138. _____ [ ] 139. _____ [ ] 266. _____ [ ] 140. _____ [ ] 141. _____ [ ] 142. _____ [ ] 143. _____ [ ] 144. _____ [ ] 267. _____ [ ] 145. _____ [ ] 146. _____ [ ] 147. _____ [ ] 148. _____ [ ] 149. _____ [ ] 150. _____ [ ] 151. _____ [ ] 152. _____ [ ] 153. _____ [ ] 154. _____ [ ] 155. _____ [ ] 268. _____ [ ] 156. _____ [ ] 157. _____ [ ] 158. _____ [ ] 159. _____ [ ] 160. _____ [ ] 161. _____ [ ] 162. _____ [ ] 163. _____ [ ] 164. _____ [ ] 165. _____ [ ] 270. _____ [ ] 166. _____ [ ] 167. _____ [ ] 168. _____ [ ] 169. _____ [ ] 170. _____ [ ] 171. _____ [ ] 172. _____ [ ] 173. _____ [ ] 174. _____ [ ] 175. _____ [ ] Dichlorodifluoromethane 1,1-Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethylene trans-1,2-Dichloroethylene 2,4-Dichlorophenol 2,6-Dichlorophenol 1,2-Dichloropropane cis-1,3-Dichloropropylene trans-1,3-Dichloropropylene Dieldrin Diethyl phthalate 2,4-Dimethyl phenol Dimethyl phthalate Di-n-butyl phthalate 1,4-Dinitrobenzene 4,6-Dinitro-o-cresol 2,4-Dinitrophenol 2,4-Dinitrotoluene 2,6-Dinitrotoluene Di-n-octyl phthalate p-Dimethylaminoazobenzene (*) Di-n-propylnitrosoamine 1,4-Dioxane (*) Diphenylamine (difficult to distinguish from Diphenylnitrosamine (difficult to distinguish diphenylamine) 1,2-Diphenylhydrazine Disulfoton Dithiocarbamates (Total) (*) Endosulfan I Endosulfan II Endosulfan sulfate Endrin Endrin aldehyde EPTC (*) Ethyl acetate Ethyl cyanide (propanenitrile) Ethyl benzene Ethyl ether bis(2-Ethylhexyl)phthalate Ethyl methacrylate Ethylene oxide Famphur Fluoranthene Fluorene Fluoride Formetanate hydrochloride (*) Heptachlor Heptachlor epoxide Hexachlorobenzene Hexachlorobutadiene Hexachlorocylopentadiene HxCDDs (All hexachlorodibenzo-p-dioxins) HxCDFs (All hexachlorodibenzo-furans) Hexachloroethane Hexachloropropylene Indeno (1,2,3-c,d)pyrene 3-Iodo-2-propynyl n-butylcarbamate (*) Iodomethane Isobutyl alcohol Isodrin Isosafrole Kepone Lead Mercury--Nonwastewater from Retort Mercury--All others Methacrylonitrile Methanol 176. _____ [ ] 272. _____ [ ] 273. _____ [ ] 177. _____ [ ] 178. _____ [ ] 179. _____ [ ] 180. _____ [ ] 181. _____ [ ] 182. _____ [ ] 183. _____ [ ] 184. _____ [ ] 185. _____ [ ] 274. _____ [ ] 275. _____ [ ] 276. _____ [ ] 186. _____ [ ] 187. _____ [ ] 188. _____ [ ] 189. _____ [ ] 190. _____ [ ] 191. _____ [ ] 192. _____ [ ] 193. _____ [ ] 194. _____ [ ] 195. _____ [ ] 196. _____ [ ] 197. _____ [ ] 198. _____ [ ] 199. _____ [ ] 200. _____ [ ] 201. _____ [ ] 277. _____ [ ] 202. _____ [ ] 203. _____ [ ] 278. _____ [ ] 204. _____ [ ] 205. _____ [ ] 206. _____ [ ] 207. _____ [ ] 208. _____ [ ] 209. _____ [ ] 210. _____ [ ] 211. _____ [ ] 212. _____ [ ] 213. _____ [ ] 214. _____ [ ] 215. _____ [ ] 280. _____ [ ] 281. _____ [ ] 282. _____ [ ] 216. _____ [ ] 283. _____ [ ] 284. _____ [ ] 285. _____ [ ] 217. _____ [ ] 218. _____ [ ] 219. _____ [ ] 220. _____ [ ] 221. _____ [ ] 222. _____ [ ] 223. _____ [ ] 224. _____ [ ] 225. _____ [ ] 226. _____ [ ] 227. _____ [ ] 228. _____ [ ] 229. _____ [ ] 230. _____ [ ] Methapyrilene Methiocarb (*) Methomyl (*) Methoxychlor 3-Methylcholanthrene 4,4-Methylene-bis(2-chloroaniline) Methylene chloride Methyl ethyl ketone Methyl isobutyl ketone Methyl methacrylate Methyl methansulfonate Methyl parathion Metolcarb (*) Mexacarbate (*) Molinate (*) Naphthalene 2-Naphthylamine Nickel o-Nitroaniline (*) p-Nitroaniline Nitrobenzene 5-Nitro-o-toluidine o-Nitrophenol (*) diphenylnitrosamine) p-Nitrophenol N-Nitrosodiethylamine N-Nitrosodimethylamine N-Nitroso-di-n-butylamine N-Nitrosomethylethylamine N-Nitrosomorpholine N-Nitrosopiperidine N-Nitrosopyrrolidine Oxamyl (*) Parathion Total PCBs (sum of all PCB isomers, or all Arochlors) Pebulate (*) Pentachlorobenzene PeCDDs (All pentachlorodibenzo- p-dioxins) PeCDFs (All pentachlorodibenzofurans) Pentachloroethane (*) Pentachloronitrobenzene Pentachlorophenol Phenacetin Phenanthrene Phenol Phorate Phthalic acid (*) Phthalic anhydride Physostigmine (*) Physostigmine salicylate (*) Promecarb (*) Pronamide Propham (*) Propoxur (*) Prosulfocarb (*) Pyrene Pyridine Safrole Selenium Silver Silvex (2,4,5-TP) Sulfide 2,4,5-T (2,4,5-Trichlorophenoxyacetic acid) 1,2,4,5-Tetrachlorobenzene TCDDs (All tetrachlorodibenzo- p-dioxins) TCDFs (All tetrachlorodibenzofurans) 1,1,1,2-Tetrachloroethane 1,1,2,2-Tetrachloroethane Tetrachloroethylene NEICVP1493E01 CHI Form LDR-1 Addendum, Page 2 of 3 [REVISED 02/29/00] Appendix A Clean Harbors Environmental Services, Inc. Page 294 of 612 Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION NOTIFICATION FORM LDR-1 ADDENDUM Manifest No.______________________ 231. _____ [ ] 232. _____ [ ] 286. _____ [ ] 287. _____ [ ] 233. _____ [ ] 234. _____ [ ] 289. _____ [ ] 235. _____ [ ] 236. _____ [ ] 237. _____ [ ] 238. _____ [ ] 239. _____ [ ] 240. _____ [ ] 2,3,4,6-Tetrachlorophenol Thallium Thiodicarb (*) Thiophanate-methyl (*) Toluene Toxaphene Triallate (*) Tribromomethane (Bromoform) 1,2,4-Trichlorobenzene 1,1,1-Trichloroethane 1,1,2-Trichloroethane Trichloroethylene Trichloromonofluoromethane 241. _____ [ ] 242. _____ [ ] 243. _____ [ ] 244. _____ [ ] 290. _____ [ ] 245. _____ [ ] 246. _____ [ ] 291. _____ [ ] 247. _____ [ ] 248. _____ [ ] 249. _____ [ ] 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol 1,2,3-Trichloropropane 1,1,2-Trichloro-1,2,2-trifluoroethane Triethylamine (*) tris-(2,3-Dibromopropyl)phosphate Vanadium (*) Vernolate (*) Vinyl chloride Xylenes--mixed isomers (sum of o-, m-, and pxylene concentrations) Zinc (*) KEY TERMS/DEFINITIONS CONTAMINANTS SUBJECT TO TREATMENT (CSTT) are the specific constituents listed by waste code number in the Treatment Standard Table in 268.40. CSTT's must be identified for all hazardous debris wastes that are intended for treatment using one of the hazardous debris alternate treatment technologies described in 268.45. REASONABLY EXPECTED TO BE PRESENT means that the generator is relying on knowledge of the raw materials used, the process, and potential reaction products, or on the results of a one-time analysis for the entire list of UHC's that may be present in the untreated hazardous waste. If a one-time analysis of the entire list of UHC's is conducted, subsequent analyses are required for only those pollutants which would reasonably be expected to be present in the waste as generated, based on the previous sampling and analysis results. UNDERLYING HAZARDOUS CONSTITUENT (UHC) means any constituent listed in 268.48 Table UTS - Universal Treatment Standards (except fluoride, selenium, sulfides, vanadium and zinc) which can reasonably be expected to be present at the point of generation of the hazardous waste, at a concentration above the constituent-specific UTS treatment standard. [See 40 CFR 268.2] NEICVP1493E01 CHI Form LDR-1 Addendum, Page 3 of 3 [REVISED 02/29/00] Appendix A Clean Harbors Environmental Services, Inc. Page 295 of 612 Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION FORM LDR-1 SECTION I. CHARACTERISTIC WASTES D001-43 (CONTINUED) COLUMN 1: LINE ITEM SEE MANIFEST COLUMN 2: WASTE CODE / SUBCATEGORY ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________ [ ] D009 [ ] Low Mercury, less than 260 mg/kg Mercury [ ] High Mercury Organic Subcategory [ ] High Mercury Inorganic Subcategory [ ] D010 Selenium [ ] D011 Silver [ ] D012 Endrin [ ] D013 Lindane [ ] D014 Methoxychlor [ ] D015 Toxaphene [ ] D016 2,4-D [ ] D017 2,4,5-TP (Silvex) [ ] D018 Benzene [ ] D019 Carbon tetrachloride [ ] D020 Chlordane [ ] D021 Chlorobenzene [ ] D022 Chloroform [ ] D023 o-Cresol [ ] D024 m-Cresol [ ] D025 p-Cresol [ ] D026 Cresol [ ] D027 1,4-Dichlorobenzene [ ] D028 1,2-Dichloroethane [ ] D029 1,1-Dichloroethylene [ ] D030 2,4-Dinitrotoluene [ ] D031 Heptachlor (and its epoxide) [ ] D032 Hexachlorobenzene [ ] D033 Hexachlorobutadiene [ ] D034 Hexachloroethane [ ] D035 Methyl ethyl ketone [ ] D036 Nitrobenzene [ ] D037 Pentachlorophenol [ ] D038 Pyridine [ ] D039 Tetrachloroethylene [ ] D040 Trichloroethylene [ ] D041 2,4,5-Trichlorophenol [ ] D042 2,4,6-Trichlorophenol [ ] D043 Vinyl Chloride MANIFEST NO_____________________________ COLUMN 3: WASTEWATER/ NON-WASTEWATER [ ] WW [ ] Non-WW [ ] Non-WW only [ ] Non-WW only [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW [ ] WW [ ] Non-WW COLUMN 4: HANDLING CODE 1 2 3 4 2 3 4 2 3 4 1 2 3 4 6 1 2 3 4 6 2 3 4 5 6 2 3 4 5 6 2 3 4 5 6 2 3 4 5 6 2 3 4 5 6 2 3 4 5 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 1 2 3 4 6 SECTION II. SPENT SOLVENT WASTES F001 THROUGH F005 COLUMN 1: LINE ITEM SEE MANIFEST ____________ COLUMN 2: WASTE CODE / SUBCATEGORY [ ] F001 [ ] F002 [ ] F003 [ ] F004 [ ] F005 COLUMN 3: WASTEWATER/ NON-WASTEWATER [ ] WW [ ] Non-WW COLUMN 4: HANDLING CODE 3 4 5 6 ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ [ ] 1. ALL F001-F005 [ ] 2. Acetone [ ] 3. Benzene [ ] 4. n-Butyl alcohol [ ] 5. Carbon disulfide [ ] 6. Carbon tetrachloride [ ] 7. Chlorobenzene [ ] 8. o-Cresol [ ] 9. m-Cresol (difficult to distinguish from p-cresol) [ ] 10. p-Cresol (difficult to distinguish from ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ m-cresol) [ ] 11. Cresol - mixed isomers (sum of o-, m- and p-cresol) ______ NEICVP1493E01 [ ] 12. Cyclohexanone [ ] 13. o-Dichlorobenzene [ ] 14. 2-Ethoxyethanol (F005) only) [ ] 15. Ethyl acetate [ ] 16. Ethyl benzene [ ] 17. Ethyl ether [ ] 18. Isobutyl alcohol [ ] 19. Methanol [ ] 20. Methylene chloride [ ] 21. Methyl ethyl ketone [ ] 22. Methyl isobutyl ketone [ ] 23. Nitrobenzene [ ] 24. 2-Nitropropane (F005 only) ______ ______ ______ ______ ______ ______ ______ ______ ______ [ ] 25. Pyridine [ ] 26. Tetrachloroethylene [ ] 27. Toluene [ ] 28. 1,1,1-Trichloro- ethane [ ] 29. 1,1,2-Trichloro- ethane [ ] 30. Trichloroethylene [ ] 31. 1,1,2-Trichloro- 1,2,2-trifluoroethane [ ] 32.Trichloromonofluoro- methane [ ] 33. Xylene - mixed isomers (sum of o-, m-, and p-xylene) Appendix A Page 296 of 612 CHI Form LDR-1, Page 2 of 3 [Effective 12/07/05] Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. LAND DISPOSAL RESTRICTION FORM LDR-1 MANIFEST NO_____________________________ SECTION III. CALIFORNIA LIST WASTES COLUMN 1: LINE ITEM SEE MANIFEST COLUMN 2: WASTE CODE / SUBCATEGORY COLUMN 3: WASTEWATER/ NON-WASTEWATER COLUMN 4: HANDLING CODE ____________ Hazardous waste containing one or more of the following [ ] WW [ ] Non-WW California List constituents: 1 2 3 4 6 [ ] ALL CALIFORNIA LIST CONSTITUENTS [ ] Liquids with nickel greater than or equal to 134 mg/l [ ] Liquids with thallium greater than or equal to 130 mg/l [ ] Liquids with PCB's > or = 50 ppm [ ] Waste containing HOC's > or = 1,000 mg/kg SECTION IV. OTHER LISTED WASTES (F006-12, F019-F028, F037-38, F039, K-, U-, AND P-CODES) COLUMN 1: LINE ITEM SEE MANIFEST COLUMN 2: WASTE CODE / SUBCATEGORY COLUMN 3: WASTEWATER/ NON-WASTEWATER ______ ________________________________________________________ [ ] WW [ ] Non-WW ______ ________________________________________________________ [ ] WW [ ] Non-WW ______ ________________________________________________________ [ ] WW [ ] Non-WW ______ ________________________________________________________ [ ] WW [ ] Non-WW ______ ________________________________________________________ [ ] WW [ ] Non-WW COLUMN 4: HANDLING CODE 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 3 4 5 6 [ ] CHECK HERE IF ADDITIONAL LISTED WASTE CODES ARE PRESENT. COMPLETE AND ATTACH LDR-1 CONTINUATION SHEET. [ ] CHECK HERE IF WASTE CODE F039 (MULTISOURCE LEACHATE) IS PRESENT. IDENTIFY F039 CONSTITUENTS BY COMPLETING SECTIONS II AND IV OF CHI FORM LDR-1 ADDENDUM AND ATTACH COMPLETED ADDENDUM TO THIS FORM. SECTION V. CONTACT NAME AND DATE Print Name: _______________________________________________ Date:___________________________________________ KEY TERMS/DEFINITIONS CLASS I SDWA SYSTEM means a Class I deep well facility regulated under the Safe Drinking Water Act (SDWA). CWA SYSTEM means a centralized wastewater treatment facility discharging under a Clean Water Act (CWA) permit. For example, a CWA facility would treat organic or inorganic aqueous wastes and discharge the treated effluent to the local sewer system. Examples of CWA treatment systems owned and operated by Clean Harbors include the wastewater treatment operations at Baltimore (including the CES system), Bristol, Chicago, Cincinnati and Cleveland. CWA-EQUIVALENT SYSTEM means a "zero discharge system" that engages in "CWA-equivalent" treatment before land disposal. Zerodischarge facilities treat hazardous wastes using "CWA-equivalent" treatment methods, but do not discharge the treatment effluent to a sewer or water body (e.g., spray irrigation land farm). "CWA-equivalent" treatment methods means biological treatment for organics, alkaline chlorination, or ferrous sulfate precipitation for cyanide, precipitation/ sedimentation for metals, reduction of hexavalent chromium, or other treatment technology that can be demonstrated to perform equally or greater than these technologies. HIGH TOC IGNITABLE LIQUIDS SUBCATEGORY means an ignitable liquid hazardous waste (waste code D001) which contains greater than or equal to 10% total organic carbon (TOC). Pursuant to 40 CFR 268.40, such wastes must be treated using organic recovery (RORGS) or combustion (CMBST) technology. Examples of RORGS technologies include the CES unit at Clean Harbors of Baltimore. Examples of CMBST technologies include hazardous waste fuel blending and subsequent reuse at a cement kiln, or destruction at a RCRA incinerator. WASTEWATERS are wastes that contain less than 1% by weight total organic carbon (TOC) and less than 1% by weight total suspended solids (TSS). [See 40 CFR 268.2(f)] NEICVP1493E01 Appendix A Page 297 of 612 CHI Form LDR-1, Page 3 of 3 [Effective 12/07/05] Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 298 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 299 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 300 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-10 HIGH HAZARD PROCEDURES NEICVP1493E01 Appendix A Page 301 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS OF CONNECTICUT, INC. HIGH HAZARDS PROCEDURE DEPARTMENTS Central Profile Group, Compliance, Receiving Chemists, Operations, Laboratory INTRODUCTION This standard operating procedure (SOP) has been implemented to provide all employees a system to highlight the potential non-routine hazards of particular wastes they may work with. NOTE: This procedure applies to the handling of High Hazard wastes in drum, labpack or bulk form. It does not address reagent chemicals which may have the same constituents as "high hazard" wastes. There are SOP's in place to address the handling of the reagent chemicals. In addition, some High Hazard wastes (for example, hydrofluoric acid, ammonia) may have their own SOPs already issued for their handling - those specific SOPs are to be followed. Finally, this High Hazard Procedure is to be carried out in addition to the "A99" High Hazard Program initiated by CHI corporate-wide. DEFINITION "High Hazard" wastes are defined as those meeting anyone (or more) of the following criteria: Constituent Acid/cyanides Ammonia Arsenic Barium Action Level Any concentration >10,000 ppm w/ pH >7 Any concentration if liquid present Any concentration if liquid present NEICVP1493E01 1 Appendix A Page 302 of 612 Version: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Bromine/bromide Cyanides Fuming acids Hydrazine Hydrofluoric acid or fluoride compounds Hydrogen peroxide Hypochlorite's Iodine/ iodide Mercury Oleum Selenium Sulfide compounds Unsampleable Others Any concentration if liquid present >5 ppm Any concentration Any concentration >100 ppm and pH <7 Any concentration Any concentration Any concentration if liquid present All (unless drum in drum out) Any concentration Any concentration if liquid present pH <5 Any pesticide, PCB's, or asbestos waste Case by case PROCEDURE Central Profile Group - Note presence of any of above High Hazard materials by entering identification within WIN System in Instructions or WSPROVW screens. Compliance Department - Identify the presence of any High Hazard wastes within incoming loads by noting within Vehicle Offloading Authorization Form (VOAF). Receiving Chemists or Operations Department - Upon receipt of shipment documentation (including VOAF), spray-paint a fluorescent "H" marking on the tops of all drums received which contain any of the waste types defined as High Hazard (above),' as the drums are in staging. This requirement and all other High Hazard requirements apply to labpacks. NOTE: Marking a drum with a fluorescent "H" does not relate to the PPE that should be used in handling the waste (i.e., "High Hazard" does not imply Level B). NEICVP1493E01 2 Appendix A Page 303 of 612 Version: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Receiving Chemists - Sampling of High Hazard drum wastes will continue to be performed with barricading or "taping off" of the area, and sampling the container for airborne concentrations from the waste. The Drager (or Sensidyne) tube results will be noted within the Receiving Report and WIN data entry. Operations Department, Laboratory - Sampling of High Hazard bulk wastes will be performed under Level B or other appropriate respiratory protection. The sample will be brought to the Laboratory. Lab Chemists will perform sampling of airborne concentrations from the waste sample, under a hood. The Drager tube results will be documented within the Lab/Receiving Report and WIN data entry. Laboratory - Upon confirmation or discovery of a High Hazard waste, will note the particular High Hazard(s) within the Lab's Waste Analysis "QC" Sheet. Laboratory/Data Entry - Enter the High Hazard identification into the "Comments" section of the Lab Screen within the computer tracking system. Laboratory - In issuing a transfer ticket for pumping, transfer, stabilization or any other activity (in bulk, drums or tanks), will note the existence of any High Hazard in waste to be handled. For staging or other movement of such High Hazard wastes, the transfer ticket to be issued will include notation of the High Hazard(s). For pumping or other handling of High Hazard wastes, further attention will be called to potential hazards by use of a red (Critical Step) ticket, identifying the High Hazard(s} and any additional required precautions. Chemists will refer to the PPE chart prepared by H&S. The chemist will identify the proper PPE to be worn. Modified Level B wastes for which Level B (supplied air) may not be sufficient respiratory protection will include within the Transfer Ticket a call for "Engineering Controls", "Coppus Blower" or similar notation. Other issues noted by the Lab, or required within other SOPs, must also be addressed as appropriate (i.e., bonding/grounding (for flammables), etc. NOTE: When a ticket is issued, the Operations Supervisor will review the notes, consult with the chemist and 'Lab or Operations Manager for any changes or questions, and advise employee(s) who will perform work as NEICVP1493E01 3 Appendix A Page 304 of 612 Version: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut necessary. When the waste or the proposed management activity or the involved employees require it, a Work Plan will be completed by the Laboratory and Operations prior to that activity. Operations Department - prior to any container handling, will examine the labels of all containers, and follow any High Hazard precautions associated with any Transfer Tickets. NEICVP1493E01 4 Appendix A Page 305 of 612 Version: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-11 SAMPLING EQUIPMENT NEICVP1493E01 Appendix A Page 306 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 307 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 308 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 309 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 310 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 311 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 312 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX I-12 PAINTCARE PROCESSING STANDARD OPERATING PROCEDURE NUMBER 62WC-125-000 NEICVP1493E01 Appendix A Page 313 of 612 Revised 02/01/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PaintCare Processing Standard Operating Procedure Connecticut Facility Bristol, CT NEICVP1493E01 Appendix A Page 314 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TITLE: PaintCare Processing Facility: Connecticut Reviewed By: Eric Congdon Approved By: Eric Congdon Prepared by: Eric Congdon SOP Number: 62WC-125-000 Title: Issue Date: Environmental Compliance Manager 07/01/2013 Title: General Manager Next Review Date: 07/01/2014 Page 2 of 8 Table of Contents 1.0 Objective ............................................................................................................................................3 2.0 Site Specific Terms ..........................................................................................................................3 3.0 Responsibilities.................................................................................................................................3 4.0 Prerequisites .....................................................................................................................................3 5.0 Equipment Description ....................................................................................................................4 6.0 PaintCare Operation ........................................................................................................................4 7.0 Consequences of Deviations..........................................................................................................6 8.0 Appendices........................................................................................................................................6 NEICVP1493E01 Appendix A Page 315 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TITLE: PaintCare Processing Facility: Connecticut Reviewed By: Eric Congdon Approved By: Eric Congdon Prepared by: Eric Congdon SOP Number: 62WC-125-000 Title: Issue Date: Environmental Compliance Manager 07/01/2013 Title: General Manager Next Review Date: 07/01/2014 Page 3 of 8 1.0 Objective To ensure that PaintCare materials are processed safely and efficiently. 2.0 Site Specific Terms PaintCare - Product stewardship program that facilitates the return and recycling of architectural coatings WinWeb - Proprietary technology infrastructure that includes barcode scanning utilities and tracking utilities that allow for the accurate tracking of PaintCare material. 3.0 Responsibilities General Manager The General Manager will ensure that all employees are trained and knowledgeable regarding the proper procedures that are to be followed while processing PaintCare materials. Supervisors The supervisor and/or lead foreman for this process is responsible for training, monitoring, and enforcing this procedure with the employees. Employees Facility Technicians - Are responsible for following and adhering to safe work practices and all provisions found in this procedure. Employees must inspect equipment and report any failures or deficiencies to the appropriate Supervisor. Facility Coordinator - Is responsible for following and adhering to safe work practices and all provisions found in this procedure as well as ensure that PaintCare material is acutely tracked within the WinWeb system. Employees must inspect equipment and report any failures or deficiencies to the appropriate Supervisor. 4.0 Prerequisites Health and Safety Any incidents, including near misses, are to be reported immediately to the supervisor. Use of Fixed Monitoring systems when provided. The buddy system (e.g., visual, audio contact, etc.) must be maintained when this process is being conducted. Environmental Ensure all applicable monitoring equipment is available. If an incident occurs, report it immediately to your supervisor. Incidental releases are to be cleaned up immediately in the process designated PPE. If the incident requires additional assistance or equipment, the Contingency Plan may need to be implemented. NEICVP1493E01 Appendix A Page 316 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TITLE: PaintCare Processing SOP No.: 62WC-125-000 Page 4 of 8 Documented Training HazWoper training Hazard Communication for treatment chemicals OSHA regulated substances, as required (e.g., asbestos, arsenic, lead, etc.) RCRA training SOP training Forklift training 5.0 Equipment Description 5.1 PaintCare Flexbins PaintCare material will arrive at the facility in either reusable plastic flex bins or in traditional flexbins or cubic yard boxes that are placed upon a common 48"x48" pallet. 5.2 Pallet Scale Located on the Truck-to-Truck loading dock, is equipped with a digital readout and a bar code scanner that will store the weight of each pallet into WinWeb. 5.3 Area M2 Located within the main building and is one of the Facility's 5 day or less storage / staging areas. This is the area where the sorting of PaintCare material will occur. This area will also be used as the Alkaline Waste receiving and sampling area. Both activities will occur simultaneously in this area. However, Alkaline Waste receiving and sampling will not occur in the same row of M2 as PaintCare processing is taking place in. 6.0 PaintCare Operation 6.1 Receiving PaintCare Material Upon arriving at the Facility the driver of the vehicle will check in with the Facility's Compliance Guard who will; 1. Verify that the sales order, profile and shipping papers meet all regulatory requirements and are able to be received into the WinWeb system. 2. Each shipment will be received into the WinWeb system, a Vehicle Off-Loading Authorization Form is completed and WinWeb bar code labels will be printed for each piece in the shipment. 3. The vehicle is directed into a truck parking area or directly to the Truck-to-Truck dock. 6.2 Vehicle Off-Loading After receiving the vehicle it is brought to the Truck-to-Truck dock. The Facility Technician(s) will; 1. Ensure that the vehicle is secured. o If the shipment is on a van trailer it will either be connected to a tractor or a jack stand will be placed under the nose of the trailer, a wheel chalk will be placed in front of the tires. o If the shipment is on a box truck it will be secured with the vehicle's parking brake as well as a wheel chalk. 2. Open the rear door of the vehicle and place the dock plate on the rear of the vehicle. 3. Visually inspect the load to ensure that there is no obvious signs of a leaking container. If a container is leaking notify a Supervisor, who will direct the clean-up. 4. Upon confirmation that the load is intact begin removing the flexbins using a forklift. Ensure that the pallet scale is reading zero with no waste on the scale. Place each flex bin on the pallet scale. Inspect each container for integrity, labels and markings. Ensure that the waste labels have the appropriate information and match the manifest for the shipment. If there is missing information on the waste label complete the label or re-print the label using one of the Facility's waste label printers. Match the waste label with the corresponding WinWeb bar code label. Affix the WinWeb bar code label next to the waste label. 5. Scan the WinWeb bar code using the handheld scanner attached to the scale. Ensure that the scale unit beeps confirming that the scale weight was recorded. 6. Move the container into either M2 or into Area H if there is no available capacity in M2. If there is no capacity in either area notify the Supervisor. 7. Once the container is in the staging or processing area, utilize the facility scanner to scan the container into that area. NEICVP1493E01 Appendix A Clean Harbors Environmental Services, Inc. Page 317 of 612 Bristol, Connecticut TITLE: PaintCare Processing SOP No.: 62WC-125-000 Page 5 of 8 6.3 Paint Processing 1. At the beginning of each operating day the paint processing areas will be inspected by the Facility Technician responsible for PaintCare processing. Items to be inspected are; a. Eye wash and safety shower available, un-obscured and clean b. Area for signs of visible spills or leaks c. Age of waste in areas to ensure that none are over the 5 day limit d. Spill kit present and stocked e. All necessary tools are available and operable f. All necessary PPE is available 2. Don the appropriate PPE for the paint processing operation. 3. Ensure that there are available flexbins for the material that will be segregated. If there are flexbins from the prior day continue using those, otherwise start new flexbins for each type of material. 4. For new flexbins; a. Affix appropriate waste labels to two opposing sides b. If necessary, affix appropriate placard to two opposing sides next to the waste label c. Affix an appropriate WinWeb tracking label to one side next to the waste label 5. Open the flex bin and sort according to type of paint indicated on each individual label. Reference the PaintCare Acceptable/Unacceptable Materials Guidelines. Latex based paint is to be consolidated with latex paint and will go to recycling outlets. Oil based paint and other program items will be consolidated with that type of material. a. Ensure that lids are on each container and that the container is suitable for shipment b. Larger containers shall be placed at the bottom of the flex bin with smaller containers on top and filling in gaps to secure all containers in the flexbin. 6. Once each unsorted flexbin is completely empty; a. Remove the label, markings and WinWeb tracking labels. b. Place one of the small WinWeb tracking bar codes on the PaintCare Daily Processing Sheet. c. If a new flexbin is needed for segregated material and the processed flexbin is suitable, it may be reused for segregated material. d. If a new flexbin is not needed but the flexbin is suitable for reuse, collapse the flexbin and stack it on top of the new flexbins. e. If the flexbin is a reusable poly flex bin move to the Middle Street property for redistribution into the PaintCare program. f. If the flexbin is not suitable for re-use, contact the Supervisor for disposal instructions. 7. Once a segregated flexbin is completed; a. Close the flexbin. b. Remove one of the small WinWeb tracking bar codes and place on the PaintCare Daily Processing Sheet. c. Move the flexbin using a forklift to the pallet scale. d. Using the scanner attached to the pallet scale scan the WinWeb tracking bar code label to store the weight to WinWeb. e. Move the flexbin into the appropriate staging or storage area. f. Once the container is in the staging or processing area, utilize the facility scanner to scan the container into that area. 8. At the close of each business day the PaintCare Daily Processing Sheet is to be brought to the Facility Coordinator. 6.4 PaintCare Tracking 1. Daily the Facility Coordinator will track the previous days paint processing activity in the WinWeb system using the PaintCare Daily Processing Sheet. 2. The Facility Coordinator will monitor the on-site inventory of processed material for; a. Weights - ensure that the WinWeb has accurate tracking weights uploaded to WinWeb b. Inventory Levels - Coordinate with Facility Technicians to monitor quantities of processed paint and as necessary schedule outbound loads for both latex and other types of materials. 6.4 Emergency Shutdown In the event of an unplanned emergency shutdown - vacate the area following the evacuation routes laid out in theNFEaICcVilPit1y4C93oEn0t1ingency Plan. Appendix A Page 318 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TITLE: PaintCare Processing SOP No.: 62WC-125-000 Page 6 of 8 7.0 Consequences of Deviations In addition to the process interruptions which can occur, the following additional consequences of deviations could result: Injuries and/or fatalities Property damage Regulatory violations and/or fines Damaged public relations and/or customer relations Disciplinary actions up to and including termination 8.0 Appendices Job Hazard Analysis (62WC-125-000-1) PPE Hazard Assessment (62WC-125-000-2) PaintCare Daily Processing Sheet PaintCare Acceptable/Unacceptable Materials Guidelines NEICVP1493E01 Appendix A Page 319 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 320 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix A Page 321 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT B INSPECTION PLAN (Submitted with the RCRA Part B Permit Application in March 2017) (Last revised on February 10, 2017) Clean Harbors of Connecticut, Inc. Inspection Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 322 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN FACILITY INSPECTION PLAN CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT EPA ID NO. CTD000604488 Revised February 10, 2017 NEICVP1493E01 Appendix A Page 323 of 612 Revised 02/10/2017 Page 1 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN Table of Contents FACILITY INSPECTION PLAN 1.0 Purpose ..................................................................................................................................3 2.0 Inspection Methods and Use of Electronic Forms.................................................................4 3.0 Remedy of Unsatisfactory Conditions...................................................................................4 4.0 Recordkeeping and Reporting Management System.............................................................5 5.0 Inspection Requirements .......................................................................................................5 6.0 Facility Inspection Elements, Methods and Frequencies ......................................................6 TABLES Table 1 Table 2 Table 3 Inspection List of Waste Management Areas and Facility Assets ...........................3 Regulatory Framework of the Facility Inspection Program .....................................6 Organizational Format of the CHBI Facility Inspection System .............................7 APPENDICES Appendix 1 General Facility System Inspection Elements, Methods and Inspection Frequency Appendix 2 Container Management System Inspection Elements, Methods and Inspection Frequency Appendix 3 Tank Management System Inspection Elements, Methods and Inspection Frequency Appendix 4 Other Waste Management System Inspection Elements, Methods and Inspection Frequency Appendix 5 Daily, Weekly, Monthly, and Annual Inspection logs ACRONYMS CHCI CTDEEP IWT WINWeb CFR CSA WMA RCSA EPA Clean Harbors of Connecticut, Inc., Bristol, Connecticut Connecticut Department of Energy and Environmental Protection Electronic Inspection Work Ticket Waste Information Network - A networked, single web based system developed by Clean Harbors for internal use that has a multitude of recordkeeping and reporting functions that can be accessed via the internet. Code of Federal Regulations Container Storage Area Waste Management Area Regulations of Connecticut State Agencies U.S. Environmental Protection Agency NEICVP1493E01 Appendix A Page 324 of 612 Revised 02/10/2017 Page 2 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN 1.0 Purpose FACILITY INSPECTION PLAN Clean Harbors of Connecticut, Inc. (CHCI) has prepared this Facility Inspection Plan (the "Plan') in compliance with US EPA regulation 40 CFR 264.15 and 270.14, incorporated by reference in Section 22a-449(c)-104(a)(1) of the Regulations of Connecticut State Agencies. The purpose of the Facility Inspection Plan is to describe the procedures for inspecting the waste management areas at the facility and to establish a schedule for conducting those inspections. The Plan establishes a schedule of inspection items and elements of permitted waste management areas and establishes the minimum frequency and method of the inspections. Table 1 lists the waste management areas and facility assets subject to the inspection requirements. Table 1. Inspection List of Waste Management Areas and Facility Assets WASTE MANAGEMENT AREAS Container Storage Areas Container Staging Areas Waste Storage Tank Systems Bulk Loading and Unloading Area (BULA) Mix-Tub, Bulk Storage and Transfer Area (MBSTA) Truck-to-Truck Transfer (TTT) Areas Truck Parking Areas (TPAs) Miscellaneous Process Areas (MPAs) Facility Security, Safety and Emergency Equipment Subareas Areas A, B, C, D, E, F, G, J, K, and L Areas M1, M2, H Tank No. 11 Tank No. 14 Spill Control Area Solidification / Stabilization Area Loading/Unloading Dock Area Five Truck Bays Area 1 (4 Bays) Area 3 (1 Bay) Proposed Temporary Parking Area Drum Crusher Unit Lab Pack Pour-Off Station Drum Rinse Station Site Operations The Facility Inspection Plan provides a systematic management method of identifying potential problems, malfunctions, or deterioration that may cause or lead to a release of hazardous constituents to the environment or a threat to human health. Scheduled inspections are required to detect malfunctions, deterioration, operator errors, leaks, and discharges which may cause or may lead to a threat to human health; release of waste constituents to the environment; or interruption and curtailment of normal operations. Inspections will be used to identify potential operational problems, and to identify required maintenance of in-service equipment and structures while the facility is operational or equipment is in service. The Plan shall be NEICVP1493E01 Appendix A Page 325 of 612 Revised 02/10/2017 Page 3 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN maintained at the facility at all times and updated as required to reflect any changes to the waste management operations at the facility. Changes to the inspection plan will be made in accordance with permit modification procedures found in 40 CFR 270.42 / Section 22a-449(c)104(a)(1). 2.0 Inspection Methods and Use of Electronic Forms CHCI has developed specific inspection forms under its compliance management program for inspection documentation. For integration of all facility operations, certain non-RCRA inspection items can be included on the Inspection Forms. Such items can be added or deleted at the facility's discretion. Inspection forms can consist of written hardcopy or equivalent electronic format. An inspection form shall document the date and time of inspection, name of the inspector, the status of each inspected item, the reason for any observed condition requiring corrective action and a link to the work ticket that is created for the issue. Observations are entered in fields on the form that includes drop-down menu items of the inspection management system database. Inspectors will conduct inspections using the electronic system in the same manner as conventional paper forms and will review each area for the required inspection elements. Copies of example daily, weekly, monthly, and annual electronic inspection forms are included as Appendix 5. CHCI maintains inspection results in the WINWeb Electronic Inspection Management System developed by Clean Harbors. The inspection management system consists of three main components. An Inspection Due screen that lists all open inspections that need to be completed, an Inspection Log that provides easy access to all completed inspections, and a Work Ticket Management System used to list all open work tickets and the tracking and completion data associated with them. 3.0 Remedy of Unsatisfactory Conditions Potential problems that require repairs or unsatisfactory conditions identified on the inspection log will be corrected or addressed as soon as possible or practicable. If the problem identified is a threat to human health or the environment, then actions to mitigate the situation will be undertaken immediately. All steps necessary to minimize the exposure of the workers to hazardous materials, hazardous waste, or hazardous situations will be taken prior to beginning the repair work. Unsatisfactory conditions noted during inspections requiring immediate corrective actions will be reported to the General Manager, Operations Manager, Compliance Manager or designee following completion of the inspection. Unsatisfactory conditions that do not pose any threat to human health or the environment will be evaluated and repairs will be scheduled in a timely manner to ensure that the observation does NEICVP1493E01 Appendix A Page 326 of 612 Revised 02/10/2017 Page 4 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN not lead to a significant condition. Work ticket corrective action items that are not completed the day of the inspection are electronically saved in the WINWeb electronic inspection system and link to the same checklist element on the next scheduled inspection event form. The outstanding work ticket items are displayed and linked to data entries that document tasks. Once the problem has been resolved, it will be documented on the work ticket and re-inspected during the next scheduled inspection to confirm completion. 4.0 Recordkeeping and Reporting Management System All RCRA Inspection Forms and associated documents shall be incorporated into the facility's Operating Record. Inspection data shall be available to the CTDEEP representatives in hardcopy, or other compatible format, upon request. One or more inspectors will be designated to perform the inspections as scheduled. A record of the inspections and the schedule will be maintained at the facility. The results of the inspections will be recorded on an electronic inspection log that will be maintained in the WinWeb operating record. The electronic inspection work ticket records shall be maintained at the facility in a readily available location and maintained for a minimum of three (3) years from the applicable record's inspection date or as specified by the CTDEEP or modified by CHCI policies and procedures. 5.0 Inspection Requirements This section presents the regulatory framework of the CHCI facility inspection plan which is based on applicable US EPA regulations that are incorporated by reference in Section 22a449(c)-104(a)(1) of RCSA. They include the following in Table 2 below: NEICVP1493E01 Appendix A Page 327 of 612 Revised 02/10/2017 Page 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN Table 2. Regulatory Framework of the Facility Inspection Program. Regulatory Requirements General Inspection Requirements Specific Process Inspection Requirements Container Storage Area Inspection Inspection Frequency Schedules Citations Incorporated by reference in Section 22a-449(c)104(a)(1) of RCSA 40 CFR 264.15(a) and (b), 264.33, 270.14(b)(5) 40 CFR 264.15(b)(4), 270.14(b)(5) 40 CFR 264.174 40 CFR 264.15, 270.14(b)(5) Description General inspection of the facility perimeter, safety and emergency equipment, security devices, operating and structural equipment, general requirements of miscellaneous units, communication systems, alarm systems, fire protection equipment, and decontamination equipment. Specific inspection for container, tank systems, and miscellaneous units. Specific inspections of container storage areas for adequate aisle space, potential spills or accumulation of liquids in secondary containment systems and loading or unloading areas, and deterioration of secondary containment area structures; containers are visually inspected for structural condition (e.g., open, deteriorated, damaged, corroded, leaking, bulging from internal pressure and appropriate markings for hazards, chemical identification and system tracking. Inspection frequencies are based on specified regulatory and permit requirements; inspection frequencies performed include daily, weekly, monthly or annual based upon the minimum regulatory requirements and /or modified at the discretion of facility management or specific permit conditions. 6.0 Facility Inspection Elements, Methods and Frequencies The CHCI Facility Inspection Plan is organized into a structured format and managed through WINWeb to account for a systematic implementation of the program. Accordingly, there exists a consistent inspection of permitted waste management areas inclusive of emergency equipment, requirements (inspection parameters), inspection checklist items (Inspection elements), inspection methods (physical and functional) and inspection frequencies (daily, weekly, monthly, annually). This organizational format is presented in Appendix 1, Appendix 2, Appendix 3 and Appendix 4. Detailed information on the structure and organization of the CHCI Facility Inspection Plan is summarized in Table 3 below: NEICVP1493E01 Appendix A Page 328 of 612 Revised 02/10/2017 Page 6 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN Table 3. Organizational Format of the CHCI Facility Inspection System. INSPECTION FORMAT Inspection Parameter Inspection Element Method Inspection Frequency Corrective Action Work Ticket DESCRIPTION Permitted waste management areas inclusive of emergency equipment that are organized into separate configurable forms. Inspection criteria formatted into a set of standardized checklist items on an electronic form. Conditions consistent with the inspection criteria are recorded as "Pass." Observed conditions that deviate from the criteria are noted as "Fail" and are categorized in a standard drop-down menu. The form includes a field that allows the inspector to record specific observations (i.e., location, drum identification number, tank, row, etc.). Physical Inspection: An inspection method conducted by an inspector that is visuallybased and adequate to verify the operating status of a waste management area or condition of emergency equipment to assure conformance with element checklist items. Functional Inspection: An inspection method conducted by an inspector to determine if equipment or instrumentation is capable of performing within mechanical and electrical specification ranges established by the manufacturer. Functional inspections are intrusive methods requiring maintenance tools and/or function tests to verify proper operation of a system as designed. Remote Inspection: An inspection method based on control panel advisor screen displays, process data acquisition and recording (PDAR) systems, sensor level probes and audible alarms, programmable logic controller (PLC), etc. that provide continuous information feeds of data which create an electronic record. The inspection schedule frequency that establishes the minimum number of required inspection events which assess the conditions of waste management areas, process areas, equipment, containers, tanks and storage buildings. Frequencies are based on minimum regulatory requirements, best management practices and the rate of probable deterioration of equipment, manufacturers' recommendations and operating experience. The frequency of any inspection type can be increased, but cannot be decreased from the approved schedule of the Facility Inspection Plan. Daily - Once per calendar week day. Weekly - Once per calendar week. Monthly - Once per calendar month. Annually - Once during a 12-month period within a month of the recurring event. When the inspector records on the inspection form an observed condition that deviates from the criteria which flag "Fail," the WINWeb system creates an individualized electronic work ticket to systematically track the progress of corrective actions. Work ticket actions are linked to the specific checklist element assigned to the waste management area parameter and remain outstanding through subsequent checklists until corrective actions are completed and closed by the facility manager or compliance manager. NEICVP1493E01 Appendix A Page 329 of 612 Revised 02/10/2017 Page 7 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN APPENDIX 1 GENERAL FACILITY INSPECTION ELEMENTS, METHODS AND INSPECTION FREQUENCY INSPECTION PARAMETER General Facility, Perimeter and Security Systems INSPECTION ELEMENT Inspect security entry gate for proper operation, damage and corrosion Inspect security building doors for proper operation, damage and corrosion Inspect access and intra-facility roads for spills Inspect fences and locked gates for access obstructions, breaks or damage Inspect that warning signs are clearly visibility Inspect for erosion openings under fences Inspect for intrusive vegetation obscuring warning signs along the perimeter fence Inspect facility lighting system for proper operation METHOD Functional INSPECTION FREQUENCY Daily Functional Daily Physical Physical Daily Monthly Physical Physical Physical Monthly Monthly Monthly Functional Monthly Safety and Emergency Equipment Systems Inspect for any obstructions to facility evacuation routes Inspect tags of fire extinguishers for expiration dates and adequate pressure Test audible and visual alarms Test communication devices that include telephone, paging, two-way radios and loudspeaker systems for damage, out-of-service conditions and proper operation Inspect self-contained breathing apparatus (SCBA) for air pressure with a pressure gauge, regulators to verify that air passage is unobstructed, and masks and hoses for serviceability Inspect first aid stations Inspect sprinkler systems and other fire suppression systems Inspect external condition of safety showers and operate to verify adequate water flow Inspect external condition of eye wash stations and operate to verify adequate water flow Physical Functional Functional Functional Functional Physical Functional Functional Functional Daily Monthly Monthly Monthly Monthly Monthly Monthly Monthly Monthly NEICVP1493E01 Appendix A Page 330 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN INSPECTION PARAMETER Safety and Emergency Equipment Systems Emergency Generator INSPECTION ELEMENT Inspect emergency spill response and decontamination equipment for adequate supplies, damage out-of-service dates and proper operable condition. Inspect inventory of facility PPE for adequate supplies, out-of-service dates, missing information and proper operable condition. Inspect and test fire hydrants and sprinkler systems for adequate water supply, leaks or evidence of corrosion Conduct monitoring control system test of toxic gas detection sensor network for the scrubber roof exhaust and operations building for Chlorine, Hydrogen Cyanide, Hydrogen Sulfide, Nitrogen Dioxide and Sulfur Dioxide. Test internal gas sensor alarms and 24-hour monitoring of the toxic gas detector system by the off-site third party alarm service provider. Conduct monitoring control system calibration of toxic gas detection sensor network for the scrubber roof exhaust and operations building for Chlorine, Hydrogen Cyanide, Hydrogen Sulfide, Nitrogen Dioxide and Sulfur Dioxide. METHOD Physical Physical Functional Functional Remote Functional Remote INSPECTION FREQUENCY Monthly Monthly Annually Monthly Annually Inspect for fuel level, lubrication oil level, coolant level, oil leaks, coolant leaks, loose drive belts, mechanical integrity and crankcase containment Verify automatic engine start-up, operation and shut-down to monitor for voltage, frequency output, engine lubrication oil pressure, engine coolant levels and air filter differential pressure Conduct mechanical system preventive maintenance service of entire generator system and operation in accordance with the manufacturer's maintenance schedule Functional Functional Functional Monthly Monthly Annually NEICVP1493E01 Appendix A Page 331 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN APPENDIX 2 CONTAINER MANAGEMENT INSPECTION ELEMENTS, METHODS AND INSPECTION FREQUENCY INSPECTION PARAMETER Container Management System INSPECTION ELEMENT Inspect Container Storage Building loading and unloading areas for evidence of leaks, spills or accumulated liquids Inspect aisles in container storage areas for a minimum of two (2) feet of aisle space Inspect sumps for presence of liquids Inspect the condition of the surface epoxy-coat sealant for cracks, chips, flaking, lifting or worn-out sections Inspect the container storage areas concrete base slabs and curbs for cracks, gaps, gouges, and other signs of wear or structural damage Inspect container management areas to ensure incompatible wastes are properly segregated from other wastes and materials Inspect containers for evidence of pressure build-up, structural damage, leaks, missing cap or bung, corrosion, or deterioration Inspect containers for legible markings or identification labels Inspect for unstable overhanging containers on double-stacked pallets Inspect equipment and conveyors for operability, condition Inspect the secondary containment trenches for accumulated solid debris METHOD Physical INSPECTION FREQUENCY Daily Physical Physical Physical Physical Daily Daily Daily Daily Physical Physical Physical Physical Physical Physical Daily Daily Daily Daily Weekly Weekly NEICVP1493E01 Appendix A Page 332 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN APPENDIX 3 TANK MANAGEMENT INSPECTION ELEMENTS, METHODS AND INSPECTION FREQUENCY INSPECTION PARAMETER Tank #11 and Tank #14 Systems INSPECTION ELEMENT Inspect secondary containment system in tank area for leaks, spills or accumulated liquids Inspect tanks for evidence of pressure build-up, structural damage, leaks, corrosion, or deterioration Inspect sumps for presence of liquids Inspect overfill alarm equipment Inspect tank liquid levels Inspect overflow controls, liquid level transmitters, shut-offs and level alarms Inspect functioning toxic gas detection monitoring controls Inspect tank exterior seams and pipe connections for leaks Inspect tank exterior shell for corrosion, deterioration and coating Inspect tank valves, connectors, piping network and pumps for proper operational conditions and leaks Inspect operation of volatile organic emissions control for Tank #14 Inspect tanks for legible markings or identification labels/signage Inspect storage of spare backup carbon control canister for Tank #14 Monitor transfer pumps, connectors and valves to Tank #14 containing volatile organic waste (>500 ppmw) Conduct an external ultrasonic shell thickness survey per API standards to be completed by internal engineering resources or subcontractors based on permit conditions, applicable regulations or Clean Harbors BMPs that require independent 3rd party engineering certification Conduct an internal inspection for pitting and corrosion using appropriate standards for the type of construction and tank service (i.e.: API standards) METHOD Physical Physical Physical Functional Physical Functional Functional Physical Physical Functional Functional Physical Physical Physical Functional Functional INSPECTION FREQUENCY Daily Daily Daily Daily Daily Daily Daily Daily Daily Daily Daily Weekly Weekly Monthly Annually Annually NEICVP1493E01 Appendix A Page 333 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN APPENDIX 4 OTHER WASTE MANAGEMENT INSPECTION ELEMENTS, METHODS AND INSPECTION FREQUENCY INSPECTION PARAMETER Bulk Unloading and Loading (Former Spill Control Area) INSPECTION ELEMENT Inspect Bulk Loading and Unloading Area (BULA) secondary containment for leaks and spills Inspect for proper pump operation Inspect pumps, hoses and connectors for leaks, deterioration and corrosion Inspect manifolds and valves for proper operation Inspect manifolds and valves for leaks, deterioration and corrosion Inspect concrete surface base slab for cracks, gaps and epoxy surface coat deterioration Inspect secondary containment sump for accumulated liquids and solid debris METHOD Physical Functional Physical Functional Physical Physical Physical INSPECTION FREQUENCY Daily Daily Daily Daily Daily Weekly Weekly MBSTA Truck Parking Inspect the MBSTA concrete surface base and secondary containment for spills and leaks Inspect aisle spacing between containers for a minimum of two (2) feet of aisle space Inspect area for prohibited waste, incompatible waste and materials Inspect mix-tub container for structural damage and proper containment Inspect concrete surface base slab for cracks, gaps and epoxy surface coat deterioration Physical Physical Physical Physical Physical Inspect trailers in Truck Parking Areas (TPAs) 1 and 3 and secondary containment areas for spills and leaks Inspect bulk containers for secured tarp covers, closed lids and tailgates Inspect bulk containers for condition integrity Inspect bulk containers for identification placards, markings and labels Inspect for trailers staged less than 10 days from arrival date Inspect secondary containment sumps for accumulated liquids and solid debris Inspect concrete surface base slab for cracks, gaps and epoxy surface coat deterioration Physical Functional Functional Physical Physical Physical Physical Daily Daily Daily Daily Weekly Daily Daily Daily Daily Daily Weekly Weekly NEICVP1493E01 Appendix A Page 334 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN INSPECTION PARAMETER Loading / Unloading INSPECTION ELEMENT Inspect the Truck-to-Truck Transfer (TTT) and Loading Dock Areas concrete surface base and secondary containment for spills, leaks and accumulated precipitation Inspect concrete surface base slab for cracks, gaps and epoxy surface coat deterioration METHOD Physical INSPECTION FREQUENCY Daily Physical Weekly Lab Pack Pour-Off Station Drum Crusher Inspect area for leaks and spills Inspect that empty containers are removed Inspect for proper operation and position of guard protection Inspect area for leaks and spills Inspect for proper operation of safety guards Physical Daily Physical Functional Physical Functional Daily Daily Daily Weekly NEICVP1493E01 Appendix A Page 335 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 FACILITY INSPECTION PLAN APPENDIX 5 DAILY, WEEKLY, MONTHLY, AND ANNUAL INSPECTION LOGS NEICVP1493E01 Appendix A Page 336 of 612 Revised 02/10/2017 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Form Code: 232 WC Daily Inspection Log Compliance Header Inspector Name Area of Inspection Inspection Date and Time Instructions Daily Inspection Log Instructions: Inspections must be conducted daily when the facility is in operation. Note condition of inspection items. If item does not apply, mark N/A. All unsatisfactory findings must be explained below. Include all repairs or remedial actions required or performed. Container Storage Area A Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed NEICVP1493E01 Appendix A Page 337 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Form Code: 218 WC Daily TTT Inspection Compliance Header Inspector Name Area of Inspection Inspection Date and Time Instructions Weekly TTT Inspection Instructions: Inspections must be conducted weekly when the facility is in operation. If item does not apply, mark N/A. Explain unsatisfactory findings. Include all repairs or remedial actions required or performed. Weekly TTT Inspection Items Are the fire extinguishers, inspected, mounted, and documented Are emergency eyewash/showers tested, inspected, and documented Are portable eyewash stations inspected for adequate water and documented Are First Aid & Bloodborne Pathogen kits inspected, inventoried, and supplies ordered Are spill kits inspected, inventoried, and supplies ordered Are daily pre-shift inspections completed on forklifts and tagged out when defective Are daily pre-shift inspections completed on yard mules and tagged out when defective Are grounding/bonding cables securely attached to a good ground and inspected Are flammable liquids stored in flammable liquids storage cabinets Is your training documented in People Soft Compliance Footer Inspector Signature NEICVP1493E01 Appendix A Page 338 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Attach Photo Inspection Overall Assessment NEICVP1493E01 Appendix A Page 339 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area B Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area C Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or NEICVP1493E01 Appendix A Page 340 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area D Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids NEICVP1493E01 Appendix A Page 341 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area E Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area F Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. NEICVP1493E01 Appendix A Page 342 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area G Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good NEICVP1493E01 Appendix A Page 343 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area H Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area J Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that NEICVP1493E01 Appendix A Page 344 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area K Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard NEICVP1493E01 Appendix A Page 345 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area L Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area M1 Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks NEICVP1493E01 Appendix A Page 346 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Container Storage Area M2 Secondary Containment - Base free of leaks, spills and accumulated precipitation Secondary Containment - There are no cracks or gaps in containment that need to be caulked/sealed. Any areas of older cracks that have been previously repaired are still in good condition. Containers - The Containers are in good condition, (no rust, pinched, holes, bulging or damaged). Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - The containers have labels that NEICVP1493E01 Appendix A Page 347 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut are completed properly with no missing information (i.e. accumulation start date, hazard identification, etc.) Secondary Containment - Coating in good condition, no cracks, gaps pr worn out areas. Containers - Closed bungs and lids Container - Properly sealed Containers - Drum placement (e.g., drums not overhanging pallets). Waste Storage Tank #11 Overflow controls - Adequate freeboard Ovrflow Controls - Liquid level transmitters, sutomatic or mannual shut-offs and level alarms - Operational Monitoring Equipment - Temp. & pressure guages, vapor supression, gas leak detection and fire supression system - Operational Exterior Evaluation - Seam/connections free of leaks. Exterior Evaluation - Shell free of corrosion or deterioration Ancillary Equipmnet - Operational Ancillary Equipment - Equipment in good condition (i.e., not corroded or deteriorated) Ancillary Equipment - Equipment is not leaking Secondary Containment Area - Check for evidence of failure (e.g., secondary containment, curbing, floor, foundation, cracks, deterioration, other). Secondary Containment - Base free of leaks, spills and accumulated liquids Waste Storage Tank #14 Overflow controls - Adequate freeboard Ovrflow Controls - Liquid level transmitters, sutomatic or mannual shut-offs and level alarms NEICVP1493E01 Appendix A Page 348 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut - Operational Monitoring Equipment - Temp. & pressure guages, vapor supression, gas leak detection and fire supression system - Operational Exterior Evaluation - Seam/connections free of leaks. Exterior Evaluation - Shell free of corrosion or deterioration Ancillary Equipmnet - Operational Ancillary Equipment - Equipment in good condition (i.e., not corroded or deteriorated) Ancillary Equipment - Equipment is not leaking Secondary Containment Area - Check for evidence of failure (e.g., secondary containment, curbing, floor, foundation, cracks, deterioration, other). Secondary Containment - Base free of leaks, spills and accumulated liquids Spill Control Area Secondary Containment - Area free of spills/leaks Pumps - Operational Pumps - Equipmnet is free of leaks, detrioration or corrosion Hoses - Operational Hoses - Equipment is free of leaks, detrioration or corrosion Manifords and Valves - Operational Manifolds and Valves - Inspect valve stems, manifolds, pumps, flexible hoses, pipe fittings, etc. for signs of leaks deterioration or corrosion Solidification/Stabilization Area Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, other. NEICVP1493E01 Appendix A Page 349 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Asile Spacing - Containers are stored in an organized fashion that allows for easy inspection; minimum 2 ft. spacing between containers, and is clear and free of obstructions. Containers - Area is free of prohibited waste Loading/Unloading Dock Area Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. Truck Parking Areas 1 Trailers and Secondary Containment - Area free of spills/leaks Containers - In good condition (no corrosion or deteriation, not leaking or bulging Containers - Closed bungs and lids Trailers - Staged less than 5 days from date of arrival Containers - Properly sealed, marked and labeled Truck Parking Areas 2 Trailers and Secondary Containment - Area free of spills/leaks Containers - In good condition (no corrosion or deteriation, not leaking or bulging Containers - Closed bungs and lids Trailers - Staged less than 5 days from date of arrival Containers - Properly sealed, marked and labeled Truck Parking Areas 3 Trailers and Secondary Containment - Area free of spills/leaks Containers - In good condition (no corrosion or deteriation, not leaking or bulging NEICVP1493E01 Appendix A Page 350 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Containers - Closed bungs and lids Trailers - Staged less than 5 days from date of arrival Containers - Properly sealed, marked and labeled Security Entry Gates - All gates are in good conditions (no corrosion or damage) Entry Gates - Locked during off hours Building Doors - In good condition (no corrosion or damage) Building Doors - Locked during off-hours Safety & Emergency Equipment Exits/Firelanes/Evacuation Routes - Check that all routes are clear or unobstucted. Process Areas Pour-off Station - Area free of spills/leaks Pour-off Station - Empty containers removed Pour-off Station - Guard protection in place and not damaged Compliance Footer Inspector Signature Attach Photo Inspection Overall Assessment NEICVP1493E01 Appendix A Page 351 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Form Code: 243 WC New Weekly Inspection Log Compliance Header Inspector Name Area of Inspection Inspection Date and Time Instructions New Weekly Inspection Log Instructions: Inspections must be conducted weekly when the facility is in operation. Note condition of the inspection items. If item does not apply, mark N/A. All unsatisfactory findings must be explained below. Include any repairs, changes or remedial actions required or performed. Container Storage Area - A Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - B Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - J Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris NEICVP1493E01 Appendix A Page 352 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Form Code: 251 WC New Monthly Inspection Log Compliance Header Inspector Name Area of Inspection Inspection Date and Time Solidification and Stabilization Area Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. Instructions New Monthly Inspection Log Instructions: Inspections must be conducted monthly when the facility is in operation. Note condition of the inspection items. If item does not apply, mark N/A. All unsatisfactory findings must be explained below. Include any repairs, changes or remedial actions required or performed. Roll-off and Storage Area Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. Security Facility Fence - In good condition (not corroded or damaged) Floodlights - Operational Facility Alarms - Operational Safety and Emergency Equipment Self-contained Breathing apparatus and air reserves Spill response kits - Kit in correct locations Spill response kits - Items adequately stocked Aqueous film forming foam - Checked per NEICVP1493E01 Appendix A Page 353 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut manufacturer's specifications Aqueous film forming foam - Wheels turned to ensure operational Wind Sock - Visible and in good condition Decontamination equipment - Adequate Supply of cleaning solutions, sponges, brushes, mops, plastic covering and pool First aid equipment - Equipment accessible First aid equipment - Adequately stocked Personal protective equipment - In good condition and adequately stocked Communication system - Operational Emergency Alarms - Can be heard throughout facility Warning Signs - Intact Lighting and emergency lighting - Meets required OSHA specifications Fire extinguishers - In good condition and operable? Battery backups - Contain sufficent charge Compliance Footer Inspector Signature Attach Photo Inspection Overall Assessment NEICVP1493E01 Appendix A Page 354 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - C Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - K Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - D Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - L Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - E NEICVP1493E01 Appendix A Page 355 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - M1 Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - F Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - M2 Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - G Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment - Tenches are free of debris NEICVP1493E01 Appendix A Page 356 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Container Storage Area - H Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Base/Foundation and Secondary Containment Tenches are free of debris Base/Foundation and Secondary Containment All incompatible materials properly stored and segregated Tank No. 11 Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Secondary Containment - Area free of spilled or leaked waste Lables - Present on each tank Tank No. 14 Lables - Present on each tank Secondary Containment - Area free of spilled or leaked waste Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Spill Control Area Containers - Inconpatables properly segregated Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Loading/Unloading Dock Area Base/Foundation and Secondary Containment Area free of cracks or gaps or deterioration Truck Parking Area 1 Base/Foundation and Secondary Containment - Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. NEICVP1493E01 Appendix A Page 357 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Truck Parking Area 2 Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. Truck Parking Area 3 Base/Foundation and Secondary Containment Area free of cracks, deterioration, leaks, ponding, wet spots, spills, pitting, and accumulated precipation. Security Non-entry gate - Locked and in good condition (no corrosion or damage) Warning Signs - In place and in good condition Safety and Engineering Equipment Eyewashes and showers - In good condition and have adequate water pressure Personal protective equipment - In good condition and adequately stocked Emergency Equipmnet - In good condition and adequately stocked Overpack drums - In good condition and adequately stocked Telephone or paging system - Check for operability Two-way radils - Operational Drum Crusher Drum Crusher - Operating properly and used for appropriate containers Compliance Footer Inspector Signature Attach Photo Inspection Overall Assessment NEICVP1493E01 Appendix A Page 358 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut WC Annual Inspection Log Form Code: 268 Compliance Header Inspector Name Area of Inspection Inspection Date and Time Safety and Emergency Equipment Sprinkler - Operational Foam supression system - Operational Instructions Annual Inspection Log Instructions: Inspections must be conducted annually when the facility is in operation. Note condition of the inspection items. If item does not apply, mark N/A. All unsatisfactory findings must be explained below. Include any repairs, changes or remedial actions required or performed. Waste Storage Tank #11 Internal and exterior evaluation - Tank free of cracks, corrosion and other conditions which may lead to leaks. Internal and exterior evaluation - Seals and gaskets in good condition Waste Storage Tank #14 Internal and exterior evaluation - Tank free of cracks, corrosion and other conditions which may lead to leaks. Internal and exterior evaluation - Seals and gaskets in good condition Compliance Footer Inspector Signature Attach Photo Inspection Overall Assessment NEICVP1493E01 Appendix A Page 359 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT C PERSONNEL TRAINING PLAN (Submitted with the RCRA Part B Permit Application in March 2017) (Updated on June 5, 2018) Clean Harbors of Connecticut, Inc. Personnel Training Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 360 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT N PERSONNEL TRAINING PLAN NEICVP1493E01 1 Appendix A Page 361 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION 8.1 TITLE Overview and Objectives PAGE .......................................... 1 8.2 Training Methodology 8.2.1 Formal Classroom Training .............................. 2 8.2.2 On-the-Job Training ....................................... 2 8.2.3 Assurance of Quality Training ........................... 2 8.3 Recordkeeping ...................................................... 3 8.4 Outline of Training Program ..................................... 3 8.4.1 Basic Training .............................................. 7 8.4.2 Continuing Emergency Response Training ............ 10 8.4.3 Additional Training ....................................... 11 8.4.4 Annual Refresher Course ................................. 11 8.5 Personnel Training Instructor .................................... 12 8.6 Training Documentation .......................................... 12 8.6.1 Relevance of Training to Job Position .................. 12 APPENDICES 8-1 8-2 8-3 8-4 EMPLOYEE DEVELOPMENT RECORD DESCRIPTION OF ADDITIONAL TRAINING JOB DESCRIPTIONS TRAINING OUTLINES TABLES 8-1A 8-1B 8-2 TITLE Core Training Subjects ............................................ Required Training For Each Job Title ............................. Emergency Response Training Program ........................ PAGE 4 5 11 NEICVP1493E01 2 Appendix A Page 362 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 8.0 PERSONNEL TRAINING PLAN 8.1 OVERVIEW AND OBJECTIVES Accidents and emergency situations can be avoided, or at least minimized, by having a work force that is trained to perform jobs properly, use proper tools and take adequate precautions. If an accident does occur, the consequences can be lessened through rapid and effective response. The purpose of the Personnel Training Plan is to familiarize employees with the operation of the facility, prevent accidents and mitigate impacts should an accident occur. Thorough training of facility personnel is recognized as being a fundamental step toward these goals. Consequently, a comprehensive Personnel Training Plan, which includes written testing procedures, has been developed. Improvements to the program will be implemented when appropriate. The objectives of the Personnel Training Plan are: 1. To provide each employee with the knowledge necessary to enable him or her to perform their job in a safe and effective manner. 2. To ensure that personnel are able to recognize potential hazards and are familiar with procedures and policies designed to mitigate and/or minimize such hazards should they occur. 3. To keep personnel familiar with policies and procedures and to implement additional training as regulatory and/or operational changes occur. The Personnel Training Plan consists of a combination of Formal Classroom Training, On-the-Job Training, and demonstrations and drills implemented by qualified site management, and other industry professionals (e.g., Red Cross, local fire department or training academy). Training is fundamental to efficient operation of the facility. The Personnel Training Plan is designed to provide basic training to all individuals who work at the facility and to give increasingly specialized training to those individuals performing more complex and/or potentially hazardous tasks on a need-to-know basis. NEICVP1493E01 Page 1 Appendix A Page 363 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut This plan and the operational procedures taught during training are designed to meet the requirements of 40 CFR 264.16, 29 CFR 1910.120 and 29 CFR 1910.1200, where applicable. Re-training is administered based upon individual and regulatory needs. Any revision or modification made to this plan will require a Class I or Class II permit modification and must be approved by the DEEP. 8.2 TRAINING METHODOLOGY 8.2.1 Formal Classroom Training One of the most common and effective methods of personnel training at Clean Harbors is classroom training [40 CFR 264.16(a)(1)]. Classroom training, which may include seminars given by off-site industry professionals, is supplemented by audio/visual/lecture presentations. In this manner, management ensures that all required subject matter has been addressed. Site-specific requirements can be emphasized and experts in a particular area may not only present the information, but can also be available for feedback and questioning. 8.2.2 On-the-Job Training Certain subject matter is not suitably addressed or absorbed in a classroom format and is best administered via On-the-Job Training [40 CFR 264.16(a)(1)]. On-the-Job training at Clean Harbors provides individualized training pertinent to normal daily operations of the facility. A major advantage of this type of training is "hands-on" experience, with supervision, for specific equipment and processes used at the facility. On-the-Job Training will be used primarily for orientation purposes for operational and laboratory new hires and transfers. On-the-Job Training will be based upon job duties and will be administered most often by an employee's supervisor, but always by an individual with prior experience in a particular area. 8.2.3 Assurance of Quality Training Assuring a high quality of training administered at the facility is of great importance and is accomplished through a number of means. 1. Safety and/or operations training. 2. Interactive discussions with employees to ensure that concepts are thoroughly communicated by the instructor and learned by the employee. 3. Daily, weekly and monthly inspections of facility operations to ensure that training has been effective. NEICVP1493E01 Page 2 Appendix A Page 364 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 4. Modifications of training courses or additional training may be provided if inspections indicate a need. These methods, as well as task specific On-the-Job Training, ensure continued effectiveness and quality of training. 8.3 RECORDKEEPING All training received by employees will be identified on their individual Employee Development Record (See Appendix 8-1 for sample record) [40 CFR 264.16(d)(4)]. The training subject, employee's name(s) and date of the training session are identified on the Employee Development Record. All of the training documentation for current personnel (Employee Development Records, Acknowledgments of Training Received, copies of each employee's completed written tests on training subjects) will be kept at the facility during its active life [40 CFR 264.16(e)]. Training records on former employees will be kept for at least three years from the date the employee last worked at the facility. Personnel training records may be transferred with the employee when transfers occur within Clean Harbors. The facility will also maintain records of the job title for each position at the facility and the name of the employee filling each job [40 CFR 264.16(d)(1)], and a written job description for each position at the facility involved in hazardous waste management. Information to be included is described in 40 CFR 264.16(d)(2). Training documentation may be kept in electronic or paper format. 8.4 OUTLINE OF TRAINING PLAN Table 8-1A identifies the Core Training Subjects, which form the base training for facility personnel [40 CFR 264.16(d)(3)]. The Core Training Subjects have been divided into two categories: Basic Training and Additional Training. Basic Training is provided to every individual assigned to the facility and provides them with the information necessary for their assigned tasks and performance expectations, as well as basic safety rules and means for responding to accidents, emergencies and alarms. Table 8-1B identifies additional training that is provided to individuals, depending on an individual's job description and other assigned duties (e.g., Emergency Coordinator for the Contingency Plan) and is updated, as needed, for remedial purposes and in accordance with various regulatory requirements. NEICVP1493E01 Page 3 Appendix A Page 365 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 8-1A CORE TRAINING SUBJECTS Basic Training* New Employee Orientation Job-Specific Duty Orientation Overview, Site Safety Procedures Contingency Plan Responsibilities Regulatory Requirements Gas Detection Response Requirements Additional Training** Frequency Waste Analysis Plan Annual DOT Requirements Annual Inspection Plan Annual Hazard Communication Annual Personal Protective Equipment Annual Respiratory Protection Program Annual Use and Maintenance of Fire Protective Equipment Annual Heat/Cold Stress Management Annual Hearing Conservation Annual Fork Lift and Heavy Equipment Training Initial Factors Influencing Reaction Rates Annual Basic Chemical Concepts Annual Basic Toxicological Principles Annual Laboratory/QC Safety Initial Confined Space Entry Annual Lock-Out/Tag-Out Procedures Annual Asbestos Training Initial Hot Work Procedures Initial Grounding and Bonding Safety Annual Safe Drum Handling Annual Placards, Labels and Marks 3 years Truck to Truck Operations (permitted waste streams, volume capacity, and duration) Initial Footnotes: *All employees receive Basic Training within six months of assignment to the facility and prior to working alone. **Additional Training is provided on a need-to-know basis and is updated as required. Initial- Training within 6 months and/or when changes are made. NEICVP1493E01 Page 4 Appendix A Page 366 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 8.1B - REQUIRED TRAINING FOR EACH JOB TITLE New Employee Orientation Job-Specific Duties Site Safety Procedures Contingency Plan Regulatory Requirements Hazard Communication Personal Protective Equipment Respiratory Protection Fire Equipment Heat/Cold Stress Management Hearing Conservation Fork Lift and Heavy Equipment Factors Influencing Reaction s Basic Chemical Concepts Basic Toxicological Principles Laboratory QC Confined Space Entry Lock-out Tag-out Procedures Asbestos Training Hot Work Procedures Grounding/Bonding Safety Safe Drum Handling Placards, Labels and Markings Truck-to-Truck Operations Facility General Manager I X X X X X X X X X X X X X X X X X X X X X X X X Compliance Manager X X X X X X X X X X X X X X X X X X Laboratory Manager X X X X X X X X X X X X X X X X X X X X X WWT Treatment Operator X X X X X X X X X X X X X X X Facility X X X X X X X X Lab Chemist I X X X X X X X X X X X X X X X X X X X X X X Facility Coordinator X X X X X X X X X X X X X X X X X X Equipment Operator X X X X X X X X X X X X X X X X X X X X X X X Plant Foreman X X X X X X X X X X X X X X X X X X X X X X X Facility Operations Manager I X X X X X X X X X X X X X X X X X X X X X X X Truck to Truck Technician X X X X X X X X X X X X X X X X X X X X X Facility Technician (I- III) X X X X X X X X X X X X X X X X X X X X X X X Facility Maintenance (I -III) X X X X X X X X X X X X X X X X X X X X X X X Receiving Chemist X X X X X X X X X X X X X X X X X X X X X X X X Compliance Guard X X X X X X X X X X X X X X NEICVP1493E01 Page 5 Version: 06-05-2018 Appendix A Page 367 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut This Page Left Intentionally Blank NEICVP1493E01 Page 6 Version: 06-05-2018 Appendix A Page 368 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 8.4.1 Basic Training Each new on-site operational employee will complete either a 24-hour or a 40-hour OSHA Hazardous Materials Management Training prior to job-specific and facility-specific duties. Refer to Appendix 8-4 for an outline of the 24- hour and 40-hour OSHA Hazardous Materials Management Training. Each employee must satisfactorily complete training in the five (5) basic subjects identified in Table 8-1, which includes the requirements of 40 CFR 264.16(a) [40 CFR 264.16(b)], prior to working alone. This training will be designed to: Familiarize the individual with facility operations; Establish basic rules of conduct and expectations for the individual's job performance; Minimize the potential for accidents or injuries, including conditions that may be unique to the facility; Ensure that the individual is able to respond properly to emergencies; and Familiarize the individual with the appropriate regulatory requirements. Basic training is updated as needed to introduce new or revised information. Updated training (encompassing all applicable training topics) will be provided on an as-needed basis. The actual duration is dependent on subject matter or changes to regulations or operations. Basic training consists of the following: 1. New Employee Orientation This orientation is designed to familiarize the new employee with the organization and administrative policies of the facility. Necessary insurance, payroll and taxation forms are also completed at this time. 2. Job Specific Duty Orientation This orientation is intended to describe in detail what an individual is expected to do. For new employees, the employee's supervisor or other designee will go over the job description with the individual to ensure they understand what they will be expected to do. For new or unusual tasks, the trainer will include a review of pertinent facility plans (e.g., Inspection Plan, Waste Analysis Plan), emergency response procedures, and the applicable Standard Operating Procedures (e.g. Calibration, Use and Maintenance of Equipment). A mixture of classroom and onthe-job training will be utilized. Written and/or oral tests will be utilized to determine if additional training is necessary. 3. Overview, Site Specific Safety Procedures This discussion establishes: a. That every individual is expected to conduct themselves in a safe manner; NEICVP1493E01 Page 7 Appendix A Page 369 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut b. The minimum required personal protective equipment for their job assignment (uniform, steel toe boots, hard hat and safety glasses); c. Restricted areas that may only be entered when wearing prescribed levels of personal protective equipment; (dismantling requires safety glasses; the remainder of the plant requires minimum personal protective equipment); d. Areas where individuals may eat, drink, smoke and use toilet facilities, and areas where they may not; e. The location of telephones, alarms, lists showing the names and phone numbers of Emergency Coordinator and alternates and response agencies, emergency evacuation rally points, and other emergency equipment (e.g., fire extinguishers, eyewash/safety showers); f. That employees must verbally report all accidents, unusual events and unsafe conditions to their supervisor or to the Emergency Coordinator; g. That there are personnel responsible and procedures in place for the inspection and repair of all safety equipment and emergency systems, and those employees will receive additional training if they are to perform these tasks; h. That there are various plans and procedures intended to minimize the potential for adverse reactions or incidents involving hazardous waste, such as the Waste Analysis Plan, and procedures for management of ignitable, reactive and incompatible wastes, and that employees will receive additional training if they have additional responsibilities relative to these plans; and i. The disciplinary policy of the facility, and administration of the policy by the facility's Disciplinary Committee. j. That employees are trained on the operation and activation of the SPOK, Inc. (formerly AMCOM) e-Notify system. 4. Contingency Plan All facility personnel are trained to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems, including the various conditions causing the implementation of the facility's Contingency Plan [40 CFR 264.16(a)(2) and (3)]. Employees will be instructed on all aspects of the Contingency Plan, including their role, the locations of emergency response equipment and communication or alarm systems, evacuation routes, rally locations, operation and activation of the SPOK, Inc. e-Notify system, and actions to be taken in response to an emergency (fire, explosion or release). In addition, emergency drills will be performed quarterly and each employee's response will be documented via a training record. This documentation will include NEICVP1493E01 Page 8 Appendix A Page 370 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut the date, time and details of the incident. The details will include all procedures performed to respond to the drill incident. a. Procedures for Using, Inspecting, Repairing, and Replacing Facility Emergency and Monitoring Equipment: Personnel shall receive instruction in the use of all emergency equipment applicable to their duties, including alarms and fire extinguishers. Appropriate personnel will be trained to inspect any facility emergency and monitoring equipment in their work area to prevent equipment failure. Instruction in this area will be in both classroom and on-the-job training. b. Key Parameters For Waste Feed Cut-off Systems: Material handlers shall receive training in the use of pumps and valves, which regulate waste flow to tanks, as part of the training for tank operators. They will also be trained in procedures used in the event the level of waste in the tank gets too high or an overfill occurs. c. Communication or Alarm System: Authorized personnel will be instructed as to the location and use of communication and alarm systems, including the SPOK, Inc. e-Notify system, as part of the Contingency Plan portion of training. Personnel in operational areas of the facility receive additional instruction in the use of communication systems and alarms particular to their respective areas. d. Response to Fires or Explosions: All personnel involved in hazardous waste management at the facility shall receive basic instruction in fire and explosion prevention and response, including the use of facility firefighting equipment and notification of the Bristol Fire Department. e. Response to Release of Hazardous Waste to the Environment: All personnel involved in hazardous waste management at the facility shall receive basic instruction in spill and release prevention and response. Emergency response training will be conducted in accordance with the facility Contingency Plan. f. Shutdown of Operations: The primary responsibility for shutdown of operations, evacuation routes and rally points lies with plant managers and supervisors. All personnel with operational responsibilities shall be instructed in the proper NEICVP1493E01 Page 9 Appendix A Page 371 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut procedures for planned and unplanned shutdown of operations, emergency evacuation routes, and rally locations. This training shall be provided as part of the job-specific training programs. 5. Regulatory Requirements This section presents an overview of the Resource Conservation and Recovery Act and other applicable regulations (e.g. Hazardous Material Transportation Act, Hazardous and Solid Waste Amendments of 1984, Occupational Safety and Health Act, Clean Water Act, Clean Air Act) and is most often a classroom discussion which includes: a. Basic requirements for the regulated community (generators, transporters and treatment/storage/disposal facilities); and b. The cradle-to-grave concept of the manifest. The relationship between Region I of the US EPA and the State of Connecticut Department of Energy and Environmental Protection is also discussed. 8.4.2 Continuing Emergency Response Training Continuing emergency response training shall be provided to maintain proficiency of plant personnel with regard to Contingency Plan emergency procedures. On a quarterly basis, training will be provided with regard to fire and spill prevention plans. Response drills will be provided by facility management to train employees concerning potential on-site incidents and possible remediation efforts. Drills will be held within designated work areas for emergency responses to minor spills, fires and releases. Area process shutdowns will be demonstrated, as will the use of emergency protective equipment. Quarterly, the emergency response team will practice release procedures and equipment use related to major fires and spills. Shutdown procedures for facility operations will be rehearsed. Annually, all personnel will rehearse a plant evacuation drill. In a separate activity, the Emergency Coordinator will be responsible for the planning and implementation of an emergency situation scenario for emergency response personnel. The emergency situation will be at the discretion of the Emergency Coordinator, and will involve roleplaying by emergency personnel and other plant operations personnel. The emergency response-training program is summarized in Table 8-2. NEICVP1493E01 Page 10 Appendix A Page 372 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 8.4.3 Additional Training Additional training (see subject listing on Table 8-1) is provided to individuals on a needto-know basis, depending on the requirements of their job. Appendix 8-2 provides a brief summary of the subject matter. Section 8.4, Table 8-1 of this plan identifies the training required for each position. As stated previously, the Core Training subjects are felt to be the basis for which personnel may operate the facility safely and efficiently. Additional specialized subject matter may be administered as the need or opportunity arises. TABLE 8-2 EMERGENCY RESPONSE TRAINING PROGRAM TRAINING FREQUENCY ACTIVITY ATTENDANCE Quarterly Drills for minor spill, fires and process shutdowns Spill, fire and release prevention (gaseous and liquid) Major fires, spills and operations shutdown drills for emergency response teams Annually Evacuation drills for all personnel Staged emergency situations for spill response teams REQUIRED All facility personnel All facility personnel Emergency Response Teams All facility personnel Spill Response Teams 8.4.4 Annual Refresher Course A minimum eight (8) hours of continuing training is provided at least annually for all facility employees involved in hazardous waste management [40 CFR 264.16(c)]. It includes both classroom and on-the-job training. It also includes the course topics presented in the initial training discussed in Sections 8.4.1 and additional training discussed in Section 8.4.2 of this plan, as needed. The classroom-training segment includes operational training meetings, formal classroom training, departmental safety meetings, and review of training modules as required. Topics for this training could include: Changes in types or quantities of wastes accepted, and treatment or storage mechanisms. Changes or revisions to permit conditions, emergency coordinators and general operations. NEICVP1493E01 Page 11 Appendix A Page 373 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  Any incident requiring the implementation of the contingency plan, notification requirements and so on. 8.5 PERSONNEL TRAINING INSTRUCTOR The General Manager at the Facility shall be responsible for directing the training of facility personnel in waste management procedures [40 CFR 264.16(a)(2)]. This individual shall be knowledgeable in all aspects of the facility operations and the environmental regulations, and is specifically trained in proper waste management procedures. 8.6 TRAINING DOCUMENTATION Documents and records maintained at the facility will include the following information: 1. The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job (updated as required). 2. A written job description for each position identified pursuant to no. 1 above and other pertinent information listed in 40 CFR 264.16(d)(2). 3. A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position identified pursuant to No. 1 above. 4. Records documenting all training conducted. 5. Documentation demonstrating that an annual review of the introductory training for each employee has been held. 6. A copy of the Personnel Training Plan with current information for each employee. 7. An Employee Development Record for each employee involved in hazardous waste management. Table 8-1A lists the initial training required for each job title [40 CFR 264.16(d)(2)]. Table 8-1B lists the annual update training required for each job title. Update training for these required subjects is to be conducted at least once per year. 8.6.1 Relevance of Training To Job Position Several figures previously shown demonstrate that the training program has been designed to tailor course requirements to the subject areas and levels of detail appropriate for each job title. NEICVP1493E01 Page 12 Appendix A Page 374 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut In summary, all personnel receive training related to personal safety, the chemistry of wastes and associated health effects, the facility Contingency Plan including emergency evacuation, waste regulations overview, and their rights regarding knowing the chemical hazards associated with materials at the facility. NEICVP1493E01 Page 13 Appendix A Page 375 of 612 Version: 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX 8-1 EMPLOYEE DEVELOPMENT RECORD NEICVP1493E01 Appendix A Page 376 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Empl Name Campbell,Bryan J Job Title Facility General Manager I NEICVP1493E01 DeptID '62WC' Location CT-BRIST01 Course Code CA1002 ED13MG ET2125 ET3050 HS1049 HS2100 HS4010 HS4020 HS4080 HS4090 HS5020 HS5095 HS6020 HS6035 HS6071 HS6074 HS6301 HS6302 HS6303 HS6304 HS6305 HS6306 HS6307 HS6308 LCR001 LCR002 LCR003 LCR004 LCR005 LCR006 LCR007 LCR008 LCR009 LCR010 MGMT11 MT1166 MT2030 MT2065 MT2070 MT2075 MT3009 MT3012 MT3020 MT3201 MT4001 MT4005 MT4010 MT4015 MT4020 MT4025 MT5005 MT6000 MT6001 MT6002 MT6003 MT6004 MT6006 Course Description Ethics Policy Training Prev Workplace Harassment MGR Reasonable Suspicion TestngSup Annual RCRA Training 09 - Cold/Fire OSHA 24 Hour Hazwoper Bonding & Grounding Powered Indus Truck (Forklift) LOTO Authorized Training Hot Work Training Affected Asbestos Safety Hydrogen Sulfide Awareness Fire Safety Toxicology Quantitative Fit Test Basic Waste Chemistry 1 of 8 Globally Harm Sys (GHS) 2 of 8 Medical/Bloodborne 3 of 8 Respiratory Protection 4 of 8 Conf Space/Heat Stress 5 of 8 Pers Prot Equip/Hearing 6 of 8 Decontamination Proc 7 of 8 Emergency Response 8 of 8 Drum/Material Handling Always Follow Work Permit Sys Always Prot EMP Wrk 4' Abv Grn Always Cond Ovrhd Lift Ops Saf Always Ens Exc Prot Sys in Pla Always Use Lifesaving PPE Never Use Ill Drugs/Alch 8hrs Never Smoke/Ign Srce in Unauth Never Operate Equip Not Train Never Poss Unauthorized Weapon Never Oper Tool etc Endan Life Behavioral Training MGR/SUP Alcohol & Drug Free Wkpl MNGR Overview of Clean Harbors Search & Inspection Policy EMP Search & Inspection Policy SUP Electronic Comm & Email Policy Trip & Dispatch App/Workbench CustomerNOW PSHR Training Entry/Reporting Social Media Policy Asset Mgmt Program Overview Assets Requiring Attention My Assets Short Term Rental Permit and Registrations DVIR Entry WIN Positive Employ Relations 2016 Compatibility Workbench Electronic Inspections Compliance Calendar Tank Management System Incident Management Workbench Cert of Disposal Workbench Course Taken 12/13/2011 11/18/2016 2/6/2017 2/1/2013 1/13/2017 4/19/2011 10/25/2013 10/26/2011 11/16/2016 12/7/2016 11/15/2016 11/15/2016 1/13/2017 11/16/2016 11/15/2016 1/24/2017 2/1/2017 11/15/2016 11/15/2016 11/15/2016 11/15/2016 11/15/2016 11/15/2016 11/15/2016 1/24/2017 1/24/2017 1/26/2017 1/26/2017 1/27/2017 1/27/2017 1/30/2017 1/30/2017 11/8/2016 2/1/2017 1/20/2017 12/19/2016 12/6/2013 12/20/2016 12/20/2016 12/20/2016 2/3/2017 1/20/2017 2/3/2017 12/20/2016 2/3/2017 2/3/2017 2/3/2017 1/6/2017 12/28/2016 2/2/2017 1/6/2017 2/2/2017 2/2/2017 2/2/2017 12/30/2016 12/30/2016 Appendix A Page 377 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX 8-2 DESCRIPTION OF ADDITIONAL TRAINING NEICVP1493E01 Appendix A Page 378 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Hazard Communication This program provides a basic understanding of the dangerous properties of chemical and hazardous substances and of the work place hazards that can result from improper use. The terms toxicity, dose and route of entry are defined in common sense terms. Examples of potential hazards and chemical exposures are drawn from commonplace facility operations. The program also describes the means available to workers to identify and prevent workplace hazards involving chemicals at the facility. Engineering Controls, personal protective equipment, container labeling and Safety Data Sheets are addressed as key components in better assuring the safe handling and use of chemical products. The OSHA Hazard Communication Standard is presented to inform workers of their rights and the requirements of these laws. Personal Protective Equipment The use of appropriate personal protective equipment while on the job is essential, especially in potentially hazardous working environments. This program is designed to make employees aware of the potential hazards that may be present in their working environment; and to outline procedures for use, handling and care of this equipment. Discussed are eye, head, foot, hearing, skin and respiratory protection. Respiratory Protection This program is designed to provide a basic understanding on why respiratory protection is necessary, the type of respiratory protection devices (RPD) that are available, the proper selection criteria and limitations of each type of RPD, and why training is necessary to assure maximum protection. Where appropriate, training in the proper application and use of emergency escape respirator(s) will be included. The facility's respiratory protection policy will also be discussed as it applies to emergency egress. This is updated not less than annually for individuals assigned respiratory gear. NEICVP1493E01 Appendix A Page 379 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The Program is also designed to provide instructions of the inspection, use and maintenance of the respiratory protection devices in use at the work site. The facility's written respiratory protection policy will be discussed in depth. Where appropriate, fit testing will be provided to assure proper selection and fit. Training in the proper application and use of self-contained breathing apparatus as well as the cascade system will also be provided. Updated not less than annually for persons required to be fit-tested or use breathing air. Introduction to the Use and Maintenance of Fire Protective Equipment Designed to familiarize employees on the various types of fire extinguishers, how they work and how to use them effectively in an emergency situation. Locations and uses of existing extinguisher. Heat/Cold Stress Management This training program is designed to alert employees to the potential harmful health effects associated with heat stress, and to instruct them in the proper procedures to follow when working in hot environments. Alternatively, safety concepts for working in the cold are discussed, including recognition and prevention of frostbite and hypothermia. Hearing Conservation Operations requiring the use of hearing protection are discussed, as well as how noise is measured and its effect from prolonged exposure. The facility's Hearing Conservation Program is discussed, including audiometric testing, noise abatement programs, selection, care, use and maintenance of hearing protection hear. Updated no less often than annually for those individuals who may be required to wear hearing protection. Forklift and Heavy Equipment Training This program consists of classroom and "hands-on" instructions, designed to train an employee in the safe and proper operation of a forklift truck. The program is completed with a qualifying test. NEICVP1493E01 Appendix A Page 380 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Factors Influencing Reaction Rates An introductory course which outlines the factors, which influence the rate of a chemical reaction. Included is a discussion on the effect the nature of the reacting chemical, the concentration, surface area and physical state of the reactants, temperature, activation energy and catalysis. Basic Chemical Concepts General principles of chemistry, which render substances hazardous, are covered in this session. The first portion covers flammable chemicals and possible fire hazards. The characteristics of a fire and handling procedures for flammable chemicals and possible fire hazards. The characteristics of a fire and handling procedures for flammable materials are discussed. The second portion covers characteristics and procedures for the handling of reactive/corrosive chemicals. The third portion covers characteristics and procedure for handling toxic/poisonous chemicals. Basic Toxicological Principles Covers the principles, which govern an individual's response to toxic materials and risks associated with each class of toxic chemicals. Laboratory/QC Safety A presentation of safety procedures utilized in the lab and by sampling personnel. Includes demonstration of sampling techniques, handling of samples and required forms, personal protective equipment and storage and handling of laboratory supplies. Confined Space Entry Instruct employees of the hazards inherent to any confined spaces entry. Instructions in correct procedures for entering confined spaces as well as motivation to follow these procedures at all times are included. NEICVP1493E01 Appendix A Page 381 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Lock-Out/Tag-Out Procedures This training program is designed to inform employees of the essential lock-out/tag-out procedures required to ensure safety while repairing, maintaining or entering equipment. Asbestos Training This program is designed to provide an understanding of the potential health effects associated with exposure to asbestos and the proper waste management practices that must be followed to minimize exposure. Updated no less than annually for personnel who might inadvertently be involved in containerized asbestos handling. Hot Work Procedures The facility's hot work permit procedures will be discussed in detail along with the preventative measures that should be taken to minimize the potential for fire, explosion, adverse health effects and electrical shock. Grounding and Bonding Safety This program has been developed to alert employees to the hazards of improper grounding and bonding of containers during liquid transfer. It shows the trainee what has to be accomplished to safely handle these transfer procedures by the use of proper grounds and bonds. Safe Drum Handling This course addresses proper drum handling procedures and includes specific information on the facility's drum storage requirements. Proper lifting and sampling procedures are discussed. Placards, Labels and Markings Designed to familiarize the employee with the DOT placards and labels, and EPA hazardous waste and PCB container markings. Truck-to-Truck Operations NEICVP1493E01 Appendix A Page 382 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The Truck-to-truck Transfer Plan of the permit will be used to train personnel about the permit and regulatory requirements for in transit shipments of waste. The training also includes system-tracking tools. NEICVP1493E01 Appendix A Page 383 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX 8-3 JOB DESCRIPTIONS NEICVP1493E01 Appendix A Page 384 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ID 042044 099696 5235 098508 2493 020325 098659 5906 042068 095977 095912 096972 023435 093538 043181 053581 Name David A Madrak Brad Picard Jason A Daigle Steven Brylow David H Berggren Denise M Bush Justin Pitt William J Pires Philip D Dobreski Victor Deliz Geoffrey Bok Jose Vega Jake P Lori Ferguson Woodie Bryan Campbell Donald Smith Descr Equipment Operator Equipment Operator Facility Coordinator WWT Operator Facility Manager Maintenance Facility Operations Coord Facility Operations Manager I Lab Chemist I Truck to Truck Technician Truck to Truck Technician Lab Supervisor WWT Operator Facility WWT Operator Facility Facility Technician I Facility General Manager I Corporate Compliance Manager Dept ID 62WC 62WC 62WC 62WC 62WC 62WC 62WC 62WC 60TT 60TT 62WC 62WC 62WC 62WC 62WC 60P3 Location CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CTC CH Reg/Temp Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Regular Full/Part FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL FULL NEICVP1493E01 Appendix A Page 385 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Position Description Instruction: The Job Code is to be created by Compensation unless you are updating or revising an existing, approved job description. JOB CODE 011219 JOB TITLE Equipment Operator I Pay Grade FLSA Status EEO Category File Name/Drive Location H17 Non-Exempt Operatives 011219_Equipment Operator I (HR Hardrive) Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation SUMMARY PARAGRAPH OF JOB RESPONSIBILITIES Definition The summary contains the primary responsibilities and purpose for this job listed below condensed in two or three sentences. [A suggested beginning is: The (insert job title) is primarily responsible for x, y and z.] The Equipment Operator I operates heavy equipment within the facility. Assures unit has daily maintenance duties performed and communicates any problems or issues with the unit immediately upon discovery. Definition PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Primary Duties and Responsibilities are specific functions and/or the main duties required to do one's job. They are the reason that the job exists and must be performed by the employee in this position. Instruction In order of significance and importance, list the primary duties and responsibilities. Ensures Health and Safety is the number one goal by following policies, processes, and acting in a safe manner at all times. Performs one of the following, backhoe, heavy duty crane, heavy duty forklift, and/or trackhoe. Operates a forklift as necessary. Completes daily checklist as required for proper operation of the unit being operated. Assures unit is never operated in an unsafe manner or in a manner which is inconsistent with Standard Operating Procedures. Completes and submits all associated paperwork as required for waste tracking movements. Assures that all containers are properly secured, ie chockblocks, jackstands. Ensures that work meets all applicable Health and Safety Standard Operating Procedures. NEICVP1493E01 Appendix A Page 386 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Ensures that work meets compliance standards within facility operation. Responsible for maintaining a clean work environment. Performs other duties and tasks as assigned from time to time by management and will be required by the needs of the Clean Harbors business. Disclaimer The above statements are intended to describe the general nature and complexity of the work being performed by personnel assigned to this classification, and do not represent an exhaustive list of all tasks, duties, and responsibilities required of personnel assigned to this position. It does not prescribe or restrict the work that may be assigned. Definition EDUCATION/KNOWLEDGE Minimum Education is the education that is needed to do the job correctly. Preferred Education is what you would like to have. Instruction Select the Minimum and Preferred Education from drop down and comment in the open box (at right) if specific education is to be included. Example Minimum Preferred For a Bookkeeper --Minimum is High School with Specialized Training in Accounting equivalent to two years college, Preferred is a Bachelor degree in Accounting. High School High School Education or equivalent. Definition EXPERIENCE Experience represents prior experience in a similar role or similar duties required to fully perform the job effectively. Instruction Select the Minimum and Preferred years of experience from the drop down and comment in the open box (at right) if specific experience is to be included. Minimum Other Preferred Specific Experience 1-2 Years of Specific Experience equipment operating experience. Definition REQUIRED LICENSE(S)/ENDORSEMENT(S) Required Licenses and Endorsements are specific licenses and endorsements required for employment in this job. NEICVP1493E01 Appendix A Page 387 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Instruction REQUIRED LICENSE(S)/ENDORSEMENT(S) List any and all specific licenses or endorsements required for this position. Note: This section may not be applicable for all jobs. Examples May include required licenses for driving, certifications required for the job (e.g. CDL Class A license), hazard waste endorsement, CPA in accounting/finance, required OSHA certified training. Training to operate equipment Definition COMPETENCIES Competencies are required knowledge, skills, and/or behaviors required for an individual to adequately perform in his/her role. Instruction List competencies that are required for this job. Some examples are noted below -- please note that Competencies are not limited to the examples provided. Examples Job specific competencies could be Beacon software knowledge, PeopleSoft 9.1, understanding of GAAP principles of accounting or SOX compliance, Win Web, or any other specific Clean Harbors' skill/behavior required for the position. Examples of generic competencies more related to level of position could be Time Management, Team Player, Communication Skills, Presentation Skills, Customer Focus, Organizational Agility, Drive for Results, Building Effective Teams, Developing Direct Reports, and Negotiating. Ability to work in team environment. Demonstrates complete proficiency in operation of one of the following units: backhoe heavy duty crane heavy duty forklift trackhoe NEICVP1493E01 Appendix A Page 388 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut COMPETENCIES Definition PHYSICAL REQUIREMENTS Physical Requirements are the PHYSICAL REQUIREMENTS NECESSARY to perform the job. The physical requirements must be job related and specific. Travel is considered a physical requirement. Instruction List all specific physical activities required to do this particular job. Examples Requirements for standing, sitting for extended periods of time, lifting (add weight or item), climbing a ladder, entering confined spaces, working in extreme heat conditions, safely jumping on and off equipment, 20/20 eye sight (corrective eye sight accepted), ability to pass test and wear respirator, ability to climb in and out of manhole. Able to enter/exit heavy equipment without strain ( sometimes climbing a ladder ) Able to operate physical controls/pedals associated with the piece of equipment ( manual dexterity) 20/20 eyesight corrected or uncorrected - depth perception is critical Needs good balance Ability to use tools and to assist in PM of Equipment Ability to lift hoods to assist with equipment repairs Ability to sit for extended periods of time Prepared By Date Submitted APPROVALS Name Date Compensation NEICVP1493E01 Appendix A Page 389 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES POSITION DESCRIPTION Job Title: Facility Coordinator Job Code: 110250 Hours/Days: 40 hours Grade: F Status: Non-Exempt The Facility Coordinator position coordinates several different functions in the facility, including receiving, shipping, and general administration. The essential elements of the position include, but are not limited to; 1. Working knowledge of WIN central and plant receiving, drum staging, and profile access and printing. 2. Data entry into Powersuite, WIN and/or local databases. 3. Organization and filing of plant paperwork and truck to truck paperwork. 4. Organization and maintenance of trailer inventories and data entry into shared files in Outlook. 5. Printing and creating outbound manifests and hazardous waste labels and for outbound loads. 6. Creation of TPO shipping papers for rejected materials. 7. Lab data entry into WIN system. 8. Data entry of tracking info into WIN for drum and bulk tracking operations. 9. Scanning storage areas and downloading of tracking gun. 10. Filing, typing, and general clerical duties. 11. Any administrative duties as deemed required by supervisors. 12. Responsibility for supply management in their area of responsibility, including proper housekeeping and best management practices. NEICVP1493E01 Appendix A Page 390 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 13. Responsible for adherence to all applicable CHES policies and CHES SOPs 14. Maintains a safe working environment that is in compliance with all applicable OSHA regulations as well as all applicable company Health & Safety and Compliance protocols. 15. Performs job functions in compliance with the company standard: Clean Compliance 16. Performs other assignments as assigned by management. EDUCATION/EXPERIENCE: High School or equivalent COMPETENCIES: Ability to work in team environment Proficiency in Windows based applications PHYSCIAL REQUIREMENTS: Always requires color determination Frequently requires sitting Occasionally requires speaking, listening, standing, reaching, carrying, climbing, walking, pulling and/or pushing, lifting up to 50 lbs., stooping and crouching, grasping, crawling, near vision acuity, and or smelling NEICVP1493E01 Appendix A Page 391 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Position Description Instruction: The Job Code is to be created by Compensation unless you are updating or revising an existing, approved job description. JOB CODE 160117 JOB TITLE Waste Water Treatment Operator 170098 210104 Pay Grade FLSA Status EEO Category File Name/Drive Location H16 Non-Exempt Operatives 160117_Waste Water Treatment Operator (HR Hardrive) Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation SUMMARY PARAGRAPH OF JOB RESPONSIBILITIES Definition The summary contains the primary responsibilities and purpose for this job listed below condensed in two or three sentences. [A suggested beginning is: The (insert job title) is primarily responsible for x, y and z.] The Waste Water Treatment Operator offloads and performs required treatments on drum and bulk loads, as well as operations of WWT CTU and filter press operations. Definition PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Primary Duties and Responsibilities are specific functions and/or the main duties required to do one's job. They are the reason that the job exists and must be performed by the employee in this position. Instruction In order of significance and importance, list the primary duties and responsibilities. Ensures Health and Safety is the number one goal by following policies, processes, and acting in a safe manner at all times. Operates a forklift when necessary. Responsible for performing and documenting daily safety check prior to operation. Is proficient in CTU and filter press operations. Offloads inbound tankers and performs treatments as instructed by the laboratory truck offloading sheets. Is responsible for final disposition of loads to laboratory prescribed tank. Rinses tankers and fill out final truck offloading paperwork. Completes daily CTU or filter press checklist. Runs CTU or filter press in accordance treatment recipes provided by the Laboratory. NEICVP1493E01 Appendix A Page 392 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Assures the CTU or filter press has daily maintenance duties performed and communicates any problems or issues with the unit immediately upon discovery to management and maintenance. Assures that the CTU or filter press is never operated in an unsafe manner or in a manner which is not consistent with Standard Operating Procedures. Completes and submits all associated paperwork as required for waste tracking movements and other pertinent record keeping requirements. Able to use scanning applications for waste tracking. Ensures that work meets all applicable Health and Safety Standard Operating Procedures. Reviews all applicable SOP's and satisfactorily completes quizzes. Ensures, understands, and has ownership for area specific permit required compliance standards. Responsible for maintaining a clean work environment. Understands Clean Compliance Standard. Performs other duties and tasks as assigned from time to time by management and will be required by the needs of the Clean Harbors business. Disclaimer The above statements are intended to describe the general nature and complexity of the work being performed by personnel assigned to this classification, and do not represent an exhaustive list of all tasks, duties, and responsibilities required of personnel assigned to this position. It does not prescribe or restrict the work that may be assigned. Definition EDUCATION/KNOWLEDGE Minimum Education is the education that is needed to do the job correctly. Preferred Education is what you would like to have. Instruction Select the Minimum and Preferred Education from drop down and comment in the open box (at right) if specific education is to be included. Example Minimum Preferred For a Bookkeeper --Minimum is High School with Specialized Training in Accounting equivalent to two years college, Preferred is a Bachelor degree in Accounting. High School High School Education or equivalent. Definition EXPERIENCE Experience represents prior experience in a similar role or similar duties required to fully perform the job effectively. Instruction Select the Minimum and Preferred years of experience from the drop down and comment in the open box (at right) if specific experience is to be included. NEICVP1493E01 Appendix A Page 393 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Minimum Specific Experience Other 1-2 years of experience in operations environment. Preferred Specific Experience Definition REQUIRED LICENSE(S)/ENDORSEMENT(S) Required Licenses and Endorsements are specific licenses and endorsements required for employment in this job. Instruction List any and all specific licenses or endorsements required for this position. Note: This section may not be applicable for all jobs. Examples May include required licenses for driving, certifications required for the job (e.g. CDL Class A license), hazard waste endorsement, CPA in accounting/finance, required OSHA certified training. DOT Training. Fork lift training (preferred). Definition COMPETENCIES Competencies are required knowledge, skills, and/or behaviors required for an individual to adequately perform in his/her role. Instruction List competencies that are required for this job. Some examples are noted below -- please note that Competencies are not limited to the examples provided. Examples Job specific competencies could be Beacon software knowledge, PeopleSoft 9.1, understanding of GAAP principles of accounting or SOX compliance, Win Web, or any other specific Clean Harbors' skill/behavior required for the position. Examples of generic competencies more related to level of position could be Time Management, Team Player, Communication Skills, Presentation Skills, Customer Focus, Organizational Agility, Drive for Results, Building Effective Teams, Developing Direct Reports, and Negotiating. Ability to work in team environment. Proficiency in Windows based applications. Leadership skills. Demonstrates complete proficiency in treatment operations. Knowledge of CHI systems. Scanning (waste tracking). View Plant Inventory. NEICVP1493E01 Appendix A Page 394 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut COMPETENCIES Definition PHYSICAL REQUIREMENTS Physical Requirements are the PHYSICAL REQUIREMENTS NECESSARY to perform the job. The physical requirements must be job related and specific. Travel is considered a physical requirement. Instruction List all specific physical activities required to do this particular job. Examples Requirements for standing, sitting for extended periods of time, lifting (add weight or item), climbing a ladder, entering confined spaces, working in extreme heat conditions, safely jumping on and off equipment, 20/20 eye sight (corrective eye sight accepted), ability to pass test and wear respirator, ability to climb in and out of manhole. Climb on and off forklifts Lifting up to 50 lbs from the ground to your waste Climb up and down vertical ladders Capable of reaching out, over and down exerting a force 20/20 eyesight corrected or uncorrected - depth perception is critical 10 pushups, deep knee squats and sit-ups (to determine if fit) Good hand/eye coordination Prepared By Date Submitted APPROVALS Name Date Compensation NEICVP1493E01 Appendix A Page 395 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Position Description Instruction: The Job Code is to be created by Compensation unless you are updating or revising an existing, approved job description. JOB CODE 160966 JOB TITLE Facility Operations Coord Pay Grade FLSA Status EEO Category File Name/Drive Location E15 Exempt - Administrative Administrative Support Workers 160966_Facility Operations Coord (HR Shared Drive) Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation SUMMARY PARAGRAPH OF JOB RESPONSIBILITIES Definition The summary contains the primary responsibilities and purpose for this job listed below condensed in two or three sentences. [A suggested beginning is: The (insert job title) is primarily responsible for x, y and z.] This position is primarily responsible for all activities for customer inbound loads, facility outbound loads, payroll and overall compliance assistance for all departments. Definition PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Primary Duties and Responsibilities are specific functions and/or the main duties required to do one's job. They are the reason that the job exists and must be performed by the employee in this position. Instruction In order of significance and importance, list the primary duties and responsibilities. Ensures Health and Safety is the number one goal by following policies, processes, and acting in a safe manner at all times. Maintain and Reconcile Plant Container Discrepancy Workbench Maintain all outbound manifest, returns and investigate missing items Assist and coordinate all outbound transportation Reconciliation of the weekly payroll Reconciliation of the P-Card Workbench Inspect invoices for both inbound and outbound loads for accuracy Track and complete all rebate activities in conjunction with finance Maintain schedule for inbound customer loads Create quotes, work orders and profiles for inbound loads Responsible for the maintenance and distribution of all plant reporting while maintaining compliance NEICVP1493E01 Appendix A Page 396 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Maintain and Reconcile all container inventory and ensure all items are tracked accordingly Assist with vouchering of invoices as necessary Assist with Shipping & Receiving inbound and outbound loads Maintain inventory levels of all office supplies Performs other duties and tasks as assigned from time to time by management and will be required by the needs of the Clean Harbors business. Disclaimer The above statements are intended to describe the general nature and complexity of the work being performed by personnel assigned to this classification, and do not represent an exhaustive list of all tasks, duties, and responsibilities required of personnel assigned to this position. It does not prescribe or restrict the work that may be assigned. Definition EDUCATION/KNOWLEDGE Minimum Education is the education that is needed to do the job correctly. Preferred Education is what you would like to have. Instruction Select the Minimum and Preferred Education from drop down and comment in the open box (at right) if specific education is to be included. Example Minimum Preferred For a Bookkeeper --Minimum is High School with Specialized Training in Accounting equivalent to two years college, Preferred is a Bachelor degree in Accounting. High School Definition EXPERIENCE Experience represents prior experience in a similar role or similar duties required to fully perform the job effectively. Instruction Select the Minimum and Preferred years of experience from the drop down and comment in the open box (at right) if specific experience is to be included. Minimum 1-3 years Preferred 3-5 years Specific Experience Accounting Specific Experience Accounting and General Office Definition REQUIRED LICENSE(S)/ENDORSEMENT(S) Required Licenses and Endorsements are specific licenses and endorsements required for employment in this job. Instruction List any and all specific licenses or endorsements required for this position. Note: This section may not be applicable for all jobs. NEICVP1493E01 Appendix A Page 397 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Examples REQUIRED LICENSE(S)/ENDORSEMENT(S) May include required licenses for driving, certifications required for the job (e.g. CDL Class A license), hazard waste endorsement, CPA in accounting/finance, required OSHA certified training. Definition COMPETENCIES Competencies are required knowledge, skills, and/or behaviors required for an individual to adequately perform in his/her role. Instruction List competencies that are required for this job. Some examples are noted below -- please note that Competencies are not limited to the examples provided. Examples Job specific competencies could be Beacon software knowledge, PeopleSoft 9.1, understanding of GAAP principles of accounting or SOX compliance, Win Web, or any other specific Clean Harbors' skill/behavior required for the position. Examples of generic competencies more related to level of position could be Time Management, Team Player, Communication Skills, Presentation Skills, Customer Focus, Organizational Agility, Drive for Results, Building Effective Teams, Developing Direct Reports, and Negotiating. Proficient in MS Office, Word and Excel Excellent Computer Skills Good working knowledge of WINWEB system Knowledge of Kronos Payroll System Working Knowledge of Peoplesoft System Communication Skills Customer Focus Organizational Skills Time Management Working knowledge of DOT, manifesting, placarding and labeling Definition PHYSICAL REQUIREMENTS Physical Requirements are the PHYSICAL REQUIREMENTS NECESSARY to perform the job. The physical requirements must be job related and specific. Travel is considered a physical requirement. NEICVP1493E01 Appendix A Page 398 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PHYSICAL REQUIREMENTS Instruction List all specific physical activities required to do this particular job. Examples Requirements for standing, sitting for extended periods of time, lifting (add weight or item), climbing a ladder, entering confined spaces, working in extreme heat conditions, safely jumping on and off equipment, 20/20 eye sight (corrective eye sight accepted), ability to pass test and wear respirator, ability to climb in and out of manhole. Requires speaking, listening, and acuity Requires sitting, standing, grasping, and reaching Requires walking, stooping, and crouching Requires lifting, pulling, pushing, or carrying up to 10 lbs. Prepared By Date Submitted APPROVALS Name Date Compensation NEICVP1493E01 Appendix A Page 399 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICE POSITION DESCRIPTION Job Title: Facility Operations Manager I Reports To: General Manager Job Code: 110744 Hours/Days: 40+ hours, Monday-Friday Grade: 7 Status: Exempt The Plant Operations Manager reports directly to the General Manager and is responsible for management of all plant operations such as drum pumping, drum dumping, tank farm operations. Plant Operations Managers act as second in command in the absence of the General Manager. The essential elements of the position include, but are not limited to; 1. Performs multiple site specific plant operations such as: drum pumping drum dumping tank farm operations truck offloading/loading in compliance with DOT segregation requirements wastewater treatment fuels blending Shredder operations Inventory and Waste Tracking scanning application Proper warehousing requirements 2. Oversees and manages multiple areas and shifts within the facility 3. Supervises and develops multiple Operations Supervisors, Plant Foremen and plant operations 4. Ensures proper waste routing and management according to specified efficiencies 5. Works in conjunction with the General Manager on personnel functions including, but not limited to hiring, terminating, development, etc 6. Works closely with the General Manager to continue to develop and enhance the facilities throughput and operation NEICVP1493E01 Appendix A Page 400 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 7. Analyzes and reviews profitability of facility in conjunction with the General Manager 8. Ensures that employees follow and maintain all applicable Health and Safety Standard Operating Procedures -Holds employees accountable 9. Ensures, understands and has ownership for area specific permit required compliance standards. 10. Develops daily production goals for multiple groups and ensures execution 11. Responsible for maintaining a clean work environment 12. Reviews all applicable SOP's and scores satisfactorily on quizzes 13. Performs other assignments as assigned by management 14. Understands and drives Clean Compliance standard EDUCATION/EXPERIENCE: High School diploma or equivalency BS in Chemistry or related field (preferred) 6-8 years of plant operations experience 4-5 years of plant supervision experience DOT training COMPETENCIES: Ability to work in team environment Proficiency in multiple site specific plant operations such as: - drum pumping - drum dumping - tank farm operations - truck offloading/loading - wastewater treatment - fuels blending - Shredder operations - Scanning applications - EOM inventory SOP's Initiative Leadership skills Management skills Knowledge of CHI systems PHYSCIAL REQUIREMENTS: NEICVP1493E01 Appendix A Page 401 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Always requires color determination Frequently requires standing, pulling and/or pushing, carrying, reaching, stooping and crouching, speaking, listening, or smelling Respirator Fit test Occasionally requires sitting, climbing, walking, lifting, grasping, crawling, near vision acuity. Fit test NEICVP1493E01 Appendix A Page 402 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES POSITION DESCRIPTION Job Title: Chemist I Reports To: Laboratory Manager Job Code: 051312 Family: CH Hours/Days: 40 hours, M-F Status: Non-Exempt Grade: F The Chemist I reports directly to the Laboratory Manager and is responsible for the routine analysis of samples to determine their chemical and physical properties. 1. Performs basic analysis of samples following prescribed procedures 2. Calibrates and utilizes basic instrumentation 3. Maintenance of equipment under direct supervision 4. Completes all paperwork associated with the analyses in a neat and timely fashion (ex., calibration logs, run logs, etc.) 5. Ensures that all work meets applicable QA/QC guidelines 6. Responsible for supply management in their area of responsibility 7. Responsible for proper management of waste generated as a result of analytical procedures 8. Responsible for maintaining a safe working environment that is in compliance with all applicable OSHA regulations as well as all applicable company Health and Safety and Compliance protocols. 9. Works under the direct supervision of more senior members of the laboratory General, all specialties: 1. Reviews all applicable laboratory SOPs, annually, and scores a satisfactory score on SOP quizzes. 2. Responsibility for supply management in their area of responsibility, including proper housekeeping and best management practices. NEICVP1493E01 Appendix A Page 403 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 3. Responsible for adherence to all applicable CHES policies and CHES SOPs 4. Performs job functions in compliance with the company standard: Clean Compliance 5. Performs other assignments as assigned by management. EDUCATION/EXPERIENCE: High School Diploma or equivalency BS in Chemistry or related science (strongly preferred) 0-1 years of experience in a laboratory setting 24 or 40 hour OSHA training and annual updates DOT training KNOWLEDGE: Solid understanding of math, chemistry and chemical testing COMPENETENCIES: Good organizational skills, decisiveness and initiative Computer skills Ability to work in a team environment PHYSICAL REQUIREMENTS: Always requires grasping, reaching, near acuity, listening, and smelling Frequently requires standing and speaking. Occasionally requires sitting, walking, lifting, pulling and/or pushing, carrying, stooping and crouching and color determination. NEICVP1493E01 Appendix A Page 404 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Position Description Instruction: The Job Code is to be created by Compensation unless you are updating or revising an existing, approved job description. JOB CODE 932122 JOB TITLE Truck to Truck Technician Pay Grade FLSA Status EEO Category File Name/Drive Location H14 Non-Exempt Operatives 932122_Truck to Truck Technician (HR Shared Drive) Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation SUMMARY PARAGRAPH OF JOB RESPONSIBILITIES Definition The summary contains the primary responsibilities and purpose for this job listed below condensed in two or three sentences. [A suggested beginning is: The (insert job title) is primarily responsible for x, y and z.] The Truck to Truck Technician is responsible for the movement and placement of waste from Clean Harbors' facilities, and direct generators. Definition PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Primary Duties and Responsibilities are specific functions and/or the main duties required to do one's job. They are the reason that the job exists and must be performed by the employee in this position. Instruction In order of significance and importance, list the primary duties and responsibilities. Ensures Health and Safety is the number one goal by following policies, processes, and acting in a safe manner at all times. Coordinates loads between hubs, plants, and outbound destinations. Ensures transportation efficiency and maintain compliance with our storage permits. Dispatches transportation from hubs. Assists on tracking of manifest return timelines. Maintains Hub Database (Outlook and Hub Management). NEICVP1493E01 Appendix A Page 405 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Performs other duties and tasks as assigned from time to time by management and will be required by the needs of the Clean Harbors business. Disclaimer The above statements are intended to describe the general nature and complexity of the work being performed by personnel assigned to this classification, and do not represent an exhaustive list of all tasks, duties, and responsibilities required of personnel assigned to this position. It does not prescribe or restrict the work that may be assigned. Definition EDUCATION/KNOWLEDGE Minimum Education is the education that is needed to do the job correctly. Preferred Education is what you would like to have. Instruction Select the Minimum and Preferred Education from drop down and comment in the open box (at right) if specific education is to be included. Example Minimum Preferred For a Bookkeeper --Minimum is High School with Specialized Training in Accounting equivalent to two years college, Preferred is a Bachelor degree in Accounting. High School Degree or Equivalency; Fork-lift trained Definition EXPERIENCE Experience represents prior experience in a similar role or similar duties required to fully perform the job effectively. Instruction Select the Minimum and Preferred years of experience from the drop down and comment in the open box (at right) if specific experience is to be included. Minimum Preferred Specific Experience Specific Experience Definition REQUIRED LICENSE(S)/ENDORSEMENT(S) Required Licenses and Endorsements are specific licenses and endorsements required for employment in this job. Instruction List any and all specific licenses or endorsements required for this position. Note: This section may not be applicable for all jobs. Examples May include required licenses for driving, certifications required for the job (e.g. CDL Class A license), hazard waste endorsement, CPA in accounting/finance, required OSHA certified training. Fork-lift trained NEICVP1493E01 Appendix A Page 406 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut REQUIRED LICENSE(S)/ENDORSEMENT(S) Definition COMPETENCIES Competencies are required knowledge, skills, and/or behaviors required for an individual to adequately perform in his/her role. Instruction List competencies that are required for this job. Some examples are noted below -- please note that Competencies are not limited to the examples provided. Examples Job specific competencies could be Beacon software knowledge, PeopleSoft 9.1, understanding of GAAP principles of accounting or SOX compliance, Win Web, or any other specific Clean Harbors' skill/behavior required for the position. Examples of generic competencies more related to level of position could be Time Management, Team Player, Communication Skills, Presentation Skills, Customer Focus, Organizational Agility, Drive for Results, Building Effective Teams, Developing Direct Reports, and Negotiating. Proficiency in Windows based applications Strong organizational skills Ability to perform multi tasks Strong communication skills Definition PHYSICAL REQUIREMENTS Physical Requirements are the PHYSICAL REQUIREMENTS NECESSARY to perform the job. The physical requirements must be job related and specific. Travel is considered a physical requirement. Instruction List all specific physical activities required to do this particular job. Examples Requirements for standing, sitting for extended periods of time, lifting (add weight or item), climbing a ladder, entering confined spaces, working in extreme heat conditions, safely jumping on and off equipment, 20/20 eye sight (corrective eye NEICVP1493E01 Appendix A Page 407 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PHYSICAL REQUIREMENTS sight accepted), ability to pass test and wear respirator, ability to climb in and out of manhole. Climb on and off forklifts Lifting up to 50 lbs from the ground to your waist Climb up and down vertical ladders Capable of reaching out, over and down exerting a force 20/20 eyesight corrected or uncorrected - depth perception is critical 10 pushups, deep knee squats and sit-ups (to determine if fit) Good hand/eye coordination Move a drum weighing up to 800 lbs with a drum dolly Moving a flex bin weighing up to 1500 lbs with a palette jack Prepared By Date Submitted 12/23/10 APPROVALS Name Date Compensation NEICVP1493E01 Appendix A Page 408 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Position Description Instruction: The Job Code is to be created by Compensation unless you are updating or revising an existing, approved job description. JOB CODE 111529 JOB TITLE Laboratory Supervisor *180090 Pay Grade FLSA Status EEO Category File Name/Drive Location E16 Exempt-Executive First/Mid Level Officials and Managers 111529_Laboratory Supervisor (HR Hardrive) Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation Input by/Determined by Compensation SUMMARY PARAGRAPH OF JOB RESPONSIBILITIES Definition The summary contains the primary responsibilities and purpose for this job listed below condensed in two or three sentences. [A suggested beginning is: The (insert job title) is primarily responsible for x, y and z.] The Laboratory Supervisor is responsible for the non-routine analysis of samples to determine their chemical and physical properties and managing laboratory operations. Definition PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Primary Duties and Responsibilities are specific functions and/or the main duties required to do one's job. They are the reason that the job exists and must be performed by the employee in this position. Instruction In order of significance and importance, list the primary duties and responsibilities. Ensures Health and Safety is the number one goal by following policies, processes, and acting in a safe manner at all times. Performs non-routine analysis of samples following prescribed procedures with the ability to solve minor problems. Calibrates and utilizes sophisticated instrumentation, able to understand all aspects of the instrumentation. Maintenance of equipment, including outside vendor scheduling per maintenance contract schedules and suggests solutions to equipment problems and new/replacement laboratory equipment. Completes all paperwork associated with the analysis in a neat and timely fashion. Ensures that all work meets applicable QA/QC guidelines. Ensures that laboratory maintains all applicable local, state and federal testing certifications. NEICVP1493E01 Appendix A Page 409 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut PRIMARY DUTIES AND RESPONSIBILITIES/ESSENTIAL FUNCTIONS Responsible for meeting analytical testing schedules for required permit and discharges. Maintains working relationship with outside laboratory for required permit and discharge analytical. Responsible for supply management in their area of responsibility. Responsible for problem solving when results fall outside of mandated specifications. Responsible for proper management of waste generated as a result of analytical procedures. Responsible for maintaining a safe working environment that is in compliance with all applicable OSHA regulations as well as all applicable company Health & Safety and Compliance protocols. Implements, maintains and provides necessary training in accordance with the Chemical Hygiene Plan. Supervises the laboratory staff of small operations Trains less senior members of the laboratory, implements and suggests operational improvement strategies, completes all personnel functions for the laboratory staff, including but not limited to, hiring, terminating, performance evaluations, as applicable. Performs other duties and tasks as assigned from time to time by management and will be required by the needs of the Clean Harbors business. Disclaimer The above statements are intended to describe the general nature and complexity of the work being performed by personnel assigned to this classification, and do not represent an exhaustive list of all tasks, duties, and responsibilities required of personnel assigned to this position. It does not prescribe or restrict the work that may be assigned. Definition EDUCATION/KNOWLEDGE Minimum Education is the education that is needed to do the job correctly. Preferred Education is what you would like to have. Instruction Select the Minimum and Preferred Education from drop down and comment in the open box (at right) if specific education is to be included. Example Minimum Preferred For a Bookkeeper --Minimum is High School with Specialized Training in Accounting equivalent to two years college, Preferred is a Bachelor degree in Accounting. High School High School diploma or equivalency. BS/BA in BS in Chemistry or related field. Definition EXPERIENCE Experience represents prior experience in a similar role or similar duties required to fully perform the job effectively. Instruction Minimum Select the Minimum and Preferred years of experience from the drop down and comment in the open box (at right) if specific experience is to be included. Preferred NEICVP1493E01 Appendix A Page 410 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Specific Experience 4-5 years of experience in a laboratory setting. Specific Experience Maintains all applicable local/state credentials. Definition REQUIRED LICENSE(S)/ENDORSEMENT(S) Required Licenses and Endorsements are specific licenses and endorsements required for employment in this job. Instruction List any and all specific licenses or endorsements required for this position. Note: This section may not be applicable for all jobs. Examples May include required licenses for driving, certifications required for the job (e.g. CDL Class A license), hazard waste endorsement, CPA in accounting/finance, required OSHA certified training. 24 or 40 hour OSHA training and annual updates. IATA certification (where approved by CHES Transportation Compliance). DOT training. Definition COMPETENCIES Competencies are required knowledge, skills, and/or behaviors required for an individual to adequately perform in his/her role. Instruction List competencies that are required for this job. Some examples are noted below -- please note that Competencies are not limited to the examples provided. Examples Job specific competencies could be Beacon software knowledge, PeopleSoft 9.1, understanding of GAAP principles of accounting or SOX compliance, Win Web, or any other specific Clean Harbors' skill/behavior required for the position. Examples of generic competencies more related to level of position could be Time Management, Team Player, Communication Skills, Presentation Skills, Customer Focus, Organizational Agility, Drive for Results, Building Effective Teams, Developing Direct Reports, and Negotiating. Ability to work in team environment. Solid understanding of math, chemistry and chemical testing. Advanced working knowledge of the laboratory. Proficiency in Windows based applications. NEICVP1493E01 Appendix A Page 411 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut COMPETENCIES Knowledge of operating system. Organization skills. Problem solving skills. Initiative. Working knowledge of the laboratory. Understands the labs role in the operation. Leadership skills. Management skills. Knowledge of CHI systems. Definition PHYSICAL REQUIREMENTS Physical Requirements are the PHYSICAL REQUIREMENTS NECESSARY to perform the job. The physical requirements must be job related and specific. Travel is considered a physical requirement. Instruction List all specific physical activities required to do this particular job. Examples Requirements for standing, sitting for extended periods of time, lifting (add weight or item), climbing a ladder, entering confined spaces, working in extreme heat conditions, safely jumping on and off equipment, 20/20 eye sight (corrective eye sight accepted), ability to pass test and wear respirator, ability to climb in and out of manhole. Requires color determination. Requires standing, pulling and/or pushing, carrying, reaching, stooping and crouching, speaking, listening, and smelling. Requires sitting, climbing, walking, lifting, grasping, crawling, near vision acuity. Prepared By Date Submitted APPROVALS Name Date Compensation NEICVP1493E01 Appendix A Page 412 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICE POSITION DESCRIPTION Job Title: Facility Technician I Reports To: Plant Foreman or Operations Supervisor Job Code: 151204 Family: No Family Hours/Days: 40 hours, days vary Grade: Status: Non Exempt Facility Technician I reports directly to a Plant Forman or Operations Supervisor and performs hands on operations such as drum pumping, drum dumping, tank farm operations. The essential elements of the position include, but are not limited to; 1. Performs basic plant operations including, but not limited to: drum pumping drum dumping tank farm truck loading/unloading truck offloading/loading filter press operations 2. Operates a forklift when necessary 3. Completes and submits all associated paperwork as required for waste tracking movements 4. Ensures that work meets all applicable Health and Safety Standard Operating Procedures 5. Ensures that work meets compliance standards within facility operation. 6. Meets or exceeds production goals 7. Responsible for maintaining a clean work environment 8. Performs other assignments as assigned by management NEICVP1493E01 Appendix A Page 413 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut EDUCATION/EXPERIENCE: High School Education or equivalent Fork lift training (preferred) COMPETENCIES: Ability to work in team environment PHYSCIAL REQUIREMENTS: Always requires color determination Frequently requires standing, pulling and/or pushing, carrying, reaching, stooping and crouching, speaking, listening, tasting or smelling Occasionally requires sitting, climbing, walking, lifting, grasping, crawling, near vision acuity NEICVP1493E01 Appendix A Page 414 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICE POSITION DESCRIPTION Job Title: Facility General Manager Job Code: 160705 Reports To: Regional Vice President or Director Grade: 9 Summary: The Plant General Manager reports directly to the Regional Vice President Services and has direct responsibility for an assigned Transfer, Storage, and Disposal Facility which includes waste management, health & safety, compliance, profit & loss, and staffing. 1) Manages labor to assure operating costs are in line with budgeted and projected revenue. Labor management includes all employee hours worked, overtime hours worked, hiring, firing, and performance appraisals. Responsibilities also include labor relations, and management in accordance with worker's compensation regulations and laws. 2) Manages to facility to the clean compliance standards and measure against the CCP KPI's 3) Recommends merit increases and promotions of facility personnel. 4) Manages processing of hazardous and non-hazardous wastes according to specified requirements including RCRA, DOT, customer requirements, and least cost routing. Intimately knowledge of all facility specific capabilities and processing technologies including, but not limited to, wastewater treatment, fuels blending, incineration, lab pack processing, blending, bulking, shredding, pumping. 5) Ensures and enforces corporate and facility specific Health & Safety protocol and Standard Operating Procedures. Continuously works closely with the safety department to enhance and improve safety within facility as a top priority. Cochairs Facility Health & Safety meetings, 6) Ensures and enforces corporate and facility specific Compliance protocol and Standard Operation Procedures. Maintains the facility in compliance with Part B RCRA permit, or equivalent. Continuously works with the Facility Compliance Manager to assure continued compliance with all corporate and regulatory protocol. NEICVP1493E01 Appendix A Page 415 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 7) Manages and assures accurate and timely analytical, final coding, and billing of lab pack, drum, bulk solid, and bulk liquid materials. 8) Works closely with National Logistics to coordinate and assure proper outbound management of waste materials from disposal facilities. 9) Reviews and approves all purchasing for the facility. 10) Responsible for management of profit and loss statement according to budgeted revenue and percentages. Assures operating costs, labor, materials, supplies, disposal, and SG&A costs meet or exceed budgeted parameters. 11) Responsible for the training and development of all plant employees. Responsible for mentoring current and future managers assuring the continued growth of the company. 12) Assures facility is properly maintained; Management of maintenance department including oversight of Mapcon preventative maintenance system. 13) Assures facility is always clean and presentable for customer audits and tours. Participates when necessary or requested. 14) Assures facility provides proper customer service both internally and externally. 15) Develops and assures a good working relationship with local Field Service General Manager, Technical Services General Manager, and Logistics Manager. 16) Performs other assignments as assigned by management. Education: BS/BA degree or equivalent industry experience. Knowledge/Other: 6-8 years of plant operations experience. 7-10 years industry experience (preferred) 3-4 years of management experience Working knowledge of environmental statutes and Knowledge of CHI Policies & Procedures Knowledge of CHI Priorities Ability to work in team environment Good organization skills and initiative Leadership skills and experience Computer skills and knowledge of CHI systems. Interpersonal and communication skills regulations. NEICVP1493E01 Appendix A Page 416 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLEAN HARBORS ENVIRONMENTAL SERVICES, INC. POSITION DESCRIPTION Job Title: Corporate Compliance Manager Reports To: Job Code: 10130 Family: CPM Hours/Days: 40+ Grade: 6 Status: Exempt 1. Provides responses to compliance, sales, field personnel and customers concerning federal, state and local environmental regulations. 2. Prepares regulatory permit submittals including Part B permit applications, NPDES permit applications, TSCA authorizations, generator biennial reports, export/import notices, SARWA Tier I and II reports, TRI reports,e tc. 3. Performs audits of internal facilities to ensure effectiveness of compliance programs. 4. Performs audits of external facilities for liability of continued use. 5. Performs other assignments as assigned by management EDUCATION/EXPERIENCE: A.S./A.A. degree in Environmental Science or related field (preferred) 2-4 years compliance experience (required) COMPETENCIES: Knowledge of Department of Transportation (DOT) and Environmental Protection Agency (EPA) laws/regulations (required) Excellent communication, writing and presentation skills Excellent organizational skills PHYSCIAL REQUIREMENTS: Always requires color determination Frequently requires standing, pulling and/or pushing, carrying, reaching, stooping and crouching, speaking, listening, tasting or smelling Occasionally requires sitting, climbing, walking, lifting, grasping, crawling, near vision acuity NEICVP1493E01 Appendix A Page 417 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut APPENDIX 8-4 TRAINING OUTLINES NEICVP1493E01 Appendix A Page 418 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 24 HOUR EMERGENCY RESPONSE OPERATIONS SYLLABUS Introduction to Plant Plant Emergency Response Plan and Evacuation Routes and Rally Points Operations on site Buildings location H2S Monitoring System Bristol VPP Initiative Regulatory Overview Legislation Enacted 29 CFR 1910.120 Summary Training and Incident commander system Chemical Definitions Building Blocks Organic vs. Inorganic Physical Properties Waste Classifications Flammability Flash Point Fire Tetrahedron Flammable Range Fire Extinguisher Bonding and Grounding Corrosivity The Power of Hydrogen Acids Bases Halogens Neutralization Reactivity Exothermic Endothermic Detonation Deflagration Oxidizers Toxicology Routes of Entry Storage in the Body Routes of Excretion Metabolism Action of Toxic Substances Acute Effects Chronic Effects Local vs. Systemic Effects NEICVP1493E01 Appendix A Page 419 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Exposure Limits Permissible Exposure Limit Threshold Limit Value Recommended Exposure Limit Immediately Dangerous to Life and Health Concentrations of chemical Exposures Parts per Million Milligrams per cubic Meter Clean Harbors Action Levels (exposure limits) Common Units of Measure Respiratory Protection Training Air Purifying Respirator (APR) Selection Criteria Respirator Limitations Oxygen Deficiency Maximum Use Concentration IDLH Atmospheres Warning Properties Change out schedules Inappropriate Hazardous Chemicals Fit Testing Cleaning Respirators Air Supply Respirator (ASR) Self Contained Breathing Apparatus (SCBA) Inspecting Respirators Storage Medical Evaluations Personal Protective Equipment Hazard Control Hazard Assessment Eye and Face Protection Corrective Lenses Face shields Head Protection Foot Protection Hand Protection Chemical Protective Clothing Chemical Resistance Levels of Protection Hearing Conservation NEICVP1493E01 Appendix A Page 420 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Decontamination Work Zones Decontamination Solutions Locker Room Protocol Monitoring Equipment Multi Gas Meter Photoionization Detector (PID) Direct reading Colorimetric Indicator Tubes (Sensidine Tubes) Hazard Communication and Information Sources Health and Safety Hazards Safety Data Sheets (SDS) Hazard Communication Reference Books and Networks Medical Surveillance First Aid Primary Survey Bleeding and Shock Blood borne Pathogens Shock Burns Heat Emergencies Cold Emergencies Poisoning Forklift Training Video and Classroom Testing Practical Application and Review Do's and Don'ts at the Facility Receiving Processing 40 Hr. Hazardous Waste Site Operations & Emergency Response The Below Agenda May Be Modified On A Day-To-Day Basis Due To Overall Class Performance. Day 1: 8:00 a.m. Registration & Introduction Regulation Overview Hazardous Materials Toxicology 12:00 p.m. Lunch 1:00 p.m. Respiratory Protection NEICVP1493E01 Appendix A Page 421 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  SCBA Maze/Practical 5:00 p.m. Adjourn Day 2: 8:00 a.m. First Aid Overview Hazard Communication Emergency Response Procedures 12:00 p.m. Lunch 1:00 p.m. Site Control and Decontamination Procedures Personal Protective Equipment Dress Out and Decontamination Practical 5:00 p.m. Adjourn Day 3: 8:00 a.m. Review Game (Day 1 & 2) Drum Handling and Spill Control Air Monitoring Equipment/Procedures Level "A" Demonstration 12:00 p.m. Lunch 1:00 p.m. Emergency Response Practical Critique of Emergency Response Test 5:00 p.m. Adjourn Day 4: 8:00 a.m. Excavation Safety Confined Space Entry Hazard Control Lock Out/Tag Out 12:00 p.m. Lunch 1:00 p.m. NEICVP1493E01 Appendix A Page 422 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  5:00 p.m. Confined Space Entry Practical Air Line Supplies Air Respiratory Protection Extraction Device Fall Protection Adjourn Day 5: 8:00 a.m. Site Characterization DOT/RCRA Overview 12:00 p.m. Lunch 1:00 p.m. DOT/RCRA Overview (continued) Final Exam 5:00 p.m. Adjourn NEICVP1493E01 Appendix A Page 423 of 612 Version 06-05-2018 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT D CONTINGENCY PLAN (Submitted with the RCRA Part B Permit Application in March 2017) (Updated on August 8, 2020) Clean Harbors of Connecticut, Inc. Contingency Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 424 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN CONTINGENCY PLAN CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT EPA ID NO. CTD000604488 Revised August 18, 2020 NEICVP1493E01 Appendix A Page 425 of 612 Revised 08/18/20 Page 1 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Table of Contents 1.0 CONTINGENCY PLAN............................................................................................................................4 1.1 PURPOSE AND IMPLEMENTATION...............................................................................................4 1.1.1 Facility Description ..........................................................................................................................4 1.1.2 Amendments to the Plan...................................................................................................................6 1.1.3 Location of the Plan..........................................................................................................................7 1.1.4 Distribution of the Plan ....................................................................................................................7 1.1.5 Implementation of the Plan...............................................................................................................8 1.2 EMERGENCY PROCEDURES...........................................................................................................9 1.2.1 Responsibilities of the Emergency Coordinator ...............................................................................9 1.2.1.1 Implementation of Emergency Procedures ..............................................................................9 1.2.1.2 Emergency Investigation and Severity Assessment Procedures ............................................10 1.2.2 Fire/Explosion Response Procedures .............................................................................................14 1.2.2.1 Minor Fires ...........................................................................................................................15 1.2.2.2 Major Fire/Explosion............................................................................................................15 1.2.3 Spill Prevention and Response Procedures ....................................................................................16 1.2.3.1 Minor Leaks and Spills .........................................................................................................16 1.2.3.2 Major Spills ..........................................................................................................................18 1.2.3.3 Spill Response Safety Precautions and Countermeasures ....................................................19 1.2.4 Emergency Response Procedures for Tanks...................................................................................20 1.2.5 Emergency Response Procedures for Air Emissions......................................................................22 1.2.6 Procedures for Severe Weather Episodes.......................................................................................23 1.3 EMERGENCY EQUIPMENT LIST ..................................................................................................23 1.3.1 Signs ...............................................................................................................................................23 1.3.2 Alarm System .................................................................................................................................23 1.3.3 Public Address System ...................................................................................................................24 1.3.4 Fire Control Equipment ..................................................................................................................24 1.3.5 Spill Control Equipment.................................................................................................................24 1.3.6 Safety and First Aid Equipment .....................................................................................................25 1.3.7 Personal Protective Equipment.......................................................................................................25 1.3.8 Decontamination Equipment ..........................................................................................................26 1.3.9 Wind Sock ......................................................................................................................................26 1.3.10 Equipment, Testing, and Maintenance .......................................................................................26 1.3.11 Emergency Stations....................................................................................................................26 1.3.12 Radios.........................................................................................................................................27 1.3.13 Air Monitoring Instrumentation and Controls............................................................................27 1.4 EVACUATION PLAN.......................................................................................................................27 1.4.1 Initial Scene Assessment ................................................................................................................27 1.4.2 On-site Evacuation Procedures.......................................................................................................28 1.5 POWER FAILURE.............................................................................................................................28 1.6 SPECIALTY COMPRESSED GASES ..............................................................................................30 NEICVP1493E01 Appendix A Page 426 of 612 Revised 08/18/20 Page 2 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 TABLES Table 1.1 Table 1.2 APPENDICES Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Implementation of the Contingency Plan Compressed Gas Cylinder Inventory Facility Location and Surrounding Area Plan List of Emergency Coordinators Facility Site Plan and Evacuation Routes Incident Investigation Report Emergency Response Delegation Checklist Permitted Wastes and Waste Management Areas CONTINGENCY PLAN 8 30 NEICVP1493E01 Appendix A Page 427 of 612 Revised 08/18/20 Page 3 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.0 CONTINGENCY PLAN 1.1 PURPOSE AND IMPLEMENTATION The Contingency Plan and emergency procedures presented in this section outline the actions to be taken by facility personnel in the event of a fire, explosion, or unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water [40 CFR 264.5l(a) and (b)]. Quarterly drills are held to practice and improve the plan's emergency response implementation. These drills are designed to provide practice to personnel responding to various scenarios and improve communication with the Fire Department and facility neighbors. The Contingency Plan covers the following basic points: Arrangements made with the local emergency response units (police, fire departments, and hospitals) and spill response contractor; and Actions to be taken by facility personnel in response to an emergency (fire, explosion, spill, or unplanned sudden or non-sudden release). Pursuant to OSHA standard 1910.38a, "Employee Emergency Plans and Fire Prevention Plans", all facility operational personnel are trained in the usage of fire extinguishers to extinguish incipient stage fires and the proper procedures in the event of a facility evacuation. The facility's General Manager, Compliance Manager, Laboratory Manager, Laboratory Chemist, Receiving Chemist, Operations Manager, Facility Foreman, Facility Technicians, and Maintenance Technicians are 24 or 40-hour OSHA trained, and certified in CPR and first aid. Only when initially responding to an emergency will Clean Harbors personnel perform rescue actions or first aid. Otherwise the Bristol Police, Fire, and Emergency Medical personnel will be called. 1.1.1 Facility Description Clean Harbors operates a commercial facility for the storage, treatment and recycling of RCRA hazardous and non-RCRA hazardous waste. The facility is located at 5l Broderick Road in Bristol, Connecticut. The facility location is depicted on the Surrounding Area Plan provided in Appendix 1. The Facility performs the following waste management activities: Storage in containers and tanks; The loading and unloading of bulk and non-bulk containers of waste; Waste water treatment; Storage of debris in roll-off containers; The storage and disassembly of solid and universal wastes; The rinsing and crushing of non-bulk containers; NEICVP1493E01 Appendix A Page 428 of 612 Revised 08/18/20 Page 4 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The thawing of frozen aqueous wastes; The solidification/stabilization of solid and semi-solid wastes; and The truck-to-truck transfer of asbestos-containing, biomedical, RCRA hazardous and non-RCRA hazardous wastes. The categories of permitted wastes accepted, stored and treated at the Facility are provided in Appendix 6. The facility consists of waste management areas identified on the Facility Site Plan in Appendix 3 for the facility site plan: 1. Operations Building - Rinse, Crushing and Lab Pack Pour-off Stations: These areas are used for the rinsing of empty non-bulk containers, the crushing of metal non-bulk containers, and the pour-off of lab pack containers into the wastewater treatment system. 2. Operations Building - Container Storage Areas H, K, L, M1 and M2: Container Storage Area H is utilized for the temporary storage of non-bulk containers of permitted wastes prior to treating on-site, staging outbound shipments of waste, and the disassembly of lab pack containers., Container Storage Area K is utilized for the storage of non-bulk containers of permitted wastes classified as acidic, for a period of one year prior to treating on-site or preparing such waste for a shipment to an off-site facility. Container Storage Area L is utilized for the storage of non-bulk containers of permitted wastes classified as non-acidic or PCB-containing. Container Storage Area M1 is utilized to temporarily stage non-bulk containers of permitted wastes classified as acidic during waste verification activities. Container Storage Area M2 is utilized to temporarily stage non-bulk containers of permitted wastes classified as alkaline during waste verification activities. 3. Waste Storage Tank Nos. 11 and 14: These tanks are utilized for the storage of permitted wastes. 4. Bulk Unloading and Loading Area (BULA): This area is utilized for the loading and unloading of bulk and non-bulk containers of permitted wastes, the temporary storage of bulk containers of wastewater treatment sludge generated on-site, the transfer of waste between containers, the disassembly and consolidation of lab packs containing spilled or leaked wastes, and the solidification of leaking bulk containers. 5. Container Storage Area C: This area is utilized for the storage of non-bulk containers of permitted wastes classified as flammable for a period not to exceed one year, prior to treating on-site or preparing such waste for a shipment to an off-site facility. 6. Mix-Tub, Bulk Storage, and Transfer Areas (MBSTA): This area is utilized for the stabilization of RCRA hazardous solid and semi-solid wastes by means of mixing such wastes with stabilization agents to render the waste non-RCRA hazardous, the NEICVP1493E01 Appendix A Page 429 of 612 Revised 08/18/20 Page 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN solidification of non-RCRA hazardous solids and semi-solid wastes by means of mixing such wastes with solidification agents to render the waste more amenable for off-site treatment, the transferring of RCRA and non-RCRA wastes from the stabilization tubs into bulk containers for off-site shipment, the rinsing of bulk and non-bulk containers and associated equipment over the stabilization tub and the removal of free draining liquid resulting from the transportation of bulk containers prior to stabilization or solidification. 7. Container Storage Areas A, B, D, E, F, G and J: Container Storage Area A: This area is utilized for the storage of non-bulk containers of permitted wastes classified as acid-reactive. Container Storage Area B: This area is utilized for the storage of non-bulk containers of universal wastes, solid wastes, and wastes resulting from the disassembly of such wastes (e.g., cathode ray tubes, plastic and metal) in Rows 8, 9 and 10 for a period not to exceed one year, prior to disassembling on-site or preparing such waste for a shipment to an offsite facility. Rows 1 through 7 are utilized for the storage of non-bulk containers of permitted wastes classified as alkaline. Container Storage Area D: This area is utilized for the storage of non-bulk containers of permitted wastes classified as toxic or PCB-containing materials. Container Storage Area E: This area is utilized for the storage of non-bulk containers of permitted wastes classified as toxic or PCB-containing materials. Container Storage Area F: This area is utilized for the storage of non-bulk containers of permitted wastes classified as acidic. Container Storage Area G: This area is utilized for the storage of non-bulk containers of permitted wastes classified as acidic. Container Storage Area J: This area is utilized for the disassembly of wastes classified as used electronics, the extraction of CFC liquid from scrap metal appliances, and the disassembly of scrap metal appliances. 8. Loading/Unloading Dock Area: This area is utilized for the transfer of non-bulk containers of permitted wastes from one transportation vehicle to another, and the loading and unloading of non-bulk containers to and from the facility. 9. Existing and Proposed Truck Parking Areas: These areas are utilized for the temporary staging of vehicles containing wastes not destined for the facility and the temporary staging of transportation vehicles containing wastes for off-site shipment. 1.1.2 Amendments to the Plan The Contingency must be reviewed, and immediately amended, if necessary, whenever: The facility permit is revised, if necessary [to comply with 40 CFR 264.54(a)]; The plan is found to be deficient during an emergency [40 CFR 264.54(b)]; NEICVP1493E01 Appendix A Page 430 of 612 Revised 08/18/20 Page 6 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The facility changes its design, construction, operation, and/or its management policies and procedures relative to the maintenance of this plan [40 CFR 264.54(c)]; The types of waste handled are changed; The Emergency Coordinator list changes [40 CFR 264.54(d)]; or The list of emergency equipment changes [40 CFR 264.54(e)]. 1.1.3 Location of the Plan Pursuant to 40 CFR 264.53(a) copies of this Contingency Plan will be maintained on-site at each of the spill supply cabinets (see Appendix 3 for the site plan). In addition, copies of and amendments to the Contingency Plan will be submitted to the local police department, fire department, hospital, the State of Connecticut Department of Energy and Environmental Protection (CT DEEP), and the Environmental Protection Agency (US EPA), Region 1, pursuant to 40 CFR 264.53(b). Lists of specified emergency response agencies will be posted near the telephone of the Emergency Coordinator and in the facility manager's office. 1.1.4 Distribution of the Plan Copies of the Clean Harbors of Connecticut Contingency Plan and cover letter sent with the contingency plan shall be filed with the following agencies: Clean Harbors Environmental Service, Inc., 770 Derby Avenue, Seymour, CT 06483; State of Connecticut Department of Energy and Environmental Protection (CT DEEP) Emergency Response and Spill Prevention Division, 79 Elm Street, Hartford, CT 06106; City of Bristol Fire Department, 181 North Main Street, Bristol, CT 06010; City of Bristol Police Department, 131 North Main Street, Bristol, CT 06010; Bristol Hospital, 41 Brewster Road, Bristol, CT 06010; City of Bristol Health Department, 240 Stafford Avenue, Forestville, CT 06010; City of Bristol Emergency Management Director, 111 N. Main Street, Bristol, CT 06010; Environmental Restoration LLC, 110 Granby Street, Bloomfield, CT 06002; Environmental Services, Inc., 90 Brookfield Street, South Windsor, CT 06074. Cooperating agencies will be familiarized with the facility layout, properties of the waste handled at the facility and associated hazards, emergency equipment and operation, evacuation plans and routes, and other critical information. Cover letters sent with the contingency plan copies shall also indicate the service to be provided by that authority (e.g., fire department will respond to fires). Any amendments to the Contingency Plan will result in a re submittal of the amended plan to the agencies listed above. NEICVP1493E01 Appendix A Page 431 of 612 Revised 08/18/20 Page 7 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Should any State or local authorities decline to enter into such arrangements; this refusal will be documented in the Operating Record for the Facility. Agreements with the Spill Contractor, state and local authorities to respond to emergency situations at the Facility will be documented in the Facility's Operating Record. 1.1.5 Implementation of the Plan Pursuant to 40 CFR 264.51(b), the provisions of this plan will be carried out immediately whenever there is a fire, explosion, or any unplanned, sudden or non-sudden release of hazardous waste or hazardous waste constituents, which could threaten human health or the environment as outlined in Table 1.1. Definitions are provided below to clarify "Extent of Hazard." TABLE 1.1 IMPLEMENTATION OF THE CONTINGENCY PLAN EMERGENCY SITUATION FIRE FIRE EXPLOSION SPILL SPILL SPILL AIR EMISSION EXTENT OF HAZARD Contained Uncontained Potential human health, property or environmental hazard Contained and confined Uncontained and unconfined Potential for surface water contamination Off-site human health hazard IMPLEMENTATION OF PLAN No, unless fire is located within a waste management area Yes Yes No, unless there is potential for fire, explosion, or risk to human health or the environment. Yes Yes Yes NOTIFICATION OF SURROUNDING FACILITIES No, unless fire is located within a waste management area Yes Yes No, unless there is potential hazard to human health or the environment Yes Yes Yes Term contained and confined uncontained and unconfined human health, property or environmental Definition Within specific bounds; unable to spread further; under control utilizing facility fire and/or spill control equipment; poses no threat to human health or the environment as assessed by the Emergency Coordinator and the CT DEEP. Out of control; could threaten human health or the environment as assessed by the Emergency Coordinator and the CT DEEP. Based on known composition and estimated quantity of released material, assessed by the Emergency Coordinator and the CT DEEP as potentially hazardous; involving materials NEICVP1493E01 Appendix A Page 432 of 612 Revised 08/18/20 Page 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN hazard potential contamination with high vapor pressure and potentially harmful constituents Release flows toward or into waterway (river, stream); release seeps into ground; area of ground contamination as assessed by the Emergency Coordinator and CT DEEP. References maintained at the facility to aid in the event of an emergency incident include: Condensed Chemical Dictionary Dangerous Properties of Hazardous materials (Sax) Merck Index 1.2 EMERGENCY PROCEDURES 1.2.1 Responsibilities of the Emergency Coordinator 1.2.1.1 Implementation of Emergency Procedures At all times, there will be at least one employee either at the facility or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures. The Emergency Coordinator or designee will be familiar with all aspects of the operational activities on-site, the location and characteristics of managed waste, the location of all records within the facility, the facility layout, and all aspects of this plan. The Emergency Coordinator, as well as alternates, will have the authority to commit the resources necessary to fully implement the Contingency Plan (40 CFR 264.55). A list of Emergency Coordinators by name, address, and phone number is provided in Appendix 2. In the event the facility has a discharge or release of hazardous materials, or a fire or explosion which has the potential for impacting human health or the environment, the first employee detecting such a condition will proceed in accordance with the emergency procedures described below: Notify the Emergency Coordinator (Appendix 2) or designee directly or by telephone, facility page and/or hand-held radio/walkie-talkie; Activate the facility alarms; Until an authorized Emergency Coordinator arrives on the immediate scene of the emergency, the ranking employee present will be responsible for directing site personnel to: Evacuate the area by escorting visitors and contractor personnel to the rally points identified on the facility plan in Appendix 3. The rally points are located in the northeast corner of the property, at the southwest fence line and at the north corner of the property; and Assemble and prepare for receiving directives outside the evacuated area. NEICVP1493E01 Appendix A Page 433 of 612 Revised 08/18/20 Page 9 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Ensure that certain initial response functions are underway by reviewing (and delegating where appropriate) the following tasks listed in the Emergency Response Delegation Checklist (provided in Appendix 5): Determining wind direction; Conducting a personnel head count; and Controlling traffic (i.e. entering trucks). 1.2.1.2 Emergency Investigation and Severity Assessment Procedures Once the Emergency Coordinator arrives on the immediate scene of the emergency, he/she will begin to investigate the emergency and assess the severity. This assessment will determine all future steps required. The following steps will be implemented: 1. Activate Alarms/Communications The Emergency Coordinator or designee will notify the spill response contractor and appropriate Federal, State and local agencies (listed below) that have designated response roles [40 CFR 264.56(a)(2)]. The Emergency Coordinator or designee must ensure that the agencies understand the location and the nature of the emergency. Clean Harbors Environmental Services, Inc.: (203) 734-2582 and (800) 6458265 (24-hour emergency telephone number); State of Connecticut, DEEP, Emergency Response and Spill Prevention Division: 1-860-424-3338; U.S. Coast Guard National Response Center's 24-hour number 1-800-4248802 will be contacted in the event that a reportable quantity release has occurred; Bristol Fire Department 911 or (860) 584-7964 (Fire Headquarters); Bristol Police Department 911 or (860) 584-3011. Whenever there is an imminent or actual emergency, the Emergency Coordinator or designee (which could be the person who detects the incident) will activate the facility alarms and/or communications systems (e.g., public address system (throughout the facility), or radios (carried by employees in plant)) to notify all personnel/visitors on the site to evacuate [40 CFR 264.56(a)(1)]. If evacuation is required, the emergency exit routes from facility (shown on plan included as Appendix 3) will be used. In accordance with Table 1.1, the Emergency Coordinator or designee shall initiate the automated notification system to notify surrounding businesses and residences of any imminent or actual emergency situations at the facility. Clean Harbors maintains an updated database list of surrounding businesses and residences to notify in the event of a qualifying event. The Emergency Coordinator or designee shall initiate the notifications by contacting Rave Mobile Safety, Inc. at https://getrave.com/login/cleanharbors or via telephone at 888-605-7163. All facility employees will be directed to assemble at the designated areas of assembly (i.e. rally points) when an emergency alarm is activated at the facility. The Emergency NEICVP1493E01 Appendix A Page 434 of 612 Revised 08/18/20 Page 10 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Coordinator or designee will account for all employees and visitors. For visitors and contract personnel, the Emergency Coordinator or designee will refer to the visitor log maintained in the Administration Office. 2. Identify Character, Source and Amount of Released Material In the event of a release, fire or explosion, the Emergency Coordinator or designee will immediately identify the character, exact source, volume, and extent of the discharged materials by observation or review of facility records such as the waste characterization information, pre-acceptance analysis, on-site test results, or the manifest and, if necessary, by chemical analysis [40 CFR 264.56(b)]. The Emergency Coordinator or designee shall ensure that all responders wear the appropriate personal protective equipment in accordance with OSHA standards and company policy and procedures. Provided in Appendix 6 is a list of permitted wastes managed at the facility. The Emergency Coordinator or designee shall only allow facility personal to re-enter the facility, if the flow of waste can't be stopped prior to evacuating the facility. The highest level of personal protective equipment maintained at the Facility is OSHA Level B. Therefore, if the Emergency Coordinator or designee determines that OSHA Level A personal protective equipment is necessary, then facility personnel shall not reenter the facility. The Emergency Coordinator or designee will notify the off-site emergency response agency (Clean Harbors Environmental Services, Inc., whose primary Connecticut office/service center is located at Middle Street, Bristol, adjacent to this facility) that OSHA Level A personal protective equipment is needed. 3. Assess Hazards to Human Health or the Environment The Emergency Coordinator or designee will assess the possible hazards to human health or the environment that may result from a release, fire or explosion (e.g., the effects of any toxic, irritating or asphyxiating gases that are generated, hazardous runoff due to water or chemical agents used to control fire, and heat-induced explosions). Pursuant to 40 CFR 264.56(c), the assessment will consider both direct and indirect effects of the release, fire or explosion and shall include an evaluation of the type of incident, materials involved, toxicity, potential for gas evolution, wind direction, and existing and anticipated weather conditions. In making this assessment, the Emergency Coordinator will utilize air-monitoring equipment, where applicable, and facility records on materials being stored or treated including waste characterization data, material safety data sheets and/or analytical testing. If the Emergency Coordinator or designee determines that the facility has had a release, fire or explosion which could threaten human health or the environment, outside the facility, he/she will report his/her finding as follows: a. Evacuation of Local Areas NEICVP1493E01 Appendix A Page 435 of 612 Revised 08/18/20 Page 11 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The Emergency Coordinator or designee shall notify local authorities that the emergency at the facility presents a potential threat to surrounding areas and that an evacuation of local areas may be advisable. The Emergency Coordinator or designee will be prepared to assist authorities in making the final determination relative to evacuation. This assessment shall consider the effects of toxic, irritating or asphyxiating gases, hazardous runoff due to water or chemical agents used to control fire, and so on. The final decision to evacuate the area will be the responsibility of the local agencies [40 CFR Part 264.56(d)(1)]. The Emergency Coordinator or designee is responsible for initiating the automated notification system to notify surrounding businesses and residences of any imminent or actual emergency situations at the facility. Clean Harbors maintains an updated database list of surrounding businesses and residences to notify in the event of a qualifying event. The notifications shall be initiated by contacting Rave Mobile Safety, Inc. at https://getrave.com/login/cleanharbors or via telephone at 888-605-7163. b. Notifications The Emergency Coordinator or designee shall contact the appropriate Federal, State and local agencies and authorities listed below [40 CFR 264.56(d)(2)]: State of Connecticut, DEEP, Emergency Response and Spill Prevention Division: 1-860-424-3338; U.S. Coast Guard National Response Center's 24-hour number 1-800-4248802 will be contacted in the event that a reportable quantity release has occurred; City of Bristol Fire Department: 911 or (860) 584-7964 (Fire Headquarters); City of Bristol Police Department: 911 or (860) 584-3011; City of Bristol Hospital: (860) 585-3000; and City of Bristol Emergency Management Director: (860) 866-7262 Pursuant to 40 CFR 264.56(j), a report shall be submitted to the Commissioner containing the following information: Name, address and telephone number of operator or owner; Name, address and telephone number of the facility; Date, time and type of incident; Name and quantity of material involved; The extent of injuries (if any); An assessment of actual or potential hazards to human health or the environment; and Estimated quantity and disposition of recovered material. For any emergency which could threaten human health or the environment, an Incident Investigation Report (Appendix 4) shall be completed and submitted to the CT DEEP and a copy maintained as part of the CHCI operating record. 4. Preventing Fires, Explosions or Releases from Occurring, Recurring or Spreading During an emergency, the Emergency Coordinator or designee will take all reasonable measures necessary to ensure that fires, explosions and releases do not occur, recur, or if NEICVP1493E01 Appendix A Page 436 of 612 Revised 08/18/20 Page 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN they do occur, spread to waste management areas at the facility. These measures will include, where applicable, stopping processes and operations, collection and containment of released waste, and removing or isolating containers [40 CFR 264.56(e)]. 5. Cessation of Operations In the event of an emergency, the Emergency Coordinator or designee will determine if the site must be shut down until all wastes have been cleaned up and all potential danger of further accidents has been eliminated. Where applicable, the Emergency Coordinator or designee shall, subsequent to shutdown of the operation in response to a discharge, fire or explosion, monitor for leaks, pressure build up, gas generation, or ruptures in valves, pipes or other equipment [40 CFR 264.56(f)]. 6. Treating, Storing and/or Disposing of Recovered Wastes The Emergency Coordinator, in cooperation with the appropriate authorities, shall provide for treatment, storage, and/or disposal of recovered waste, contaminated soil, or other materials resulting from an accident at the facility. This may include, but is not limited to, placing waste into tanks with compatible materials or placing the wastes in containers until final disposition can be determined. Until the facility has determined that the recovered material is not a hazardous waste, the waste will be managed as a hazardous waste in accordance with applicable regulations [40 CFR 264.56(g)]. 7. Decontamination of Affected Areas and Equipment a. Incompatible Materials The Emergency Coordinator or designee shall verify that no waste which may be incompatible with any released material is treated, stored, or disposed of in any area of the facility while cleanup and decontamination procedures are being performed [40 CFR 264.56(h)(1)]. Facility personnel shall conduct an evaluation including, if necessary, review of compatibility charts, compatibility testing and a review of the waste materials' characteristics specified by the Waste Characterization Data, material safety data sheets (SDSs), pre-acceptance testing and/or on-site analytical results. b. Equipment Decontamination Outside responders shall provide for the decontamination of their equipment used in responding to the incident. The Emergency Coordinator or designee shall verify that all emergency equipment, including pumps and temporary storage containers, are cleaned and restored to preaccident conditions before operations resume. A decontamination area shall be set up, at a sufficient distance away from the affected area, to decontaminate equipment by the use of a high-pressure wash, or by another appropriate method such as, but not limited to, a detergent wash. All collected rinsate will be transferred to the on-site wastewater treatment system, or NEICVP1493E01 Appendix A Page 437 of 612 Revised 08/18/20 Page 13 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN shipped to an off-site TSDF if determined to be unmanageable on-site. Solids will be removed, containerized and transferred to an off-site TSDF. Any equipment, which cannot be decontaminated, will be disposed at an authorized TSDF [40 CFR 264.56(h)(2)]. 8. Resuming Operations The Emergency Coordinator or designee shall notify the Commissioner, the Regional Administrator of EPA Region I (only for a release of a reportable quantity of hazardous waste) and the appropriate local authorities that the facility is in compliance with Item 7 above before operations resume in the affected area(s) of the facility [40 CFR 264.56(i)]. 9. Documentation The Emergency Coordinator or designee shall note in the Operating Record the time, date, and details of any incident that requires implementation of the Contingency Plan by completing the Incident Investigation Report (Appendix 4) pursuant to 40 CFR 264.56(j). Within fifteen (15) days after the incident, the Emergency Coordinator or designee will submit a written report of the incident to the Regional Administrator of US EPA Region I as well as to the Commissioner which includes: a. Name, address, and telephone number of the owner or operator, b. Name, address, and telephone number of the facility; c. Date, time, and type of incident (e.g., fire, explosion); d. Name and quantity of material(s) involved; e. The extent of injuries, if any; f. An assessment of actual or potential hazards to human health or the environment, where this is applicable; and g. Estimated quantity and disposition of recovered material that resulted from the incident. Following an emergency which required the implementation of the Contingency Plan, facility personnel shall analyze the cause of the emergency and determine measures to be implemented, including alteration of facility procedures and systems, as appropriate, to prevent re-occurrence of the incident. A report on this analysis/investigation and a description of remedial measures shall be submitted to the Commissioner upon completion 1.2.2 Fire/Explosion Response Procedures In the event of a fire or explosion, all facility employees are trained to respond as outlined in the Training Plan. These personnel will respond to the situation with the necessary equipment to control the fire as quickly as possible. The general procedures for fire control and the duties and actions of fire/ explosion response personnel are described below. On-site fire/ explosion NEICVP1493E01 Appendix A Page 438 of 612 Revised 08/18/20 Page 14 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN response personnel will only attempt to control minor fires, as defined below. Major fires will require assistance from the local fire department. 1.2.2.1 Minor Fires The Contingency Plan shall be implemented in the event of a minor fire in a waste management area. A minor fire is defined as a small, contained fire at the incipient phase which is not likely to spread and is likely to be extinguished using hand-held fire extinguishers. Examples are small fires in the administration offices and which pose no threat to human health or the environment. In the event of a major fire, the procedures for a Major Fire/Explosion shall be implemented. 1.2.2.2 Major Fire/Explosion The following response procedures shall be used in the event of a major fire and/or explosion: The person first noting the incident shall immediately activate the facility alarm and notify the Emergency Coordinator; The facility shall be evacuated of all personnel and visitors; The Emergency Coordinator shall contact the Spill Contractor, the CT DEEP, Emergency Response and Spill Prevention Division and any other appropriate local, state and federal agencies; The Emergency Coordinator or designee shall provide adequate protection to plant emergency personnel based on the severity of the fire, and the materials involved. Facility records regarding tank contents and individual container storage area contents are maintained in the Clean Harbors WIN electronic database. These records can be accessed from any plant computer or remotely via an internet connection and shall be provided to the Emergency Coordinator as necessary. Air monitoring will be performed as necessary to determine the necessary level of personnel protective equipment and to make evacuation decisions (i.e., facility and/or off-site). The Emergency Coordinator or designee shall shutdown operations within the affected area, if it can be done safely, and at the direction of the fire department; The response team from responding local fire departments will control and extinguish the fire; After the fire is out, a damage report shall be prepared and remedial work initiated if required; A fire watch will be established for an eight-hour period following extinguishing of the fire (i.e., a person monitoring the area to look for re-ignition); All used firefighting equipment will be cleaned and any used supplies will be replenished or decontaminated in accordance with Section 1.2.1.2 (Item 7); and The Emergency Coordinator or designee shall ensure that water used to fight the fire is properly contained and disposed. NEICVP1493E01 Appendix A Page 439 of 612 Revised 08/18/20 Page 15 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.2.3 Spill Prevention and Response Procedures In the event of a spill, all facility employees are trained to respond as outlined in the Training Plan. These personnel will respond to the situation with the necessary equipment to control the spill as quickly as possible. The general procedures for spill control and the duties and actions of spill response personnel are described below. Compliance with the Facility's Inspection Plan will provide a daily check on the operating areas, which have the potential for leaks and/or spills. The facility's operating procedures are designed to minimize the potential for spills to occur. However, combinations of equipment failure and human error can lead to spill mishaps. In the event of an accidental discharge or spill of hazardous materials, the immediate objective is to contain the spill to the smallest possible area, recover and package the spilled materials, and to properly decontaminate the area prior to resuming operations. Even though a spill or material release is contained, the Contingency Plan will be implemented if: The spill could result in release of flammable liquids or vapors, which could pose a fire or gas explosion hazard. The spill could cause the release of toxic liquid or fumes. The spill can be contained on-site, but the potential exists for groundwater contamination, which could have an off-site impact. The spill cannot be contained on-site, resulting in off-site contamination including ground or surface water pollution. 1.2.3.1 Minor Leaks and Spills A minor leak or spill is defined as a leak or spill of less than 55 gallons that requires a limited and selective implementation of response procedures in the Contingency Plan appropriate to the nature of the minor leak or spill. These types of leaks or spills do not require support from outside first responders or public agencies. Although minor leaks and spills do require internal mobilization of resources, the nature of responses are typically contained and short-term in duration that do not interrupt normal facility operations. The person detecting the spill shall immediately notify the Emergency Coordinator; The Emergency Coordinator shall contact the CT DEEP Emergency response and Spill Prevention Division and any other appropriate local, state, and federal agencies. The Spill Contractor will be called only if plant personnel are not available to clean up the spill per this section; The affected area shall be isolated by closing off the source of the spill or leak (e.g., by the use of plugs or repositioning if the container), if possible, and by providing barriers to prevent the migration and further surface contamination. If necessary, facility personnel shall seal off floor drains and/or catch basins. NEICVP1493E01 Appendix A Page 440 of 612 Revised 08/18/20 Page 16 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The Emergency Coordinator or designee shall utilize facility records regarding the tank contents (transfer tickets and daily inventories located in the laboratory) and the records regarding individual container storage area contents, as necessary. If necessary, air monitoring will be performed to determine the necessary level of personnel protective equipment. The spilled materials shall be collected by the use of pumps and/or absorbent materials (e.g., clay absorbent or similar product). The affected area shall be cleaned by removing the absorbing agents, waste materials and any contaminated soils; and placing them in the appropriate containers and managing them as hazardous waste on-site or at an off-site facility. All containerized materials will be evaluated for compatibility and stored in the container storage areas containing compatible wastes prior to off-site shipment or on-site treatment. If the leak or spill impacts exposed soil, following the removal of affected soils, samples will be collected at the sides and bottom of the removed area and analyzed for the constituents determined by laboratory personnel using facility records regarding the spilled material. Additional soil will be removed as necessary. All equipment employed during the spill response operations shall be cleaned and decontaminated to its pre-emergency state. All wash waters will be routed to the wastewater treatment facility or properly containerized for management at an off-site facility. All personal protective equipment or clothing, which cannot be decontaminated will be containerized for transport to an off-site facility. All containerized materials will be evaluated for compatibility and stored in a container storage area containing compatible wastes prior to off-site shipment. Upon notification to the CT DEEP, if a written report is requested, within fifteen (15) days of the minor leak or spill, the Emergency Coordinator or designee shall complete an Incident Investigation Report (Appendix 4) which includes: (1) Name, address, and telephone number of the owner or operator, (2) Name, address, and telephone number of the facility; (3) Date, time, and type of incident (e.g., minor leak or spill); (4) Name and quantity of material(s) involved; (5) An assessment of actual or potential hazards to human health or the environment, where this is applicable; and extent of injuries, if any; and (6) Estimated quantity and disposition of recovered material that resulted from the minor incident. The Incident Investigation Report shall be submitted as indicated on the report, and a copy shall be maintained in the facility Operating Record. In addition, CHCI shall electronically record the incident as part of its operating record in the Clean Harbors WINWeb Incident Management module. NEICVP1493E01 Appendix A Page 441 of 612 Revised 08/18/20 Page 17 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.2.3.2 Following a minor leak or spill, facility personnel shall analyze the cause of the emergency and determine measures to be implemented, including alteration of facility procedures and systems, as appropriate, to prevent re-occurrence of the incident. Upon notification to the CT DEEP, if a written report is requested, an after action review of the minor incident shall be submitted to the CT DEEP as part of the requested written report. Major Spills For major spills, the Contingency Plan will be implemented and the spill response procedures discussed below will be utilized. Major spills require extended implementation of response procedures of the Contingency Plan appropriate to the hazardous nature of the major spill. These types of spills may, but do not necessarily, require support from the emergency on-call contractor, outside first responders or public agencies. In addition, because the nature of major spills may require extended support from internal mobilization of personnel and resources, affected waste management areas or entire facility operations may be interrupted and/or temporarily shut-down until emergency conditions are mitigated and controlled. The person detecting the spill shall immediately activate the facility alarm and notify the Emergency Coordinator; The Emergency Coordinator shall contact the CT DEEP Emergency response and Spill Prevention Division and any other appropriate local, state, and federal agencies. The Spill Contractor will be called only if plant personnel are not available to clean up the spill per this section; The facility shall be evacuated of all personnel and visitors; The affected area shall be isolated by closing off the source of the spill or leak (e.g., by the use of plugs or repositioning of the container), if possible, and by providing barriers to prevent the migration and further surface contamination. If necessary, facility personnel shall seal off floor drains and/or catch basins. This isolation will also prevent surface waters from flowing from or into the affected area; Facility records regarding tank contents and individual container storage area contents are maintained in the Clean Harbors WIN Web electronic database. These records can be accessed from any plant computer or remotely via an internet connection and. the Emergency Coordinator or designee shall utilize this information. Air monitoring will be performed as necessary to determine the necessary level of personnel protective equipment and to make evacuation decisions (i.e. facility and/or off-site); The spilled materials shall be collected by the use of pumps and/or absorbent materials (e.g., clay absorbent or similar product); The affected area shall be cleaned by removing the absorbing agents, waste materials and any contaminated soils, placing them in appropriate containers and managing them as hazardous waste on-site or at an off-site facility. All containerized materials NEICVP1493E01 Appendix A Page 442 of 612 Revised 08/18/20 Page 18 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN will be evaluated for compatibility and stored in container storage areas containing compatible wastes prior to off-site shipment or on-site treatment; If soils are affected and removed, samples shall be collected at the sides and bottom of the removed area and analyzed for the constituents determined by laboratory personnel using facility records regarding the spilled material. Additional soil will be removed as necessary. All equipment employed during the spill response operations will be cleaned and decontaminated to its pre-emergency state. All wash water will be routed to the wastewater treatment facility or properly containerized for management at an off-site TSD facility. All personal protective equipment or clothing, which cannot be decontaminated, will be containerized for transport to an off-site TSD facility. All containerized materials will be evaluated for compatibility and stored in a container storage bay containing compatible wastes prior to shipment off-site; and Within fifteen (15) days of the major spill, the Emergency Coordinator or designee shall complete an Incident Investigation Report (Appendix 4), along with a written report of the incident, which includes: (1) Name, address, and telephone number of the owner or operator, (2) Name, address, and telephone number of the facility; (3) Date, time, and type of incident (e.g., type of major spill); (4) Name and quantity of material(s) involved; (5) The extent of injuries, if any; (6) An assessment of actual or potential hazards to human health or the environment, where this is applicable; and (7) Estimated quantity and disposition of recovered material that resulted from the incident. The Incident Investigation Report shall be submitted as indicated on the report, and a copy shall be maintained in the facility Operating Record. In addition, CHCI shall electronically record the incident as part of its operating record in the Clean Harbors WIN Web Incident Management module. Following a major spill, facility personnel shall analyze the cause of the emergency spill incident and determine corrective measures to be implemented, including alteration of facility procedures and systems, as appropriate, to prevent re-occurrence of the incident. A report on this analysis/investigation and a description of corrective measures shall be submitted to the CT DEEP upon completion as an appendix to the Incident Investigation Report. 1.2.3.3 Spill Response Safety Precautions and Countermeasures The Emergency Coordinator will implement the following safety precautions and countermeasures during a spill response: All unnecessary personnel shall be evacuated from the immediate area of the spill; NEICVP1493E01 Appendix A Page 443 of 612 Revised 08/18/20 Page 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Injured personnel shall be removed from the hazardous area (only if they are, or may be, exposed to more hazard); All responders within the contaminated area shall wear proper protective clothing such as boots, gloves, goggles, and respirators; Individuals splashed with spill materials shall flush the exposed area for a minimum of fifteen (15) minutes with large quantities of water from the nearest safety shower/eyewash, outside of the area impacted by the spill. Safety showers and eyewashes are shown on the site plan provided in Appendix 3; and Clothing contaminated by spilled materials shall be immediately removed to minimize contact with the skin. Contaminated clothing will be containerized and managed based on the applicable state and federal waste codes of the spilled materials. 1.2.4 Emergency Response Procedures for Tanks Tanks will be removed from service if the following situations occur: (1) structural failure, or (2) the level of liquid suddenly drops and the drop is not known to be caused by changes in the normal flow into or out of the tank, or (3) the tank contents cause a chemical reaction that could potentially threaten human health or the environment. The following procedures will be implemented: The person detecting the leak shall immediately activate the facility alarm and notify the Emergency Coordinator; The facility shall be evacuated of personnel and visitors (if necessary as determined by the Emergency Coordinator and the local, state and federal agencies); The Emergency Coordinator shall contact the CT DEEP Emergency response and Spill Prevention Division and any other appropriate local, state, and federal agencies. The Spill Contractor will be called only if plant personnel are not available to clean up the spill per this section; The flow into the tank shall be immediately stopped; The Emergency Coordinator shall utilize facility records regarding tank contents and individual container storage area contents that are maintained in the Clean Harbors WIN electronic database. These records can be accessed from any plant computer or remotely via an internet connection. Air monitoring will be performed as necessary to determine the necessary level of the personnel protective equipment and to make evacuation decisions (i.e. facility and/or off-site); The affected tank and surrounding area shall be isolated by closing off the source of the leak, if possible, to prevent the migration and further surface contamination. There are no floor drains in tank secondary containment; The leaked material shall be collected by the use of pumps and/or absorbent materials (e.g., clay absorbents or similar products). The Emergency Coordinator shall NEICVP1493E01 Appendix A Page 444 of 612 Revised 08/18/20 Page 20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN determine, if the tank shall be emptied by placing the contents in another tank or a tanker containing compatible materials; The affected area shall be cleaned by removing the absorbing agents, waste materials and any contaminated soils, placing them in appropriate containers and managing them as hazardous waste on-site or at an off-site facility. All containerized materials will be evaluated for compatibility and stored in container storage areas containing compatible wastes prior to off-site shipment or on-site treatment; If soils are affected and removed, samples shall be collected at the sides and bottom of the removed area and analyzed for the constituents determined by laboratory personnel using facility records regarding the spilled material. Additional soil will be removed as necessary. All equipment employed during the spill response operations will be cleaned and decontaminated to its pre-emergency state. All wash water will be routed to the wastewater treatment facility or properly containerized for management at an off-site TSD facility. All personal protective equipment or clothing, which cannot be decontaminated, will be containerized for transport to an off-site TSD facility. All containerized materials will be evaluated for compatibility and stored in a container storage bay containing compatible wastes prior to shipment off-site; and Within fifteen (15) days of a spill, the Emergency Coordinator or designee shall complete an Incident Investigation Report (Appendix 4), along with a written report of the incident, which includes: (1) Name, address, and telephone number of the owner or operator, (2) Name, address, and telephone number of the facility; (3) Date, time, and type of incident (e.g., fire, explosion); (4) Name and quantity of material(s) involved; (5) The extent of injuries, if any; (6) An assessment of actual or potential hazards to human health or the environment, where this is applicable; and (7) Estimated quantity and disposition of recovered material that resulted from the incident. The Incident Investigation Report shall be submitted as indicated on the report, and a copy shall be maintained in the facility Operating Record. Following a spill, facility personnel shall analyze the cause of the emergency and determine measures to be implemented, including alteration of facility procedures and systems, as appropriate, to prevent re-occurrence of the incident. A report on this analysis/investigation and a description of remedial measures shall be submitted to the Commissioner upon completion that discusses: The cause of the leak shall be investigated; and NEICVP1493E01 Appendix A Page 445 of 612 Revised 08/18/20 Page 21 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The tank shall be either repaired or replaced. An independent professional engineer shall certify all structural repairs in accordance with 40 CFR 264.196(f). All tanks are provided with secondary containment inside the Operations Building. 1.2.5 Emergency Response Procedures for Air Emissions In the event of an accident or emergency which results in the release of significant air emissions (e.g., an air release which results in the release of a reportable quantity), the following procedures shall be followed: The Emergency Coordinator or designee shall be notified; All unnecessary personnel and visitors shall be evacuated from the immediate area. Refer to Section 1.2.1.2 (Item 3), "Assess Hazards to Human Health and the Environment", for the procedures on implementation of the automated notification system; Any evacuation activities initiated for an air emission will be conducted using knowledge of the emission source and wind direction (the primary wind direction is northwest), as determined by wind sock(s), radio communication or other means. The Emergency Coordinator or designee shall be notified; The Emergency Coordinator shall contact the CT DEEP Emergency response and Spill Prevention Division and any other appropriate local, state, and federal agencies; The source and nature (physical and chemical) of the emission shall be identified; All responders shall wear the appropriate personal protective equipment based on the chemicals involved in the incident and potential exposure scenarios; Where possible, the emission shall be terminated by either physical and/or chemical methods (i.e., process shutdown or process modifications); and A report will be made to submitted to the CT DEEP and the US EPA containing the following information: (1) Name, address and telephone number of operator or owner; (2) Name, address and telephone number of the facility; (3) Date, time and type of incident; (4) Name and quantity of material involved; (5) The extent of injuries (if any); (6) An assessment of actual or potential hazards to human health or the environment; and (7) Estimated quantity and disposition of recovered material. NEICVP1493E01 Appendix A Page 446 of 612 Revised 08/18/20 Page 22 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Once the episode is terminated, a complete investigation of the incident will be initiated. Facility personnel shall analyze the cause of the incident and determine the measures to be implemented, including alteration of facility procedures and systems, as appropriate, to prevent re-occurrence of the incident. A report on this analysis/investigation and description of remedial measures shall be submitted to the Commissioner upon completion. 1.2.6 Procedures for Severe Weather Episodes Severe weather episodes could affect facility operations. Conditions relating to wind, various forms of precipitation or electrical storms may require shut-down of certain operations until the weather episode abates and conditions caused by the episode return to normal. Each episode shall be evaluated on a case-by-case basis. If operations must be shut down, the Emergency Coordinator or designee will monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment. 1.3 EMERGENCY EQUIPMENT LIST The facility is equipped with emergency response equipment which, when used in whole or in part, will aid in the control of fires, explosions and the sudden release of hazardous waste into the air, water, or soil. The facility site plan (Appendix 3) shows the locations of emergency equipment at the facility. 1.3.1 Signs Signs are located throughout the facility to control traffic, specify safety requirements and exit routes and describe the locations of the first aid, emergency and safety equipment. All entrances to the facility shall specify the required safety equipment for the facility. Signs restricting access to the facility are posted every fifty (50) feet along the perimeter fencing of the property. 1.3.2 Alarm System The facility maintains an alarm system (a continuous, loud low-pitched buzz) that is used to alert facility personnel of impending emergencies. Once the alarms are activated, they will continue to sound until deactivated by the Emergency Coordinator or alternate. Switches for the alarms are located at the northeast and southwest corners and front foyer of the Operations Building, as well as at the Loading/Unloading Dock, maintenance doorways of the Operations Building and at the north doorway of the Container Storage Building. NEICVP1493E01 Appendix A Page 447 of 612 Revised 08/18/20 Page 23 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.3.3 Public Address System The public address system is activated by the telephone system and has broadcasting capabilities throughout the facility. The public address system can be used as an alternate alarm system if needed. Broadcasting units are located in the Operations Building, Container Storage Building, front office and administrative building. In addition to activating the public address system, the telephones may be used contact the Emergency Coordinator and emergency response agencies. The telephone numbers for the emergency response agencies listed in Section 1.2.1 are posted near the telephone of the Emergency Coordinator and in the Plant Supervisor's office, and shall additionally be posted on the hand-held two-way radios and distributed to all employees. 1.3.4 Fire Control Equipment Fire extinguishers are of the multi-purpose dry chemical type. The locations of these firefighting devices are shown on Facility Site Plan provided in Appendix 3. Personnel will attempt to fight fires only at the incipient phase. Any fire that progresses past this phase will be controlled by the local fire department. Two fire hydrants are located in proximity to the facility on Broderick Road, for fire truck link-up and/or use. The following firefighting equipment is currently available. 20-pound ABC Extinguishers (8). 5-pound ABC Extinguisher in Maintenance Area. Sprinkler system installed within the Operations Building. 250-pound portable Aqueous Film Forming Foam (AFFF) extinguisher inside the Container Storage Building. 1.3.5 Spill Control Equipment Major equipment is maintained at the facility for on-site containment, decontamination and clean-up of hazardous materials in the event of a release or emergency. Spill kits are currently maintained in the emergency response cabinets at the following four locations of the facility: Loading/Unloading Dock; The east entrance of the Operations Building near Container Storage Area H; The west wall of the Operations Building near Container Storage Area H, and The Container Storage Building. Each spill kit contains the following: An empty 85-gallon over-pack drum; Shovel and broom; NEICVP1493E01 Appendix A Page 448 of 612 Revised 08/18/20 Page 24 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN Bag of industrial absorbent; 5-gallon bucket; and Poly plastic sheeting. Additional support equipment available for the facility includes: Industrial Vac-All - wet/dry vacuum; Various pumps, including a portable sump pump; Vacuum truck (or other waste transport/response equipment, available from adjacent Clean Harbors Environmental Services, Inc. service center); and Empty drums (available in various locations of the facility). 1.3.6 Safety and First Aid Equipment The following safety equipment and first aid supplies are available: Two (2) standard industrial first aid kits; Eyewash and emergency shower stations; Two (2) Stretchers Two (2) Fire Blankets 1.3.7 Personal Protective Equipment The following stock of personal protective equipment is maintained at the facility in the contingency cabinet on the north side of the Operations Building. The contingency cabinet includes the following equipment: Cartridge type respirators (4 full face) with inorganic vapor/general use cartridges; Two (3) Self-contained breathing apparatus (SCBA); Six (6) Tyvek and Saranex coveralls; Safety glasses (2 pair); Hard hats (2); Chemical resistant gloves (12 pair); and Miscellaneous items: acid resistant aprons, chemical resistant laboratory coats and flashlights. The equipment listed above will provide OSHA Level B protection. All plant personnel are required to wear head and eye protection whenever they are in the waste management areas of the site. Within the buildings, specific areas are posted with regulations requiring additional protection equipment, such as respirators. Equipment such as earplugs, disposable suits and rubber boots are required on a situational basis (e.g., truck unloading, spill cleanup). NEICVP1493E01 Appendix A Page 449 of 612 Revised 08/18/20 Page 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.3.8 Decontamination Equipment At a minimum, the following equipment is maintained on-site for decontamination purposes at the locations noted below: EQUIPMENT ITEM High-pressure water connection Water-soluble cleaning solution Sponges, brushes, and mops Plastic material for ground covering Plastic/inflatable pools to catch decon water LOCATION BULA Front foyer emergency response cabinet Supply room in Operations Building BULA Each emergency response cabinet 1.3.9 Wind Sock One windsock is located on the roof of the Operations Building over the east side door. Another windsock is located on the roof of the Container Storage Building over the north side door. Employees will observe the windsock(s) for a determination of wind direction, particularly when responding to an airborne release, in order to determine the safest evacuation route and any potential offsite release considerations. 1.3.10 Equipment, Testing, and Maintenance All emergency equipment shall be inspected on at least a monthly basis and after each use, as described in the Inspection Plan, to ensure materials are stocked and in proper working order. It shall be the responsibility of the Emergency Coordinator or designee to periodically test communication and fire control equipment, and ensure that all spill response, personnel protective and first aid equipment is available on-site. Fire extinguishers shall be checked monthly for proper working order. 1.3.11 Emergency Stations There is an emergency station located strategically along the primary evacuation route of the facility. The station is stocked, at a minimum, with the following emergency response equipment: Two (3) Self-contained breathing apparatus; Six (6) Tyvek and Saranex coveralls; Chemical resistant gloves (12 each); and The decontamination equipment listed in Section 1.4.8. Emergency response personnel shall be familiarized with the location of all equipment. NEICVP1493E01 Appendix A Page 450 of 612 Revised 08/18/20 Page 26 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.3.12 Radios Hand-held walkie-talkies are provided to each employee working at the facility, and additional units are in use in the laboratory, front office and other areas of the facility. All walkie-talkies are set to a common frequency so that all employees can hear and be apprised of any emergency information as it may develop. All employees are trained to immediately report any potential emergency information as they may encounter it. Radios may be used as the facility's initial contingency plan implementation means of communication and/or for communication of appropriate response information. 1.3.13 Air Monitoring Instrumentation and Controls Clean Harbors has a fixed toxic gas detector system with detectors located inside and outside the Operations Building. The system is designed to alert personnel of the presence of toxic gases. The gas detection system monitors for Chlorine, Hydrogen Cyanide, Hydrogen Sulfide, Nitrogen Dioxide and Sulfur Dioxide. The network of gas sensors covers the scrubber roof exhaust, lower scrubber area, effluent holding tanks, filter press room and tank storage and reactor areas. In addition, there are detection monitors in the wastewater system scrubber unit that monitor temperature and pH of the scrubber solution, air flow through the scrubber column, and percent loading of the scrubber recirculation pump. The master control of the fixed multi-gas detection system consists of a rack-mounted control unit located in the office of the Facility General Manager. The master control is a visual display of each gas sensor location within the Operations Building. The monitoring system consists of multi-channel control panels with individual displays of visual and audible alarm indicators. Gas detection output is presented as a bar graph reading for each individual gas monitoring channel. CHCI augmented the toxic gas sensors wiring to trigger so that flood mode is activated automatically in the event of certain emergencies. In addition to the existing internal monitoring system, CHCI has established a 24-hour monitoring of the toxic gas detector system through an off-site third party alarm service provider. In the event of a system upset, an alert will be automatically issued to notify facility management that the alarms have been triggered. 1.4 EVACUATION PLAN 1.4.1 Initial Scene Assessment The Emergency Coordinator or designee, upon arriving at the scene of the incident, will assess the situation for imminent hazards to human health or the environment and the need for evacuation of the facility (or notification of local authorities so that they may determine the necessity of evacuating the area outside the facility pursuant to Section 1.2.1.2, Item 3). The general criteria to determine whether evacuation is necessary are summarized below: Unconfined fire and/or explosion; A fire which could cause the release of toxic fumes; NEICVP1493E01 Appendix A Page 451 of 612 Revised 08/18/20 Page 27 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN A fire which could spread and possibly ignite materials at other locations on-site or could cause heat-induced explosions; An imminent danger that an explosion could occur causing a safety hazard; An imminent danger that an explosion could ignite hazardous waste at the facility; Unconfined spills or release of waste materials; An uncontained spill which could result in a release of flammable liquids or vapors, thus causing a fire or gas explosion hazard; and/or An uncontained spill which could cause the release of toxic liquid or fumes. The Emergency Coordinator or designee will utilize air monitoring equipment, as appropriate, and all available facility records on the wastes to aid in the decision for evacuation. 1.4.2 On-site Evacuation Procedures The facility evacuation routes are included in Appendix 3. The Emergency Coordinator or designee will specify an alternate evacuation route if the primary route is blocked or is downwind of hazardous vapors. The Emergency Coordinator or designee will observe one of the windsocks located on the roof of the two facility buildings to evaluate wind directions during the emergency. Personnel will be advised of the alternate route by radio, person-to-person communication, facility paging system or any other means that delivers the message. During the evacuation, the Emergency Coordinator and appointed aides will ensure that all unauthorized personnel are kept from entering the evacuated area. When evacuating the buildings, all employees will proceed upwind to the rally points and muster with their department supervisor. Should release and/or wind direction or employee safe egress factors require it, the facility has two alternate rally points (see Appendix 3). Employees will remain at the rally points as far from the building as possible so as not to interfere with emergency personnel and equipment. The department supervisors will report any unaccountedfor personnel to the Emergency Coordinator or designee. The Emergency Coordinator or designee will account for all personnel to ensure that no one has been left behind. For visitors and contract personnel, the Emergency Coordinator or designee will refer to the visitor log kept in the Administration Office, as well as the one maintained at the facility entrance. The decision to re-enter the facility will be made by the Emergency Coordinator. The Emergency Coordinator or designee will obtain rescue services for injured people where required. 1.5 POWER FAILURE If a power failure occurs at the facility, an emergency system is available to provide lighting for the facility. A power outage would result in a loss of pumping capability and, therefore, all transfers to and from tanks would cease. Valves will be manually closed and the material will remain within the piping, hoses and/or pump cavity. Once the power has been restored, the pumps and lines can be cleared. No adverse impacts are anticipated in this situation. NEICVP1493E01 Appendix A Page 452 of 612 Revised 08/18/20 Page 28 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The facility alarm system, gas detection equipment and wastewater system scrubber are backed up by an uninterruptable power supply and diesel generator which is automatically activated upon loss of external power. This allows for continued operation of these systems during a power failure (see Section 1.3.2). NEICVP1493E01 Appendix A Page 453 of 612 Revised 08/18/20 Page 29 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 1.6 SPECIALTY COMPRESSED GASES Clean Harbors maintains compressed gas cylinders consisting of the following: breathing air, SCBA units, liquid propane gas for fork trucks, and various laboratory gases for on-site activities as noted below in Table 1.2. TABLE 1.2 COMPRESSED GAS CYLINDER INVENTORY Gas Breathing Air SCBA Air Units Liquid Propane Gas (forklifts) Laboratory Gases: Nitrogen Acetylene Hydrogen Argon Oxygen Helium Nitrous Oxide Compressed Air Argon/Methane Location Container Storage Building Operations Building Portable Operations Building Shed Storage Shed Fork trucks Storage Shed Front Lab Storage Shed Maintenance Behind Lab Storage Shed Back Lab Storage Shed Maintenance Storage Shed Back Lab Maintenance Storage Shed Back Lab Storage Shed Behind Lab Storage Shed Back Lab Storage Shed Back Lab Cylinder Size (Cubic Feet) 300 300 300 60 60 33 lb 33 lb 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 Quantity Stored 7 26 3 3 16 Quantity In-Use 2 1 4 3 1 2 2 1 1 1 3 1 3 1 1 1 1 1 1 1 1 1 1 NEICVP1493E01 Appendix A Page 454 of 612 Revised 08/18/20 Page 30 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN The Clean Harbors facility maintains adequate emergency response equipment to respond to potential incidents involving the compressed gases stored/used described above. Among the emergency response equipment maintained for response to the incidents described in this Plan are six (6) SCBA units, forty-five (45) fire extinguishers, a variety of air monitoring equipment, emergency PPE and medical supplies. The SCBA units maintained on-site are tested bi-monthly to ensure their integrity and availability in the event of an emergency. In addition, the facility's air monitoring equipment is calibrated, depending on the particular equipment, on a weekly to a monthly basis. Facility employees perform emergency response drills each quarter, in which not only is equipment availability and performance is tested, but the training of all employees in such scenarios is enhanced. Each compressed gas cylinder in Table 1.2 is individually labeled and the cylinder storage/usage locations are posted with combinations of signs or placards indicating the specific gas types and hazards. All stationary cylinder locations and the entranceways to the locations of the stationary cylinders are posted as to the presence of the cylinders with compressed gas warning signs. Clean Harbors has a compressed gas safety program which includes: inventory identification and tracking, employee hazard training, proper compressed gas storage/usage practices, appropriate safety equipment (e.g., cylinder valve protective caps (both for in-use and stored units), strapping and security), emergency response provisions, and the use of Material Safety Data Sheets (SDSs) and other technical references. NEICVP1493E01 Appendix A Page 455 of 612 Revised 08/18/20 Page 31 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN APPENDIX 1 FACILITY LOCATION and SURROUNDING AREA PLAN NEICVP1493E01 Appendix A Page 456 of 612 Revised 08/03/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN NEICVP1493E01 Appendix A Page 457 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN APPENDIX 2 LIST OF EMERGENCY COORDINATORS NEICVP1493E01 Appendix A Page 458 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN LIST OF EMERGENCY COORDINATORS PRIMARY EMERGENCY COORDINATOR: BRYAN CAMPBELL, General Manager Office: Telephone: 51 Broderick Road Bristol, CT 06010 (860) 583-8917 Ext. 321 Home: 8 Harvest Lane Plainville, CT 06062 Cell phone: (860) 384-2008 Email: campbell.bryan@cleanharbors.com ALTERNATE EMERGENCY COORDINATORS: GEOFFREY BOK, Laboratory Supervisor Office: Telephone: 51 Broderick Road Bristol, CT 06010 (860) 583-8917 Home: 12 South Street Collinsville, CT, 06019 Home Phone: (860) 967-7628 Cell phone: (860) 414-4947 Email: bok.geoffrey@cleanharbors.com JOSE VEGA, Facility Foreman Office: Telephone: 51 Broderick Road Bristol, CT 06010 (860) 583-8917 Home: 75 Lexington Avenue Waterbury, CT 06710 Home Phone: (203) 519-1215 NEICVP1493E01 Appendix A Page 459 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN LIST OF EMERGENCY COORDINATORS (Cont'd) Cell phone: Email: (860) 302-0638 vega.jose2@cleanharbors.com DAVE BERGGREN, Facility Maintenance Manager Office: Telephone: 51 Broderick Road Bristol, CT 06010 (860) 583-8917 Home: 178 West Road Salem, CT 06420 Cell phone: (860) 883-3009 Alternate cell phone: (860) 859-3440 Email: berggren.david@cleanharbors.com NEICVP1493E01 Appendix A Page 460 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN APPENDIX 3 FACILITY SITE PLAN AND EVACUATION ROUTES NEICVP1493E01 Appendix A Page 461 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN NEICVP1493E01 Appendix A Page 462 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 APPENDIX 4 CONTINGENCY PLAN INCIDENT INVESTIGATION REPORT NEICVP1493E01 Appendix A Page 463 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN STATE OF CONNECTICUT DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 79 Elm Street Hartford, Connecticut 06106-5127 Bureau of Waste Management, Oil and Chemical Spill Response Division REPORT OF PETROLEUM OR CHEMICAL PRODUCT DISCHARGE, SPILLAGE OR RELEASE 1. When did the incident occur? Date: ____/____/_______ Time: _________ 2. Where did the incident occur? 3. How did the incident occur? (Describe the cause) 4. Under whose control was the chemical or petroleum product at the time of the incident? Name: Mailing and street address: Town: State: Zip: Telephone: 5. Who is the owner of the property onto which the spill occurred? Is this a corporate property (__) or property owned jointly (__), who represents the owner? Name: Mailing address and street: Town: State: Zip: Telephone: 6. When was the incident verbally reported to the CT DEEP? Date: ____________ Time:___________ DEEP Case No. ________________ NEICVP1493E01 Appendix A Page 464 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 7. Who reported the incident and who were they representing? Name: Mailing address and street: Telephone: 8. What were the chemicals or petroleum products released, spilled or discharged? Give an exact description of each of the materials involved in the incident, including chemical names, percent concentrations, trade names, etc. If the chemicals are Extremely Hazardous substances or CERCLA hazardous substances they must be identified as such and include the reportable quantity (RQ). Please attach a Material Safety Data Sheet (SDS) for each chemical involved. What were quantities of chemicals that were released, spilled or discharged to each environmental medium (air, surface water, soil, groundwater)? (NOTE: Connecticut General Statutes requires the reporting of any amount of any substance or material released to the environment). 9. Did any of chemical(s) travel beyond the property line? (NOTE: materials that enter the ground water are considered to have gone beyond the property line.) 10. What actions were taken to respond to and contain the release, spill or discharge? 11. What actions are being taken to prevent reoccurrence of an incident of this type? 12. Were there any injuries as a result of the incident? If so, list the names of exposed individuals, their addresses, phone numbers and describe their injuries. (Attach additional sheets if necessary) NEICVP1493E01 Appendix A Page 465 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN 13. What is the appropriate advice regarding medical attention necessary for exposed individuals? 14. Are there any known or anticipated health risks, acute or chronic, associated with the release of this chemical or medical advice that should be communicated? 15. Was the incident completely cleaned up by the time this report was submitted? If not, what are the anticipated remedial actions and their duration? 16. CERTIFICATION. I hereby affirm that the foregoing statement is true to the best of my knowledge. Signature Title Date ___________________________________________________________________________Print Name Telephone ___________________________________________________________________________Stree t Address/P.O. Box City/Town State Zip This form may be reproduced or computerized as long as it contains all of the information requested and is on an 8 " x 11" white paper, black type format. For serious incidents the questions may be answered in a narrative format which must include the preparer's affidavit. MAIL TO: State of Connecticut Department of Energy and Environmental Protection Bureau of Waste Management - Oil and Chemical Spill Response Division 79 Elm Street, Hartford, CT 06106-5127 TELEPHONE: Business Calls (860) 424-3024 Emergency 24 hours (860) 424-3338 NEICVP1493E01 Appendix A Page 466 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN APPENDIX 5 EMERGENCY RESPONSE DELEGATION CHECKLIST NEICVP1493E01 Appendix A Page 467 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN CHCI Emergency Response Delegation Checklist (for functions assigned by Emergency Coordinator) Wind direction monitoring: ____________________ Head count: ________________________________ Traffic control: ______________________________ Internal communication: Head count: __________________________ Incident control: _______________________ Employee issues: ______________________ External communication: Within corporation: Response assistance: ______________ Information requests: ______________ Outside corporation: Response agencies: ________________ Media: __________________________ NEICVP1493E01 Appendix A Page 468 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN APPENDIX 6 PERMITTED WASTES AND WASTE MANAGEMENT AREAS NEICVP1493E01 Appendix A Page 469 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN WASTE MANAGEMENT AREAS WASTE MANAGEMENT AREAS DIMENSIONS (1) CONTAINER STORAGE AREAS Area A 20.2-ft. by 24.1-ft. Area B 30-ft. by 63.8-ft. Area C 4.2-ft. by 23.3-ft. Area D 6-ft. by 24.9-ft. Area E 18-ft. by 21.4-ft. Area F 12-ft. by 24.1-ft. Area G Area J Area K Area L 12-ft. by 24.1-ft. 26-ft. by 34-ft. 60-ft. long by 2.6ft. wide by 2-ft. deep 5.5-ft. wide by 16ft. Secondary Containment Capacity PERMITTED CAPACITY 550 gallons 10 percent of the total volume stored in each area or 100 percent of the largest container whichever is greater 5,500 gallons (100 55-gal. drums) 18,480 gallons (336 55-gal. drums) 2,310 gallons (42 55-gal. drums) 2,640 gallons (48 55-gal. drums) 6,600 gallons (120 55-gal. drums) 2,750 gallons (50 55-gal. drums) 2,970 gallons (54 55-gal. drums) 40 cubic yards 5,390 gallons (98 55-gal. drums) 990 gallons (18 55-gal. drums) 30-Day Roll-Off Area 360 cubic yards or 9 40-cubic yard roll-offs (2) LOADING AND UNLOADING AREAS Non-Bulk Containers Bulk Area 56-ft. long by 12-ft. wide 549 gallons 5,060 gallons (92 55-gal. drums) 13,200 gallons WASTE TYPE Acidic or Reactive Wastes Alkaline Wastes Flammables Liquid Wastes Toxic/PCB Wastes Toxic/PCBs Wastes Toxic Wastes Acid Wastes Universal Wastes Acidic Wastes PCBcontaining or Alkaline Wastes Solid Metal Bearing Wastes Approved Wastes NEICVP1493E01 Appendix A Page 470 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN WASTE MANAGEMENT AREAS WASTE MANAGEMENT AREAS DIMENSIONS Secondary Containment Capacity PERMITTED CAPACITY WASTE TYPE (3) STAGING AREAS (As preparation for container storage or offsite shipment) < 5 Days Area M1 Area H (9 areas) 25-ft. long by 13 -in. wide by 1-ft. deep 2,431 gallons On pallets with spill pans 6,820 gallons (124 55-gal. drums) 8,800 gallons (160 55-gal. drums) Acidic Wastes Compatible Wastes (4) MBSTA 30.5-ft. wide by 122.5-ft. deep 23,133 gallons 540 cubic yards per day RCRA Metal Bearing Wastes (5) PAINT PROCESSING 25-ft. long by 13 - in AREA M2 in. wide by 1.25-ft. 2,431 gallons deep 4,950 gallons Latex, Oil Paint Wastes and Alkaline Wastes (6) MISCELLANEOUS PROCESSING AREAS Drum Crusher, Acidic/Alkaline Drum Rinse, Labpack/Depack Containers One 55-gallon drum at a time Approved Wastes (7) TRUCK-to-TRUCK Each bay is 56-ft. TRANSFER AREA by 12-ft. wide (5 (TRAILER STAGING) bays) 4,400 gallons 5,060 gallons per per Vehicle Bay bay Approved Wastes (8) 10-DAY or LESS TRAILER STORAGE AREA (in Trailers with a Total Capacity of 22,000 gallons) Truck Parking Area 1 (4 Trailer Bays) Truck Parking Area 3 (1 Trailer Bay) Each bay is 56-ft. long by 12-ft. wide Each bay is 55-ft. long by 12-ft. wide 4,400 gallons per Vehicle Bay 4,400 gallons 5,060 gallons per bay 5,060 gallons per bay Approved Wastes Approved Wastes NEICVP1493E01 Appendix A Page 471 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Clean Harbors of Connecticut, Inc. Bristol, CT EPA ID No. CTD000604488 CONTINGENCY PLAN WASTE MANAGEMENT AREAS (9) TANK STORAGE AREA TANK NUMBER TANK MATERIAL DIMENSIONS TANK No. 11 TANK No. 14 Fiberglass-lined Steel Tank; Contained within an Epoxy-Coated Concrete Vault. 9-ft. dia. by 8-ft. hgt. Fiberglass-reinforced Plastic with Hetron 197 Resin Liner. 12-ft. dia. by 18-ft. hgt. TANK CAPACITY Minimum Secondary Containment Capacity 4,116 gallons 29,539 gallons 10,836 gallons 29,539 gallons WASTE STREAM Non-RCRA Hazardous Wastes classified as Connecticut Regulated Wastes (CR02-Waste Oil and CR03-Waste Water Soluble Oil) Volatile Organics and/or Oily Hazardous Waste Liquids NEICVP1493E01 Appendix A Page 472 of 612 Revised 08/18/20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT E CLOSURE PLAN (Submitted with the RCRA Part B Permit Application in March 2017) (Updated on February 21, 2019) Clean Harbors of Connecticut, Inc. Closure Plan included in the Permit Application is subject to revisions/updates per Section V, Compliance Schedule of this Permit COMMERCIAL HAZARDOUS WASTE FACILITY PERMIT RENEWAL CLEAN HARBORS OF CONNECTICUT, INC. 51 BRODERICK ROAD BRISTOL, CONNECTICUT 06010 EPA ID No. CT000604488 Permit Number: DEEP/HWM-017-004 NEICVP1493E01 Appendix A Page 473 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SECTION 9.1 9.2 9.3 9.4 9.5 9.6 9.6. a 9.6. b 9.6.c 9.6. d 9.7 9.8 9.9 9.10 9.11 9.12 9.13 9.14 9.15 ATTACHMENT E - CLOSURE PLAN TABLE OF CONTENTS Clean Harbors of Connecticut, Inc. TITLE PAGE NO. Introduction . . . . . . . . . . . . . 1 Environmental Setting . . . . . . . . . . 1 Description of Regulated Units . . . . . . . . . 2 Part A Status . . . . . . . . . . . . . 7 Other Sources of Contamination . . . . . . . . 7 Site Characterization Work Plan . . . . . . . . 9 Constituents of Concern . . . . . . . . . . 9 Identify All Potential Human Exposures Pathways . . . . 19 Identify Presence/Absence of Contamination Requiring Remediation . . . . . . . . . 21 Determine the Extent of Contamination in Structures And Soils Closure Performance Standard . . . . . 23 Closure Performance Standard . . . . . . . . . 25 Removal and Disposal/Decontamination of Waste, Equipment, Structures and Soil . . . . . . . 25 Removal and/or Decontamination of Tank Systems . . . . 27 Post Decontamination Verification Sampling . . . . . 30 Quality Assurance and Quality Control Procedures QA/QC . . 31 Closure Schedule . . . . . . . . . . . 38 Closure Cost Estimates . . . . . . . . . . 38 Certification of Closure . . . . . . . . . . 42 Results of site Characterization Program and Proposed Closure Approach . . . . . . . . . . 45 NEICVP1493E01 Appendix A Page 474 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT P CLOSURE PLAN AND COST ESTIMATE NEICVP1493E01 Appendix A Page 475 of 612 Revised: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Section 9.1 9.2 9.3 9.4 9.5 9.6 9.6.a 9.6.b 9.6.c 9.6.d 9.7 9.8 9.9 9.10 9.11 9.12 9.13 9.14 9.15 Appendix 1 TABLE OF CONTENTS Title Introduction Environmental Setting Description of Regulated Units Part A Status Other Sources of Contamination Site Characterization Work plan Constituents of Concern Identify All Potential Human Exposure Pathways Identify Presence/Absence of Contamination Requiring Remediation Determine the Extent of Contamination in Structures and Soils Closure Performance Standard Removal and Disposal/Decontamination of Waste, Equipment, Structures and Soil Removal and/or Decontamination of Tank systems Post Decontamination Verification Sampling Quality Assurance and Quality Control Procedures (QA/QC) Closure Schedule Financial Assurance/ Closure Cost Estimates Certification of Closure Results of site Characterization Program and Proposed Closure Approach Title CostPro Documentation NEICVP1493E01 Appendix A Page 476 of 612 Revised: 05/01/2011 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.1 Introduction Clean Harbors of Connecticut, Inc. (the facility) operates a commercial hazardous waste storage and treatment facility located at 51 Broderick Road, and having a mailing address at 761 Middle Street in Bristol, Connecticut. This closure plan is being submitted as a document in the Part B renewal submittal. The facility will notify the Commissioner of DEEP in writing at least 45 days prior to the date partial or final closure of the facility is expected to begin. The facility does not expect partial or final closure to commence prior to the year 2050. This closure plan has been prepared to comply with the closure requirements of the Regulations of the Connecticut State Agencies (RCSA), Hazardous Waste Management Regulations Section 22a-449(c). 9.2 Environmental Setting The facility property is approximately 3.5 acres in size and is located in a light industrial park on the eastern edge of Bristol, Connecticut. The facility site is located upon an outwash deposit zone consisting of generally light brown, fine to coarse sand with silt, to a depth of approximately 52 feet. At that depth, a glacial till zone consisting of reddish-brown fine to coarse sand/gravel, with 20-50% silt content, is encountered. Approximately ten feet below the till zone is bedrock. A groundwater aquifer begins at approximately ten-foot depth and continues to bedrock. No drinking water wells are located within a half-mile of the facility. Until 2002, the facility had been required (by its State Discharge Permit) to conduct quarterly/annual sampling and analyses of four groundwater-monitoring wells. This monitoring has been conducted since 1981, and no detectable release(s) attributable to the site's operations have been found. In 1988, in accordance with provisions of the facility's HSWA (Hazardous and Solid Waste Amendments of 1984) Permit, the facility had installed eight additional monitoring wells, from which several years of extensive quarterly monitoring analyses had also been conducted. No detectable groundwater releases or contamination attributable to Clean Harbors were found. In 1998, the U.S. EPA had published a Public Notice of the agency's preliminary determination to issue a No Further Action decision regarding the facility's HSWA status. CTDEEP acknowledged that no further action was required in 2007. CTDEEP also included a requirement in the 2007 Part B permit renewal to initiate a new site investigation under corrective action. CHCI submitted a plan that was approved by CTDEEP and initiated sampling/ analysis over a two phase approach. No actionable levels of any contaminate were found in soil or groundwater. A small stream runs along the southeast line of the facility, 200 feet away from any of the facilities building. The stream is an un-named tributary of the Eight Mile River, a quarter mile away. The stream receives storm water run-off from Clean Harbors. The facility's discharge is permitted and monitored under Connecticut's General Permit for the Discharge of Storm water NEICVP1493E01 1 Appendix A Page 477 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Associated with Industrial Activity. The plant is not located within a 100-year floodplain or a coastal high hazard zone. The southeast comer of the site (where the present stream runs) is located in the 100-year floodplain. The site has never received any past flood damage. All waste management operations performed at the facility are conducted indoors or within a contained area. Any resulting storm waters are collected from outdoor process areas, tested and treated onsite through routine treatment processes. The facility is located at least one mile from any sensitive receptor (i.e., school, hospital). 9.3 Description of Regulated Units Operations at the facility, which are addressed in this closure plan, include the storage of wastes in containers and waste treatment through a variety of processes. Waste treatment at the facility utilizes RCRA exempt wastewater treatment systems, waste Bulk Loading and Unloading Area (BULA), the decanting of liquids, phase layer separation and used electronics recycling. Wastes are stored in management areas as described in Table 9.1. CHCI operates the following ten RCRA hazardous and non-RCRA hazardous waste management areas at the Bristol facility: 1. Rinsate, Crushing and Lab Pack Pour-off Stations: CHCI is authorized to engage in the following waste management activities: 1) the rinsing of empty non-bulk containers at the rinse station; 2) the crushing of non-bulk metal containers in the drum crusher; and 3) the pour-off of lab packs at the lab pack pour-off station. The rinse station is located to the west of the facility's wastewater treatment; the crushing station is located in the western corner of the Operations Building and the lab pack pour-off station is located on the mezzanine above Wastewater Treatment Tank No. 4 inside the Operations Building, as specified on Figure 104-C-01. 2. Container Storage Areas H, K, L, M1 and M2 Container Storage Area H is used for the temporary storage of non-bulk containers prior to treatment; resampling containers; the staging of outbound shipments of permitted wastes; and the disassembly of lab packs for a period not to exceed 5 calendar days from the date the waste was placed in this area. This storage area is located to the east and west of the facility's wastewater treatment system inside the Operations Building. The maximum capacity of nonbulk containers of permitted waste or other material allowed in this area is 160 55-gallon drums or a maximum of 8,800 gallons as identified on Figure 104-C-01. Container Storage Area K is used for the storage (not to exceed 1 year) prior to treating nonbulk containers of permitted wastes classified as acidic and/or preparing such waste for shipment to an off-site facility. This area is located along the eastern wall inside the Operations Building; and is constructed of an epoxy coated concrete floor, incorporating a contained NEICVP1493E01 2 Appendix A Page 478 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut epoxy coated concrete trench approximately 60ft long x 2.6ft wide x 2ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along three sides of it's perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 98 55-gallon drums or a maximum of 5,390 gallons as identified on Figure 104-C-01. Container Storage Area L is used for the storage (not to exceed 1 year) prior to treating nonbulk containers of permitted wastes classified as PCB-containing or alkaline and/or preparing such waste for shipment to an off-site facility. This area is located along the southern wall inside the Operations Building; and is constructed of an epoxy coated concrete floor, incorporating a contained 6-inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 18 55-gallon drums or a maximum of 990 gallons as identified on Figure 104-C-01. Container Storage Area M1 is used for the temporary storage of non-bulk containers of permitted wastes classified as acidic during waste verification activities for a time period not to exceed 5 calendar days from the date such waste arrived at the facility. This area is located northeast of the Loading/Unloading Dock inside the Operations Building; and is constructed of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 25ft long x 13 in wide x 1ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along it's perimeter for secondary containment purposes down between M1 and M2 will be a steel divider. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 90 55-gallon drums or a maximum of 6,820 gallons as identified on Figure 104-C-01. Container Storage Area M2 is used for the temporary storage of non-bulk containers of permitted wastes classified as alkaline during waste verification activities for a time period not to exceed 5 calendar days from the date such waste arrived at the facility. This area is located northeast of the Loading/Unloading Dock inside the Operations Building. This area is constructed of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 25 ft long x 13 in wide x 1.25 ft deep with a steel grate cover and a 6inch high epoxy coated concrete berm along its perimeter for secondary containment purposes down between M1 and M2 will be a steel divider. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 124 55-gallon drums or a maximum of 4,950 gallons as identified on Figure 104-C-01. Both M1 and M2 have only one existing concrete berm. 3. RCRA Waste Storage Tank No.'s 11 and 14 The Waste Storage Tanks are located inside the Operations Building as specified on Figure 104C-01. This area consists of a 65.5 ft long x 55.5 ft wide x 2.75 ft deep vault constructed of concrete sealed with an epoxy coating providing support and secondary containment for tank system No.'s 11 and 14 and the facility's wastewater treatment tanks. The maximum capacity of the Waste Storage Tank 11 is 4,116 gallons and 10,836 gallons for Tank 14. 4. Mix-Tub, Bulk Storage and Transfer Area (MBSTA) NEICVP1493E01 3 Appendix A Page 479 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The MBSTA is used for: 1) the stabilization of RCRA hazardous solid and semi-solid waste by means of mixing such wastes with solidification agents (i.e., lime, cement kiln dust, fly ash, etc.) to render such waste non-RCRA hazardous (passes toxicity levels for leachable metals pursuant to 40 CFR 261.24); 2) the solidification of non-RCRA hazardous solid and semi-solid waste by means of mixing such wastes with solidification agents (i.e., diatomaceous earth, cement kiln dust, ash, etc.) to render such waste more amenable for off-site treatment or disposal; 3) the transferring of RCRA and non-RCRA hazardous waste from the stabilizing tubs into bulk containers (i.e., rolloffs) for storage in this area and/or off-site shipment; 4) the rinsing of bulk or non-bulk containers and associated equipment over the stabilization tub; 5) the consolidation of bulk and non-bulk containers; and 6) the removal of free draining solid resulting from the transportation of the containers prior to stabilization or solidification; 7) the storage of debris and other materials, not destined for on-site treatment, in covered roll-off containers or transportation vessels not to exceed thirty (30) calendar days from the date such waste arrived at the facility prior to shipping to an offsite facility permitted to receive such waste. The MBSTA is located north west of the BULA as specified on Figure 104-C-01 of this permit. This area is constructed of a sloped concrete base pad, a 4.4 cubic yard steel tub, a 2.8 cubic yard steel tub and a contained 4ft x 3ft x 2 ft concrete sump located along the berm of the BULA for secondary containment purposes. The MBSTA has a minimum secondary containment volume of 20,133 gallons plus additional capacity equivalent to the negative containment volume of any device or structure within the area (i.e., containers, equipment, or pallets, etc.) and includes the volume of run-on and/or accumulated precipitation from a 25-year, 24-hour storm event. The maximum capacity of permitted waste or other material allowed in this area is detailed in Section II(A)(5)(c) of the Hazardous Waste Permit. The maximum daily through put of the solidification/stabilization process is 540 cubic yards per day. 5. Container Storage Area C Container Storage Area C is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as flammable prior to treating on-site and/or preparing such waste for shipment to an off-site facility. This area is located along the northern edge of the MBSTA as specified on Figure 104-C-01; and is constructed of a epoxy coated concrete floor, incorporating a 6-inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. The maximum capacity of non-bulk containers of permitted waste or other material allowed in this area is 42 55-gallon drums or a maximum of 2,310 gallons as identified on Figure 104-C-01. 6. BULA The BULA is used for the following waste management activities: 1) the loading/unloading of bulk containers of permitted waste; 2) the temporary storage of bulk containers of wastewater treatment sludge generated on-site; 3) the transfer of waste from bulk and non-bulk containers to other bulk and non-bulk containers; 4) the disassembly and consolidation of lab pack containers which contain spilled or leaking wastes; 5) the solidification of leaking bulk containers; and 6) the loading/unloading of non-bulk containers to the facility's wastewater treatment system or waste storage tanks. The BULA is located adjacent to the Operations Building as specified on Figure 104-C-01. NEICVP1493E01 4 Appendix A Page 480 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut This area is provided with a roof and is constructed of a concave shaped concrete floor, incorporating a 6-inch-high epoxy coated concrete berms along its perimeter (exclusive of vehicle access and egress areas) and a contained epoxy coated concrete trench approximately 10 ft long, 1 ft wide, 15.75 inches deep with a steel grate cover for secondary containment purposes. The area is capable of concurrently staging two transport vehicles for the purposes of loading/unloading waste. The area incorporates three strainers and four tanker discharge pipe receptacles. Three tanker discharge receptacles are piped to the facility's new wastewater treatment system and are dedicated for acidic, high hazardous and alkaline wastes. The fourth tanker discharge receptacle is piped to the facility's older wastewater treatment system and is dedicated for alkaline wastes. The maximum capacity of permitted waste or other material allowed in this area is two 6,600gallon capacity bulk containers or 240 55-gallon drum equivalents of waste or a total of 13,200 gallons of waste. For purposes of determining compliance with the capacity limit, each container or transport vehicle shall be assumed to be full. 7. Container Storage Building-Container Storage Areas A, B, D, E, F, G, J The Permittee is authorized to engage in the following waste management activities in the Container Storage Building: 1) the temporary storage of non-bulk containers of permitted wastes awaiting shipment to an off-site facility or on-site treatment; 2) the loading/unloading of non-bulk containers of universal and solid wastes from the trailers located in front of the Container Storage Building; 3) the temporary storage of frozen bulk containers (i.e. roll-offs); and 4) the storage of non-bulk containers of permitted waste. 5) Resampling containers. The Container Storage Building is located northwest of the Operations Building as specified on Figure 104-C-01 of this permit. The Container Storage Building is divided into seven distinct sections (Areas A, B, D, E, F, G, J) each separated by a 6-inch high epoxy coated concrete berm to facilitate the separated storage of incompatible waste streams. Container Storage Area A is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as acidic or reactive prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area A is located along the eastern wall of the Container Storage Building; and is constructed of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 24 ft long x 1.6 ft wide x 2 ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along three sides of its perimeter for secondary containment purposes. Container Storage Area B is used for the storage (not to exceed 1 year) of non-bulk containers of universal wastes, solid wastes and wastes resulting from the disassembly of such wastes (i.e. cathode ray tubes, plastic, metal) in Rows 8, 9 and 10 prior to treating on-site and/or preparing such waste for shipment to an off-site facility. The storage of non-bulk containers of permitted wastes classified as alkaline is allowed in Rows 1 through 7 prior to treating on-site and/or preparing such waste for shipment to an off-site facility for a period not to exceed one year, Container Storage Area B is located in the northwestern corner of the Container Storage Building; and is constructed of an epoxy coated concrete floor, a 6 inch wide x 6 inch high concrete berm located between rows 7 and 8 and incorporating a contained epoxy coated concrete trench approximately 74.625 ft long x 1.6 ft wide x 2.12 ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along two sides of it's perimeter and the back wall of the Container NEICVP1493E01 5 Appendix A Page 481 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Storage Building for secondary containment purposes. Container Storage Area D is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as toxic or PCB containing prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area D is located northeast of Container Storage Area B in the Container Storage Building; and is constructed of an epoxy coated concrete floor, incorporating a 6-inch high epoxy coated concrete berm along it's perimeter for secondary containment purposes. Container Storage Area E is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as toxic or PCB containing prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area E is located northeast of Container Storage Area A in the Container Storage Building; and is constructed of an epoxy coated concrete floor, incorporating a 6-inch high epoxy coated concrete berm along its perimeter for secondary containment purposes. Container Storage Area F is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as acidic prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area F is located northeast of Container Storage Area D in the Container Storage Building. This area is constructed of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 11.6 ft long x 1.6 ft wide x 2 ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along two sides of its perimeter and the back wall of the Container Storage Building for secondary containment purposes. Container Storage Area G is used for the storage (not to exceed 1 year) of non-bulk containers of permitted wastes classified as acidic prior to treating on-site and/or preparing such waste for shipment to an off-site facility. Container Storage Area G is located northeast of Container Storage Area F in the Container Storage Building. This area is constructed of an epoxy coated concrete floor, incorporating a contained epoxy coated concrete trench approximately 11.6 ft long x 1.6 ft wide x 2.2 ft deep with a steel grate cover and a 6-inch high epoxy coated concrete berm along two sides of its perimeter and the back wall of the Container Storage Building for secondary containment purposes. Container Storage Area J is used for: 1) the disassembly of waste classified as used electronics; 2) the extraction of chlorofluorocarbon (CFC) liquid from appliances containing CFC liquid; and/or 3) the disassembly of waste classified as solid waste (i.e. appliances containing CFC liquid). Container Storage Area J is located in the southeast corner of the Container Storage Building. This area is constructed of an epoxy coated concrete floor and shares the epoxy coated concrete trench with Container Storage Area B for secondary containment. 8. Loading/Unloading Dock The Loading/Unloading Dock is used for the following waste management activities: 1) the transferring of non-bulk containers of permitted waste from one transportation vehicle to another transportation vehicle; 2) the loading of non-bulk containers of permitted waste from the facility onto transportation vehicles for off-site shipment; 3) the unloading of non-bulk containers of NEICVP1493E01 6 Appendix A Page 482 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut permitted waste from transportation vehicles into the facility; and 4) the collection/storage of empty non-bulk containers onto a transport vehicle for off-site shipment. The Loading/Unloading Dock is located outside the Operations Building as specified on Figure 104-C-01 of this permit. The dock is provided with a roof and consists of a slightly concave shaped concrete floor that slopes gradually towards a containment drain located in the center of the dock that drains into the trailer bays for secondary containment purposes. The dock is provided with five trailer bays, each 56 ft long x 12 ft wide. Each bay is separated by an 8-inchhigh x 12" wide concrete berm and is provided with 549 gallons of secondary containment by a 7ft x 3.5ft x 3ft epoxy coated concrete sumps that are provided with steel grates. The Permittee shall not, at any one time, allow more than 5 full-length transportation vehicles (the rack truck or length box van trucks would count as a full transportation vehicle) to be placed in the Loading/Unloading Dock Area or a maximum of 25,300 gallons of waste or other materials is allowed in the Proposed Loading/Unloading at any one time. 9. Truck Parking Areas The Truck Parking Areas are used for the following waste management activities: 1) temporary staging of transportation vehicles containing permitted wastes, which are not destined for the facility, and 2) temporary staging of transportation vehicles containing wastes for off-site shipment. Existing Design: Existing Truck Parking Area #1 consists of four (4) sloped concrete trailer bays and Truck Parking Area #3 consists of one (1) sloped concrete trailer bay. Each bay is 55 feet long and 12 feet wide. The bays in Area #1 are separated by 12-inch-wide concrete berms and each is provided with 4,846 gallons of individual secondary containment by concrete berms and 2-foot-long, 2foot-wide and 4-inch-deep concrete sumps. The bay in Area #3 is provided with 4,728 gallons of secondary containment by concrete berms and a 2-foot-long, 2-foot-wide and 4-inch-deep concrete sump. The Permittee shall not, at any one time, place or allow in excess of five (5) full-length transportation vehicles (a rack truck or half-length box van counts as half a full-length transportation vehicle) or more than 25,300 gallons of permitted waste or other material in the Existing Truck Parking Areas. 10. Former Waste Pile The former waste pile is co-located with the current MBSTA. 9.4 Part A Status When the facility is closed, a comparison of RCRA regulated units with the Part A will be done to ensure all permitted waste types and codes are accounted. 9.5 Other Sources of Contamination There are no other expected sources of contamination, which could potentially impact or interfere with the characterization of releases from regulated units at the site. NEICVP1493E01 7 Appendix A Page 483 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Table 9-1 PERMITTED MANAGEMENT UNITS REQUIRING CLOSURE CONTAINER STORAGE AREA DIMENSION LxW (FT) A B D E F G J BULA and FORMER WASTE PILE C SOLIDIFICATION/ STABILIZATION AREA (MBSTA) 20.2-ft by 24.1-ft 30-ft by 63.8-ft 6 X 24.9 18 X 21.4 12 X 24.1 12 X 24.1 26 x 34 30 x 110 4.2 X 23.3 122.5 x 30.5 H 1068 Ft K L M1 M2 LOADING/ UNLOADING DOCK PARKING AREAS #1 AND #3 TRUCK-TO-TRUCK TRANSFER AREA 7.3 X 60 5.5 X 16 27 X 35 27 X 35 56 X 60 55 x 50 55 X 12 MATERIALS OF CONSTRUCTION MAXIMUM STORAGE CAPACITY (GALLONS) Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete 5,500 18,480 2,640 6,600 2,750 2,970 40 YDS 13,200 Sealed Concrete Concrete 2,310 See Permit Section II(A)(5)(c)(i-iii) Concrete Sealed Concrete Sealed Concrete Sealed Concrete Sealed Concrete Concrete Concrete Concrete 8,800 5,390 990 6,820 4,950 5,060 25,300 25,300 MAJOR CHEMICAL TYPES IN ASSOCIATED WASTE GROUP ACID REACTIVE ALAKLINES PCB's/ TOXIC PCB's/ TOXIC TOXIC ACIDS UNIVERSAL ALL WASTE TYPES FLAMMABLES RCRA METAL BEARING SOLIDS/ NONRCRA SOLIDS ALL WASTE TYPES ACIDS NON-ACIDS/ PCB ACIDS ALKALINE ALL WASTE TYPES ALL WASTE TYPES ALL WASTE TYPES STORAGE and TREATMENT TANKS TANK # 11 14 DIMENSIONS DXH (FT) 9 X 8 CAPACITY 4,116 11 X 16 10,836 WASTE TYPE ALKALINE CYANIDE OR OILY LIQUIDS VOLATILE ORGANICS OR OILY LIQUIDS TANK MATERIAL PLASTI-STEEL FIBERGLASS REINFORCED PLASTIC LINER MATERIAL FIBERGLASS HETRON 197 RESIN NEICVP1493E01 8 Appendix A Page 484 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.6 Site Characterization Work Plan The facility will be closed in a manner that: Minimizes the need for further maintenance; and Controls, minimizes or eliminates, to the extent necessary to protect human health and the environment, post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to the ground or surface waters or to the atmosphere; and Complies with the closure standards set forth in RCSA 22a-449(c)-104. The facility intends to clean close each RCRA permitted hazardous waste unit, including all facility structures and ancillary equipment associated with the hazardous waste unit, hereinafter referred to as the "management unit". To meet the requirements of "clean closure", the facility is proposing to decontaminate by removing all waste and waste residues from each management unit. Following decontamination, each management unit will be inspected. 9.6.a Constituents of Concern Waste Management Areas will be sampled and analyzed before decontamination to identify potential contamination. Table 9-2 summarizes sampling per area. The analytical results from the pre-decontamination sampling events (Appendix IX analytical results), the known chemical constituents managed and the Appendix VIII constituents are the chemical constituents of concern. These chemical constituents of concern are then used to develop the Clean Standard Parameter List (CSPL). Following the identification of each chemical constituent, the CSPL will then be developed utilizing the pre-existing Health-risk based data according to the RFI guidance, the background data developed and/or the Connecticut Action Levels for all exposure pathways. The CSPL will consist of all known chemical constituents managed at the facility and the 40 CFR 264 Appendix IX (Appendix IX) parameters detected during pre-decontamination sampling. In addition, the CSPL may include certain 40 CFR 261 Appendix VIII (Appendix VIII) parameters, which are not included in Appendix IX. The Appendix VIII parameters will be selected based on the potential for their presence in each management unit. The inclusion of specific Appendix VIII parameters will be based on a review of all site-specific records including: Storage records; Waste product records; Materials Safety Data Sheets; Process information; Waste characterization information Monitoring parameters for NPDES- and State-permitted discharge Media Closure Criteria (MCC) for each chemical of concern (COC) can be calculated using the following formula for all media and for all exposure pathways: NEICVP1493E01 9 Appendix A Page 485 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut MCC = Toxicity Constant x BW X AT IR x EF x ED Toxicity Constant = RfD or SF Rfd = Reference dose of potency of toxicity value for noncarcinogens. Units are in milligrams of constituent ingested, inhaled or absorbed into the human body per unit weight, per day (mg/Kg-day). SF = Slope factor or potency or toxicity value for carcinogens. Units are the inverse of the RfD units (1/mg/kg-day) and include the target cancer risk (TR). Target cancer risk = 1e-06, i.e. 1 person in a million will get cancer if exposed to this contaminant for the relevant exposure duration. BW = Average body weight of humans that will be exposed. For example a child in a residential setting is most likely to ingest soil, a 15 kg body weight is typically used in the exposure pathway. It usually takes a lifetime for carcinogens to cause cancer and an adult body weight of 70 kg is used for long-term exposures such as water ingestion. AT = Averaging time is the period over which the exposure is averaged in days. Usually it is the ED x 365 days per year for noncarcinogens and 70 years x 365 days per year for carcinogens. IR = Intake rate of contaminated media (soil, water, air) by humans. Units depend on the media: liters / day for water, mg/ day for soil, m/ day for air. To account for volatile organics in potable water that could be both ingested and inhaled, use the sum of the intake rates of each exposure pathway. IR varies with land use (residential, commercial) EF = Exposure frequency or number of days per year that the population is exposed. For example, 350 days/year is used in a residential setting assuming people take two weeks of vacation. 250 days per year is used in a workplace setting. ED = Exposure duration is the number of years a population is exposed. The clean closure criteria is determined by the health-risk based target standards and will be established for each constituent identified during pre-decontamination for each of the above exposure pathways. The health-risk based target standards to be used are specified in the Interim Final RCRA Facility Investigation (RFI) Guidance, EPA 530/SW-89-031, May 1989, or as revised. The hierarchies of RFI Guidance Standards are: Maximum contaminant Levels (MCLs) Risk-specific Doses (RSDs) Reference Doses (RfDs) Additional health-risk based target standards to be used are the State of Connecticut Action Levels (CTAL's) and statistically verified background levels. CTDEEP's Remediation action levels are listed below in Table 1 (Proposed indoor target air concentrations), Table 2 (Proposed NEICVP1493E01 10 Appendix A Page 486 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ground water volatilization criteria) and Table 3 (Proposed soil vapor volatilization criteria). NEICVP1493E01 11 Appendix A Page 487 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 12 Appendix A Page 488 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 13 Appendix A Page 489 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 14 Appendix A Page 490 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 15 Appendix A Page 491 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 16 Appendix A Page 492 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 17 Appendix A Page 493 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Connecticut Department of Health also has action levels for drinking water in private wells. Those chemicals and action levels are listed below. CHEMICAL Arsenic Barium Benzene Cadmium Carbon tetrachloride Chlordane Chromium Cyanide 1,4-dichlorobenzene 1,2-dichloroethane Dichloromethane 2,4-dichlorophenoxyacetic acid 1,2-dichloropropane 1,1-dichloroethylene Dieldrin Endrin Ethylene dibromide Isopropanol Lead Lindane Manganese Mercury Methoxychlor Methyl tertiary butyl ether Nitrite nitrogen Polychlorinated biphenyls Selenium Silvex T-butyl alcohol (TBA) & other oxygenates Tetrachloroethylene Toluene Total petroleum hydrocarbons Toxaphene 1,1,1-trichloroethane Trichloroethylene 1,2,3-trichloropropane Vinyl chloride CT ACTION 10 2000 1 5 5 0.3 100 200 75 1 5 70 5 7 0.03 2 0.05 2300 15 0.2 500 2 40 70 1000 0.5 50 50 100 5 1000 ** 3 200 5 0.05 2 LEVEL (ug/l) 1) EDB action level for providing bottled water is 0.05 ug/L, the same value as the federal MCL. This MCL is based upon EDB detection limits established in the past. However, the current detection limit is 0.02 ug/L. Detections between 0.02 and 0.05 ug/L should receive NEICVP1493E01 18 Appendix A Page 494 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut follow-up monitoring and can be referred to DPH for site-specific bottled water determination. 2) TPH is a screening level analytical determination that is too non-specific for setting an Action Level. However, detection of TPH at any level is of potential concern and would necessitate further action such as more definitive analytical testing, investigation of sources, and mitigation. 3) This value represents a DPH Comparison Value for determining the need to take action. If the TBA concentration alone, or the sum of all oxygenates in the sample equals 100 ug/L, additional action is recommended (e.g., follow-up monitoring, evaluation of sources and mitigation/treatment options, and possible provision of alternative water supply). List of oxygenates: TBA, MTBE, ethyl-t-butyl ether (ETBE), t-amyl-methyl ether (TAME), diisopropyl ether (DIPE). If the background level of a specific constituent is higher than the corresponding MCL, RSD, RfD, or CTAL, the background level will be used as the clean standard. Otherwise the MCL, RSD, RfD, or CTAL will be utilized, according to the hierarchy listed above. The only exception to this order would be if a standard with a lower hierarchy is more stringent (i.e., a waste constituent has a lower Rfd than it's RSD. In this instance, the Rfd shall be utilized). Background values may be used, but must be statistically verified; furthermore, background values in excess of health-risk based standards cannot be used without substantial verification that the residual constituents are from true background, not waste contamination. Background samples must be taken from areas not affected by waste or chemical processing activities. 9.6.b Identify all Potential Human Exposure Pathways A Health and Safety Plan shall be prepared in conformance with the requirements found in 29 CFR Parts 1910 and 1926, the NIOSH/OSHA/USCG/EPA Guidance Manual for Hazardous Waste Site Activities (NIOSH No. 85-115), and USEPA "Standard Operating Safety Guides". The Health and Safety Plan shall address all hazardous waste activities associated with closure of the management units. More specifically, the plan will, at a minimum: Provide a description of the site, Identify key personnel, Provide an analysis and evaluation of the hazards associated with each activity, Specify initial levels of protection required and action levels for additional protection, Establish training requirements for participation personnel, Include provisions for medical surveillance, Describe air monitoring procedures and requirements, Outline work zones (exclusion, contamination and decontamination zone), and Describe decontamination procedures for personnel, small equipment and heavy machinery. Air monitoring will be part of the closure process. Collected data may serve as input for NEICVP1493E01 19 Appendix A Page 495 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut decisions on personnel protective equipment (PPE), routine work procedures, sampling locations, and emergency events. Characteristics of the specific chemical constituents involved will determine the instrumentation to be used for air monitoring. The preferred method will be to use a portable organic vapor meter (OVM). The OVM includes a photo ionization detector or a flame ionization detector. Colorimetric tubes may be used if a more specific determination of air contaminants is required. Qualitative air analysis may be necessary to determine the exact chemical constituents in the air. Any combination of these air-monitoring techniques may be necessary to ensure that the proper level of personnel protection is used. The closure performance standards identified in this section shall be utilized in the development of the CSPL. A health-risk based target standard for each identified parameter on the CSPL will be developed for all exposure pathways. The pathways to be addressed are: Direct Ingestion - Based on OSHA permissible exposure limits (PEL) and/or Threshold Limit Values (TLV) -Total Mass Analysis for Porous Media -Leachate for Ground Water Analysis Dermal Contact (mass analysis) - Based on OSHA permissible exposure limits (PEL) and/or Threshold Limit Values (TLV) Inhalation Pathway (calculated, see example below) AC = AWC x VC x D -----------------------VA AC= Worst case volatile contaminant air concentration (mg/m) AWC= Average Waste Constituent Concentration (mg/kg) VC= Volume of concrete slab of the WMU (m) D= Density of concrete (kg/m) VA= Volume of standing air over the concrete slab (m) The calculated concentration will then be compared with the applicable permissible Exposure Limits (PELs) or Threshold Limit Values (TVLs) or other health-risk based standards. Predecontamination analysis will be compared with ACGIH or OSHA action level concentrations for ingestion and dermal contact. The health and safety plan is intended to eliminate any ingestion or dermal exposure by using personnel protective equipment (PPE) and requiring sound hygiene practices (IE: washing hands, showering at the end of work shift, etc). A table listing maximum contaminant levels, health and safety risk specific doses will be prepared after constituents of concern are identified from the pre-decontamination sampling. For example, when the sampling data identifies that Acetone is present, the information to be compiled to make up the CSPL will be as follows: NEICVP1493E01 20 Appendix A Page 496 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Chemical Constituent Acetone Analytical Result #mg/l Mass No. * Exposure Pathways Ingestion Dermal Leachate No. # No. ^ Inhalation No. + Footnotes: The chemical constituents to be incorporated are those defined in Section 9.6.a. All analytical results must be reported with the same units as are utilized for the health-risk based target standards. The health-risk based target standards to be incorporated are those No.s, which are contained, in the appropriate clean standard being utilized (background, MCL, RSD, RfD, or CTAL). When utilizing background data as a clean standard the necessary data development information must also be incorporated into the closure plan for review and acceptance by the regulating agency. In addition, the clean closure criteria being utilized must be identified for each No. incorporated into this table. That is, a system of footnotes corresponding to the clean standard (e.g., Background = *, MCL = #, RSD = ^ RfD = + and CTAL = ~) should be established and entered into the table along with value being utilized (see example above) in order to ensure that the clean closure standard given corresponds to the method established. 9.6.c Identify Presence/Absence of Contamination Requiring Remediation In order to determine the presence/extent of contamination at the facility, representative predecontamination samples of the facility management units (structures/equipment) shall be collected and analyzed. The results of the analyses shall be utilized to develop a clean standard parameter list (CSPL). The CSPL will identify the chemical constituents of concern, which must be removed or decontaminated to health-risk based standards. The CSPL will establish the level of decontamination required to clean close the management units. The facility will be required to assess the extent of decontamination for the management units based on the collection of pre-decontamination samples and the subsequent development of a CSPL for the chemical constituents present. These samples shall be taken from the concrete structures, the non-porous (i.e. metal, etc.) structures and the subgrade soils of the management units. When performing the sampling of facility media the collection of representative samples for both the pre-decontamination sampling and decontamination verification sampling must follow specific guidelines. Samples collected for the analysis of metals, inorganics, volatiles and semivolatile constituents in facility media will be collected and analyzed as discrete samples. To determine the number of discrete samples to be taken in each waste management area, divide the square footage of the area by 100 (eg: 1900 ft/100 = 19 samples). If the area is less than 300 ft a minimum of 3 samples will be taken. Each waste management area will be chip sampled for pre-decontamination analysis as summarized in Table 9-5. For post decontamination verification sampling, each waste NEICVP1493E01 21 Appendix A Page 497 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut management unit will be chip sampled. Refer to Table 9-5 for the number of samples collected per management area. When performing tank wipe sampling for the analysis of organic and metal constituents in facility media each sample must be collected and analyzed as a discrete sample. NEICVP1493E01 22 Appendix A Page 498 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Waste Management Unit Area H Area K Area L Area M1 Area M2 TK 11 & 14 BULA and FORMER WASTE PILE Area A Area B Area D Area E Area F Area G Area J Solidification/ Stabilization Area (MBSTA) Area C Loading/ Unloading Dock Truck Parking Area #1 Truck Parking Area #3 Tank containment TK 11 TK 14 Required Dimensions (ft) Irregular 7.3 x 60 5.5 x 16 27 x 35 27 x 35 55 x 63 30 x 110 Sampling Area (ft) 4838 438 88 945 945 3465 3300 Table 9-5 for Waste Predecon concrete samples 49 5 3 10 10 35 33 Management Predecon Soil samples 1 1 1 1 1 1 1 Areas Post decon concrete samples 49 5 3 10 10 35 33 20.2x 24.1 487 5 1 5 30 x 63.8 1914 20 1 20 6 x 24.9 149 3 1 3 18 x 21.4 385 4 1 4 12 x 24.1 289 3 1 3 12 x 24.1 289 3 1 3 26 x 34 884 9 1 9 31 x 120 3720 38 1 38 4.2 x 23.3 98 3 1 56 x 60 3360 34 1 55 x 60 3300 33 1 55 x 12 660 7 1 54 x 64 3456 35 1 9' x 8' NA 3 wipe NA 11' x 16' NA 3 wipe NA 3 34 33 7 35 3 wipe 3 wipe Post decon soil samples 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NA NA Notes: concrete chip samples. Wipe samples are identified as wipe. concrete will be cored drilled to collect sample 9.6.d Determine the Extent of Contamination in Structures and Soils The following identifies the methods to be utilized to obtain the pre-decontamination samples for use in developing the CSPL. Integrity Assessment for Cracks and Gaps in the Facility Structures NEICVP1493E01 23 Appendix A Page 499 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut All management units shall be inspected for cracks and gaps, including discolored, soft or otherwise damaged areas in facility structures, which may have allowed the release or migration of chemical constituents to the subgrade. The facility structures consist of asphalt, concrete floors and other concrete structures, which are in contact with subgrade. When an inspection of facility structures identify that a crack or gap exists, an investigation shall be conducted to determine if the crack or gap extends through the concrete to the subgrade. An accepted method for assessing concrete integrity is by coring through the concrete, incorporating the crack or gap in the core specimen, and examining the core specimen to verify whether or not the concrete has been penetrated. A four-inch core will be drilled through concrete as required. In all cases where a crack or gap extends through the facility structure to the subgrade, a concrete boring will be done and a soil sample shall be required. Soil sampling must then be conducted for the soils underlying the concrete from 0 to 12 inches in depth. If contamination is found, additional sampling will be performed to delineate the zone of contamination. The constituents detected from these sampling events must then be used to develop the CSPL. If sampling of the soils beneath the concrete indicate that chemical constituents have migrated from the management unit to the subgrade soils, and then removal of the contaminated soils will be performed. Based on existing analytical data, it is not expected that contaminated soil will be found. In the event that the subgrade soils are contaminated and cannot be decontaminated or removed to health-risk based standards, then the closure plan will be modified to include specific clean-up measures for these areas, and will be submitted to the for approval. Chip Sampling for Concrete Media Concrete chip samples from concrete facility management unit structures (E.G. the concrete floor) shall be collected from all management units. For each individual management unit (a management area encompassed by secondary containment dikes, walls or berms), a minimum of three pre-decontamination concrete chip samples shall be collected. Concrete chip samples shall be collected from the area(s) of highest suspected contamination (cracks, gaps, visible contaminants, sump or trench within each management unit). The threesample minimum does include the integrity assessment sampling in areas of highest suspected contamination or the collection of a sample from each sump or trench used for secondary containment. All samples collected shall then be analyzed for Appendix IX constituents and the detected chemical constituents must be included on the CSPL. Wipe sampling for Non-porous Media Wipe samples from the non-porous facility waste management unit structures (e.g. metal and other non-porous structures and tanks used for or exposed to chemical management activities) shall be collected from all management units. A minimum of two wipe samples shall be collected from each non-porous structure and three wipe samples (top, middle, bottom) from each tank contained within the management unit at the area of highest suspected contamination (cracks, gaps, visible NEICVP1493E01 24 Appendix A Page 500 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut contaminants). The samples collected shall be analyzed for Appendix IX constituents and the detected chemical constituents must be included in the CSPL. 9.7 Closure Performance Standard The closure plan will comply with the closure performance standard specified in 40 CFR 265.111. 9.8 Removal and Disposal/Decontamination of Waste, Equipment and Structures This section provides a description of the requirements necessary to clean close each management unit at the facility. (Container Storage Areas, MBSTA and Former Waste Pile, BULA, Rolloff storage area, Truck parking areas and loading/unloading dock area) All activity including site work, transportation and disposal is based on costs from third party companies. Procedures to be implemented in the partial and/or final closure of the facility include the following steps: Step 1 Ship offsite all waste stored onsite for disposal at permitted disposal facilities. The maximum waste inventories to be removed from the facility are identified in Table 9-1. Table 9-1 specifies the permitted facility units, which will undergo closure and the maximum waste inventories to be removed from those management units. For closure cost purposes, it is assumed all waste will be transported offsite to a third party vendor for disposal. Containers will be loaded into transportation for shipment offsite. All wastes shipped off-site shall be transported in DOT approved containers by a licensed transporter to an appropriate facility for treatment, storage or disposal. Step 2 Remove any loose dirt or dust using a dry vacuum and/or brooms. All dirt and dust will be placed into containers and disposed as hazardous waste at a permitted offsite facility based on hazardous waste determination. Step 3 Collect concrete chip samples as outlined in Section 9.6 for Appendix IX analysis. Any constituent found from analysis and the applicable ingestion risk-based standard will be added to the table referenced in Section 9.6.a. Step 4 Remove any hazardous constituents that may have contaminated the concrete floor. Each waste management unit identified in Table 9-1 will be decontaminated using an appropriate decontamination solution and any one or a combination of the following methods: Scrubbing and Washing; NEICVP1493E01 25 Appendix A Page 501 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  A High Power Wash; and/or Steam Cleaning. An appropriate decontamination solution will be selected based on the chemical constituents managed in each particular area or based on the chemical constituents detected during the predecontamination sampling events. In some instances more than one decontamination solution and possibly multiple washings may be required to decontaminate a management unit. Step 5 Collect all cleaning water generated in step 4 using a wet vacuum. All cleaning water will be collected and stored in containers, a vacuum truck or tank. Step 6 Steam clean the floor after step 5 using clean water only and collect rinsewater as described in step 5. Step 7 Temporary Storage areas will be used as necessary to store all wastes generated during closure activities. These areas will be located in a contained area. If a contained are is not available, temporary containment will be provided with absorbent material (e.g.: sand bags) Step 8 Decontamination rinsewater will be sampled and analyzed as described in Section 9.6 to determine the concentration of hazardous constituents. If the wastewater treatment system is operable and still maintained under state permit, water maybe treated and discharged to the POTW. If not, water will be shipped offsite for disposal. Step 9 Inspect the area for cracks, gaps or other surface damage that may have allowed the migration of wastes to the subsurface. Step 10 For suspect areas under step 9, a 4" core drill will be used to sample for waste constituents that may have migrated. This will be accomplished by inspecting the core for stains and extent of cracks and gaps. Step 11 For each boring under step 10, a soil sample will be taken and analyzed as described in Section 9.6. Step 12 Post decontamination concrete chip samples will be collected from the management areas as summarized on Table 9.5. Step 13 The samples will be analyzed for constituents of concern to be developed as described in Section 9.6. NEICVP1493E01 26 Appendix A Page 502 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Step 14 Determine if the ingestion risk based standards listed in the table described in step 13 have been met. If so, complete statistical analysis to determine if a sufficient number of samples were collected and analyzed. Step 15 If it is determined under step 14 that additional samples are required, steps 12 and 13 will be repeated. The number of additional samples taken will be based on the statistical calculations. Step 16 If it is determined that ingestion risk based standards cannot be met, a modified closure plan will be submitted to DEEP within 30 days. Step 17 If the ingestion based risk standards are met, the theoretical concentration of volatile and semivolatile constituents will be calculated and compared to the applicable TLV or other health based standards. The samples are collected in step 12. Refer to table 9-2 for sampling information by management area. Step 18 All contaminated PPE and spill control equipment will be collected in containers and disposed offsite. Any and all wastes generated during closure activities, including soils will be sampled and analyzed to determine and ensure their proper management and disposal. All equipment used in the closure activities will either be decontaminated for reuse or collected and disposed in accordance with all applicable regulations. Step 19 When both ingestion and inhalation/health risk based standards are met, the respective management areas will be certified clean closed by a registered professional engineer. 9.9 Removal and/or Decontamination of Tank Systems This section provides a description of the requirements necessary to clean close Tanks 11 & 14. All activity including site work, transportation and disposal is based on costs from third party companies. Procedures to be implemented in the partial and/or final closure of the facility include the following steps: Step 1 Ship offsite all waste stored onsite for disposal at permitted disposal facilities. The maximum waste inventories to be removed from the facility are identified in Table 9-1. Table 9-1 specifies the permitted tanks, which will undergo closure and the maximum waste inventories to be removed from those tanks. At the time of closure, the facility will remove all wastes from each tank. For closure cost NEICVP1493E01 27 Appendix A Page 503 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut purposes, it is assumed all waste will be transported offsite to a third party vendor for disposal. Contents of Tanks 11 and 14 will be pumped into bulk transporters for shipment offsite. Based on historical information, solid residues are not expected in the tanks, but if found will be cleaned with a pressure washer. All decontamination water generated will be appropriately managed offsite. Disposable ancillary equipment (IE: hoses) will be disposed as hazardous waste. Step 2 Remove any loose dirt or dust using a dry vacuum and/or brooms. All dirt and dust will be placed into containers and disposed as hazardous waste at a permitted offsite facility based on hazardous waste determination. Step 3 Inspect the area for cracks, gaps or other surface damage that may have allowed the migration of wastes to the subsurface. Step 4 Collect concrete chip samples from containment and wipe samples from tanks as outlined in Section 9.6 for Appendix IX analysis. Any constituent found from analysis and the applicable ingestion risk-based standard will be added to the table referenced in Section 9.6.a. Step 5 Remove any hazardous constituents that may have contaminated the concrete floor. The tanks will also be cleaned with the same equipment and cleaners. Each waste tank and ancillary equipment (piping, pumps) will be decontaminated using an appropriate decontamination solution and any one or a combination of the following methods: Scrubbing and Washing; A High Power Wash; and/or Steam Cleaning. An appropriate decontamination solution will be selected based on the chemical constituents managed in each tank or based on the chemical constituents detected during the predecontamination sampling events. Examples include: soap/water and/or industrial degreaser. In some instances more than one decontamination solution and possibly multiple washings may be required to decontaminate a management unit. Step 6 Collect all cleaning water generated in step 4 using a wet vacuum. All cleaning water will be collected and stored in containers, a vacuum truck or tank. Step 7 Steam clean the floor and tanks after step 5 using clean water only and collect rinsewater as described in step 5. Step 8 NEICVP1493E01 28 Appendix A Page 504 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Temporary Storage areas will be used as necessary to store all wastes generated during closure activities. These areas will be located in a contained area. If a contained are is not available, temporary containment will be provided with absorbent material (e.g.: sand bags) Step 9 Decontamination rinsewater will be sampled and analyzed as described in Section 9.6 to determine the concentration of hazardous constituents. If the wastewater treatment system is operable and still maintained under state permit, water maybe treated and discharged to the POTW. If not, water will be shipped offsite for disposal. Step 10 For suspect areas under step 9, a 4" core drill will be used to sample for waste constituents that may have migrated. This will be accomplished by inspecting the core for stains and extent of cracks and gaps. Step 11 For each boring under step 10, a soil sample will be taken and analyzed as described in Section 9.6. Step 12 Post decontamination concrete chip samples will be collected from the management areas as described on Table 9.2. Three random wipe samples (top, middle, bottom) will be taken from inside each tank and one outside. Step 13 The samples will be analyzed for constituents of concern to be developed as described in Section 9.6. Step 14 Determine if the ingestion risk based standards listed in the table described in step 13 have been met. If so, complete statistical analysis to determine if a sufficient number of samples were collected and analyzed. Step 15 If it is determined under step 14 that additional samples are required, steps 12 and 13 will be repeated. The number of additional samples taken will be based on the statistical calculations. Step 16 If it is determined that ingestion risk based standards cannot be met, a modified closure plan will be submitted to DEEP within 30 days. Step 17 If the ingestion based risk standards are met, the theoretical concentration of volatile and semivolatile constituents will be calculated and compared to the applicable TLV or other health based standards. Step 18 All contaminated PPE and spill control equipment will be collected in containers and disposed NEICVP1493E01 29 Appendix A Page 505 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut offsite. Step 19 When both ingestion and inhalation/health risk based standards are met, the respective management areas will be certified clean closed by a registered professional engineer. 9.10 Post Decontamination Verification Sampling Verification sampling will be performed per SW-846 according to the following procedure. Each management unit, following decontamination, will require verification sampling. Sample locations for clean closure verification will be defined using a system of systematic random numbers. Concrete samples will be collected at the rate of one sample per one hundred (100) square feet of surface area within each management unit or a minimum of three (3) samples per management unit, which ever is greater. Wipe samples will be collected from all non-porous surfaces within each management unit. Wipe samples shall be collected from each individual regulated tank. A single sample set consisting of one organics sample and one metals sample shall be taken to confirm clean closure for each regulated tank or unit. For additional information on wipe sampling see Section 9.3, QA/QC. In all cases, when an integrity assessment was performed and samples taken from soils underlying facility media (the concrete), verification sampling will be required to confirm that the remaining soils are at or below health-risk based levels. Therefore, adequate sample and location data must be retained when pre-decontamination soil samples are collected and also when verification soil samples are collected for analysis. Table 9-2 identifies, for each management unit, the number of required verification samples. Verification samples include the areas of highest suspected contamination and from those suspect areas identified during the integrity assessment. The verification samples will be submitted for analysis for those constituents contained on the CSPL. The results will be compared to the CSPL closure performance standards to determine the effectiveness of decontamination. The management units will be considered clean closed only when the final verification sample results are at or below the health-risk standards contained on the CSPL. If, based on an evaluation of the analytical data (comparison to CSPL closure performance standards or background) the decontamination efforts are not satisfactory, the decontamination will be repeated until follow-up sampling demonstrates that remaining constituents are at, or below closure performance standards or are consistent with background levels. Any concrete chip sampling areas, which exhibit levels consistent with background and either above or below health-risk levels will be considered representative of ambient background levels. Decontamination efforts will therefore be deemed complete, unless it is determined that background samples have been contaminated by wastes or by waste processing activities. If repetitive decontamination efforts and subsequent sampling procedures fail to provide satisfactory data, then the facility will submit a modified closure plan to the CTDEEP outlining additional specific procedures to be followed for closure of the management units. NEICVP1493E01 30 Appendix A Page 506 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.11Quality Assurance and Quality Control Procedures (QA/QC) 9.11.a Introduction The procedures to be used during the closure activities for sample collection and analyses are described in this section. All of the procedures described within are in accordance with the applicable requirements specified in Test Methods for Evaluation solid Waste Physical/Chemical Methods, SW-846. The Sampling and Analysis Plan includes the following information: Sample collection procedures Sampling preservation and handling procedures Chain of custody control Analytical procedures Field and laboratory quality assurance/ quality control procedures 9.11.b Sample Methods Concrete and wipe samples will be utilized to determine whether the tanks and container storage areas have been decontaminated to the levels specified in this Closure Plan. The procedures to be used to collect rinsate and samples are described below. WIPE SAMPLES Wipe samples will be obtained utilizing cotton gauze and hexane (for organic analysis) and 1:4 nitric acid: water (for metals analysis). For organic analysis, cotton gauze will be saturated with hexane and half the surface (for area of 0.5m) will be wiped repeatedly in a vertical direction. The gauze will then be turned over and the other half of the area will be wiped in a horizontal direction. Moderate pressure will be applied as the sample is taken. Metals sampling will be performed over a 0.25 square meter area with the nitric acid/water, utilizing the same technique as specified above. CONCRETE SAMPLES Concrete samples will be collected using a chisel and hammer. A 3 square inch area will be chiseled to a minimum depth of inch. A 200-gram concrete sample will be obtained and will be placed in the appropriate sample container(s). SOIL SAMPLES Soil samples will be collected using an auger, a scoop or a shovel. Procedures for collecting samples using the above mentioned equipment would be in accordance with SW-846 (1986 edition) in Section 1.2.1.6 (auger) and 1.2.1.7 (SCOOP or shovel). Soil cores may also be obtained (if necessary) by using a hollow-stem auger, split spoon or Shelby tube, or other appropriate device. RINSATE SAMPLES NEICVP1493E01 31 Appendix A Page 507 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Rinsate samples will be collected using a dipper, which consists of a glass or plastic beaker connected to a pole. The dipper will be placed into the rinsate face down. The dipper will then be turned right side up at the desired depth to fill the beaker. The rinsate will be placed in the appropriate sample containers, as specified below. 9.11.c Sample Preservation and Handling SAMPLE PRESERVATION There are several items, which should be taken into consideration when preserving the rinsate. Preservation methods are limited to items such as pH, chemical addition, refrigeration, or freezing. Sample preservation is intended to (1) retard biological action, (2) retard hydrolysis, and (3) reduce absorption effects. Cooling to 4 C will preserve samples. SAMPLE CONTAINERS Sample containers used during the closure procedures will meet the specifications set forth in SW-S46, Test Methods for Evaluation Solid Waste. Table A-l provides a list of the type of bottles to be used for specific materials, preservation methods, holding time and volumes of material required for analysis. Samples will be obtained in the order of the analytical parameter's sensitivity to volatilization. 9.11.d Sample Collection COLLECTION OF VOLATILE ORGANIC SAMPLES CONCRETE AND WIPE SAMPLES Volatile organics will be collected in two 8-ounce wide-mouth glass jars. The jars will be capped with a Teflon-lined cap. The jars will be filled as completely as possible (with concrete samples). RINSATE SAMPLES Volatile organics will be collected in two (2) forty milliliter glass volatile organic analysis vials. The vials will be capped with a Teflon lined silicone septum. Samples will be introduced into the vials by slowly pouring an unfiltered rinsate sample into the vial. This will reduce the agitation, which could potentially drive off the volatile components. Each VOA vial will be filled until there is a positive meniscus over the lip of the vial. The lid will be tightened onto the vial and the vial will be inverted to check for air bubbles. If there are any air bubbles, the vial will be emptied and refilled until there are no air bubbles. This will ensure that the rinsate sample is not losing its volatile components. COLLECTION OF SEMI-VOLATILE ORGANICS CONCRETE AND WIPE SAMPLES Samples will be collected in an 8-ounce wide-mouth jar with a Teflon-lined lid. The samples will be collected in accordance with the methods specified in this plan and will be preserved as specified. RINSATE SAMPLES Rinsate samples collected for semi-volatile analysis will be placed in a 1-liter amber glass bottle. An unfiltered rinsate sample will be slowly poured into the glass bottle. The sample will NEICVP1493E01 32 Appendix A Page 508 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut be capped with a teflon-lined cap and will be cooled to 4 degrees centigrade. All samples will have labels on the containers and will be labeled with indelible ink. COLLECTION OF METAL SAMPLES CONCRETE AND WIPE SAMPLES Samples will be collected in an 8-ounce wide-mouth jar with a Teflon-lined lid. The samples will be collected in accordance with the methods specified in this plan and will be preserved as specified. RINSATE SAMP1ES Metal samples will be collected and filtered at the laboratory or in the field. If filtered in the field, the sample will be filtered through a 0.45-micron membrane filter. After filtration, the sample will be transferred to a 1000 milliliter glass or plastic bottle and will be preserved with nitric acid to a pH of less than 2. If the sample is not field filtered, the sample will be placed in a 1000 milliliter glass or plastic bottle and will not be preserved with acid. COLLECTION OF CYANIDE SAMPLES CONCRETE AND WIPE SAMPLES Samples will be collected in an 8-ounce wide-mouth jar with a Teflon-lined lid. The samples will be collected in accordance with the methods specified in this plan and will be preserved as specified. RINSATE SAMPLE Cyanide samples will be collected in a 500 milliliter plastic bottle with a Teflon lid. The sample will be preserved with Sodium Hydroxide. 9.11.e Chain of Custody Procedures The facility will implement a chain-of-custody program, which will trace the possession and handling of individual samples from the time of sample collection through laboratory analysis. Verifiable sample custody is an integral part of this Closure Plan. Several steps will be taken in the field and laboratory to document and ensure that samples collected in the field have been properly acquired, preserved, and identified. The following sections describe these steps in detail. SAMPLE LABELS Each sample will be labeled and sealed properly immediately after collection. To prevent misidentification of samples, the Facility will place legible labels on each sample container. Labels will be sufficiently durable to remain legible even when wet. The label will include at least the following information: Name of collector Date and time of collection Place of collection Sample identification number Analytical parameters NEICVP1493E01 33 Appendix A Page 509 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut SEALS Seals will be used when utilizing an off-site laboratory to preserve the integrity of the sample from the time it is collected until it is opened in the laboratory. The seal will be attached to the cooler in such a way that it is necessary to break it in order to open the sample container, thus ensuring that the samples have not been disturbed during transportation. FIELD LOGBOOK Key information that will be documented is the data on the sample acquisition. All information pertinent to field observation, surveys, and sampling will be recorded in a bound field book with consecutively numbered pages. Entries in the field book will be written in indelible ink and will include at least the following information: Location of sampling activity Name of sample collector Purpose of sampling Type of waste (e.g. rinsate) Number and approximate volume of samples taken Sampling location point Date and time of collection Sample identification number Field observations Weather conditions The documentation in the field logbook will be sufficient to reconstruct the sampling situation for each sample taken. CHAIN-OF-CUSTODY In addition to the field logbook, each sample sent off-site will be recorded on a chain-ofcustody record. Each sample will have its own sample identification number to ensure that the sample description and location is identifiable. Chain-of-custody forms will become the permanent record of all sample handling and shipment. Samples will be collected in accordance with the sampling procedures specified in this section. If standard sampling procedures are not used, documentation of each deviation will be placed in the file. Upon completion of sampling, the sample will be prepared for shipment in accordance with the applicable sampling instructions including preservation, labeling, and logging. The chain-of-custody record will include the following information: Sample number Signature of collector Date and time of collection Sample type (e.g. rinsate) Number of containers Parameters requested for analysis Signature(s) of person(s) involved in the chain of possession Inclusive dates of possession Preservation techniques NEICVP1493E01 34 Appendix A Page 510 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut The format of this document may vary, but it will include all of the above-listed information. After sample collection, the samples will be stored at the proper temperature in a limited access area until custody is relinquished from the site and formal documentation of the transfer is completed. A field sample custodian will be responsible for sample storage and shipment and for completing the sample accountability records. Upon each transfer of custody, the person involved will verify sample numbers and condition and will document the sample acquisition and transfer. The field sample custodian will properly package the samples, indicate the shipping method and describe the sample accountability record, obtain documentation of the shipment such as a certified mail receipt or bill of lading number, and distribute copies of the sample accountability and sample identification records. On transfer of custody of the samples to the transport agency, the field sample custodian will sign and retain a copy of the chain-of custody and send the original and one copy of the chainof-custody with the samples. Upon arrival at the laboratory, the laboratory sample custodian will sign for custody and return a copy of the completed chain-of-custody to the owner/operator. Samples will be shipped by commercial carrier or will be hand delivered. 9.11.f Sample Analysis Request Sheets Sample analysis request sheets serve as the official communication between the facility and the laboratory for the particular analysis required for each sample. A sample analysis request sheet will accompany the samples on delivery to the laboratory and clearly identify which sample containers have been designated for each requested parameter. The record will include the following information: Name of person receiving the sample Laboratory sample number Date of sample receipt Analyses to be performed All information will be included in the record at the time of receipt. 9.11.g Fields Sampling QA/QC Clean Harbors will implement the appropriate QA/QC procedures to ensure that the samples collected are representative of their media. QA/QC procedures include, but are not limited to, the following items: Equipment blanks; Trip blanks; Field equipment calibration; Changing protective gloves; and Decontaminating sampling equipment. This program is designed to ensure the reliability and validity of field and analytical laboratory NEICVP1493E01 35 Appendix A Page 511 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut data gathered as part of the overall sampling program. A routine collection of two types of Quality Control (QC) blanks will be performed during each sampling event. The two types of QC blanks include trip blanks and equipment blanks. Trip blanks are used to determine if contamination is introduced from the sample containers and equipment blanks are used to determine if contamination is introduced by the sample collection equipment. This is accomplished by the following procedures: Trip Blank - Fill one of each type of sample bottles with deionized water, transport to the site, handle like a sample, and return to the laboratory for analysis. One trip blank will be collected per twenty samples. Equipment Blank - To ensure that the decontamination procedure followed in cleaning the sampling device is effective, an equipment blank is collected from the sampling device. After groundwater and/or dense samples are collected, the device is decontaminated, filled with deionized water and then transferred to the sample bottle(s) and returned to the laboratory for analysis. One equipment blank is collected per twenty samples. The results of the analysis from the blanks are not used to correct the data. If contamination is found in the blanks, the source of the contamination is identified and corrective action, including resampling if necessary may be initiated. FIELD EQUIPMENT CALIBRATION All field equipment that can be calibrated will be calibrated prior to field use. All equipment will be recalibrated in the field before measuring each sample. CHANGING PROTECTIVE GLOVES Protective gloves will be changed in the field, at a minimum, between each sampling location. This is to prevent cross-contaminating samples. DECONTAMINATION OF SAMPLING EQUIPMENT All sampling equipment will be decontaminated between sampling events by using a nonphosphate detergent, tap water rinse, followed by a deionized water rinse or other appropriate method. All water generated during decontamination procedures will be collected (e.g., in drums, vacuum truck, etc.) and will be disposed at an authorized waste management facility. Decontamination will be performed in the designated decontamination areas. 9.11.h Laboratory Procedures The laboratory utilized by the Facility will perform all analyses in accordance with approved procedures using trained personnel, calibrated equipment and appropriate QA/QC procedures. The laboratory will use only EPA-approved test methods including the following documents: "Test Methods for Evaluating Solid Waste, SW-846, United States Environmental Protection Agency, 2007 or most recent available." NEICVP1493E01 36 Appendix A Page 512 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut  "Standard Methods for the Examination of Water and Wastewater, 21st edition" "Guidelines Establishing Test Procedures for the Analysis of Pollutants, Federal Register, November 19, 2002, Pages 69951-69972." "Methods for Chemical Analysis of Water and Wastes, EPA-600479020, 1983" The laboratory will follow strict QA/OC standards, including laboratory blanks, duplicates, and spiked samples for calibrating and maintaining analytical integrity. Data from the QC samples (e.g., blanks, spiked samples) are used by the laboratory as a measure of performance or as an indicator of a potential source of cross-contamination but are not used to alter or correct analytical data. LABORATORY LOGBOOK The laboratory chosen by the Facility will maintain either a handwritten, or computerized logbook for all samples received during the closure activities. The logbook will specify all sample preparation techniques and instrumental methods. Experimental conditions, such as, but not limited to, temperatures, reaction time and instrument settings will be recorded. The results of the analysis of all quality control samples will be identified. Additionally, the laboratory logbook will include the time, date and name of the person performing each processing step for each sample. Analytical Parameter Volatile OrganicsConcrete and Wipe Samples Rinsate Samples Semi-Volatile OrganicsConcrete and wipe samples Rinsate Samples Metals analysis Concrete and wipe samples Rinsate Samples Cyanide analysis Concrete and wipe samples Rinsate Samples Preservative TABLE 9-7 SAMPLE PRESERVATION Bottle Type Holding Time Cool to 4C Cool to 4C Cool to 4C Wide Mouth Glass Jar with Teflon lined cap Glass Septa Vial Wide Mouth Glass Jar with Teflon lined cap 14 days 14 days 14 days Cool to 4C Cool to 4C Cool to 4C HNO3 (if field filter) Cool to 4C Cool to 4C Amber Glass Bottle Wide Mouth Glass Jar with Teflon lined cap Glass or plastic bottle Wide Mouth Glass Jar with Teflon lined cap Plastic Bottle 14 days 6 months 6 months 6 months 6 months Bottle Size 8 oz 40 ml 8 oz 1 L 8 oz 1000 ml 8 oz 500 ml NEICVP1493E01 37 Appendix A Page 513 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.12 Closure Schedule The closure schedule for the management units is given below. CLOSURE ACTIVITY Notify DEEP in writing of anticipated closure. Receive final volume of waste. Management unit closure begins utilizing DEEP approved closure plan. Removal of waste from management unit. Integrity assessment conducted, all damaged areas identified. All samples collected and analyzed. Remove residual waste from management units. Decontaminate management units. Collect and analyze all verification samples. Notify DEEP of changes in plan Completion of closure activities. DAY 0 0 30 55 90 100 160 160 180 Certify and submit report of closure activities 60 days following completion of closure activities. Closure will be completed within 180 days of commencement of closure activities and the closure certification and report will be submitted to the Commissioner of DEEP within 60 day of completion of the closure activities. This schedule does not account for any delays, which may be caused by force majeure, including without limitations, fires, floods, riots, or strikes. If any of the aforementioned circumstances occur, the facility will submit a written request to the Commissioner of DEEP to extend the time allowed for closure. 9.13 Closure Cost Estimates The closure cost estimate has been prepared using CostPro 6.0 in 2011 dollars. The software output can be found in Appendix 1. Third party transportation and disposal costs were used for disposal of the electronic dismantling inventory as CostPro does not have a category for this waste type. A post closure cost estimate has not been included. Clean Harbors will "clean close" the facility eliminating the need for post closure action. A summary of the units to be closed or decontaminated and the associated cost is presented below: NEICVP1493E01 38 Appendix A Page 514 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Closure of Waste Management Units Container Management Areas (includes A, B, D, E, F, G, J, H, C, K, L, M1, M2, Spill Control, MBSTA and Former Waste Pile, BULA, Truck Parking Areas #1, 2 and 3 Tank 11 (includes containment decon, sampling and analytical costs for both tanks) Tank 14 Electronic Inventory Disposal Total (2011 dollars) Dollars $3,416,699 $142,110 $37,384 $8,202 $3,604,395 NOTE: All cents rounded to the nearest dollar. 9.13.a Transportation and Disposal Unit Prices The following treatment/disposal facilities and costs were used to calculate the closure cost estimate for electronics. These figures represent third party transportation and disposal costs as of January 2011. Item Computers & monitors TV's Hard drive Circuit boards Printers & keyboards Copper wire Lithium batteries Alkaline batteries Ni-cad batteries Nickel metal hydride Lead acid batteries Total Amount 111 skids 70 skids 1 skid 3 skids 58 skids 3 skids 2.5 gal 2.5 gal 2.5 gal 2.5 gal 30 gal Outlet Supreme Recycling Supreme Recycling Supreme Recycling United Recycling Metals Management Liberty Recycling Toxco Toxco Toxco Toxco Toxco T&D Costs/ unit $.07/lb $.07/lb $.07/lb Credit No charge Credit $150 $150 $150 $150 $150 Notes: A skid of electronics weighs an average 585 #'s. Batteries average 12 lbs/gal. Solidification/Stabilization material averages 2000 lb/yd3 NEICVP1493E01 39 Appendix A Page 515 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.13.b Inventory Management Assumptions Clean Harbors makes the following assumptions concerning the disposal of its hazardous waste inventory: (a). The amount of hazardous waste on-site at the time of closure will be equal to the maximum permitted capacity of each waste management unit. (b). The Loading Area will have all materials moved to one of the permitted areas. (c). Based on historical operating data, each tank can be clean of waste and residue without entering the tank. (d). A local third party contractor will operate the Clean Harbors facility in order to perform closure. (e). Truck-to-Truck materials have been shipped offsite to the destination facilities. (f). 1 yd = 2000 lbs. (g). 90% of drum inventory is liquid and 10% is solid based on historical operating data. 9.13.c Waste Management Unit Closure Assumptions (a). All drummed materials will have been previously removed to an approve disposal facility. (b). It is assumed that one crack per WMU will require coring to identify the vertical extent. (c). It is assumed that a soil sample will be collected beneath each concrete core for analysis. (d). Appendix IX parameters will be analyzed unless a specific COC list is established. (e). PPE and polyethylene will be consolidated in the bulk solids to be sent offsite for landfill. 9.13.d Decontamination Assumptions Clean Harbors makes the following assumptions concerning the decontamination of equipment: (a). The forklifts will be cleaned using detergents and/or solvents. (b). 500 gallons of contaminated rinseate will be generated during decontamination activities. This liquid will be bulked and sent off-site for disposal at Dupont. (c). One (1) 55-gallon drums of contaminated debris (e.g., PPE, plastic sheeting, etc.) will be generated during equipment decontamination. Each drum will weigh 400 pounds. (d). The decontaminated equipment will be sold and/or sent to a scrap metal dealer. No cost benefits from this will be considered. Container Storage Area J (Inventory Only. All other costs included in CostPro) TASK Characterize, Load, Transport & Dispose Electronic Waste Computers/monitors -64935 lbs TV's- 40950 lbs Hard drive- 585 lbs Circuit boards - 1755 lbs Printers &keyboards - 33930 lbs Copper wire - 1755 lbs SOURCE FOR QUOTE Supreme Recycling Supreme Recycling Supreme Recycling United Recycling Metal Management Liberty Recycling QUOTE $.07/lb $.07/lb $.07/lb Credit No charge Credit TOTAL COST $4,545 $2,866 $41 NA NA NA NEICVP1493E01 40 Appendix A Page 516 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Lithium batteries - 2.5 gal Alkaline batteries - 2.5 gal Ni-cad batteries - 2.5 gal Nickel metal hydride - 2.5 gal Lead acid batteries - 30 gal SUBTOTAL Toxco Toxco Toxco Toxco Toxco $150 min $150 min $150 min $150 min $150 min $150 $150 $150 $150 $150 $8,202 NEICVP1493E01 41 Appendix A Page 517 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.14 Certification of Closure Upon completion of closure of each management unit or the facility, Clean Harbors will submit a certification by both the facility owner/operator and an independent registered professional engineer to the Commissioner of DEEP that the facility has been closed in accordance with the specifications in the approved closure plan. A member of the certifying organization must be present during all major closure activities to ensure that the approved closure plan is executed. The certification and report will be submitted by registered mail to the Commissioner of the DEEP by both the facility and the independent registered Professional Engineer within 60 days of completion of the closure activities. The report will include a summary of the closure activities performed, based upon the Professional Engineer observing the major closure activities, and include the following: All analytical results; including Appendix IX test results, all other pertinent analytical data plus the final confirmation sampling results; Photographic records of the closure documenting each construction step of the closure process; A copy of the contractor's daily log; A list of any departures from the approved closure plan with rationales in accordance with 40 CFR 264.112(c), and Results of the visual inspection of the management units. The following certifications shall be submitted to the Commissioner of DEEP upon completion of closure: NEICVP1493E01 42 Appendix A Page 518 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut OWNER OR OPERATOR CLOSURE CERTIFICATION The undersigned, (Name of Owner or Operator), a (1) Corporation, incorporated under the laws in the State of ____________________ licensed to do business in ____________________ , or (2) (Partnership, Individual, Municipality or Other Entity), with its principal place of business at (Address), which formerly owned or operated a hazardous waste (Description of Hazardous Waste Activity) (hereinafter Facility) known as (Name of Hazardous Waste Facility) and located at (Location) in __________County, (State), has completed and permanently ceased the activity operation of the facility and has fully implemented all measures relating to the closure of the facility as set forth in the Closure Plan approved by the Connecticut Department of Energy and Environmental Protection (DEEP) for said facility. NOW, THEREFORE, I (we) (Name of Owner or Operator) hereby swear and affirm that the abovenamed hazardous waste facility has been closed in accordance with the facility's Closure Plan approved in writing by the Commissioner of DEEP on 20__, that all measures relating to the closure of the facility required by the Closure Plan and the rules and regulations of (regulatory Citation) have been fully implemented, and that to the best of my (our) knowledge, no violations continue to exist that may have arisen prior to closure. __________________ (Signature) __________________ (Title) _________________ (Address) Taken, sworn and subscribed before me, this _____________day of_____________ A.D. 20_______________ _____________ (Notary) NEICVP1493E01 43 Appendix A Page 519 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut INDEPENDENT REGISTERED PROFESSIONAL ENGINEER CLOSURE CERTIFICATION I, (Name), a Professional Engineer registered pursuant to the Professional Engineers Registration Law, ___________, hereby certify that I have reviewed the Closure Plan for the (Type of Facility) at (Name of Hazardous Waste Facility) ("facility"), located at (Location) that I am familiar with the rules and regulations of (regulatory citation) pertaining to closure of such facility, and that I personally have made visual inspection(s) of the aforementioned facility, and that the closure of the aforementioned facility has been performed in full and complete accordance with the facility's closure plan approved in writing by the Commissioner of the DEEP on ___________ 20___________, and the rules and regulation of (regulatory citation). _______________________________ _ (Signature) ______________________________________ (Date) ______________________________________ (Professional Engineer License Number) ______________________________________ (Business Address) ______________________________________ (Telephone Number) (Seal) NEICVP1493E01 44 Appendix A Page 520 of 612 Revised: 02/12/2019 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 9.15 Results of Site Characterization Program and Proposed Closure Approach Per the Connecticut DEEP "RCRA Closure Plan Guidance" dated November 1993, once the site characterization work plan has been implemented the results will be presented in Closure Plan Part 2. Using these results, a proposal should be made in Closure Plan Part 2 to close the regulated units "clean" or close it as a landfill. In order to establish facility specific closure performance standards, it is necessary to determine the chemical constituents of concern, identify the exposure pathways to be addressed, their health-risk based target standards for clean closure and to assess the proper utilization of the predecontamination sample analytical results. Evaluation of facility specific information in regard to the above provides the data necessary for use in assessing compliance with the closure performance standards. Clean Harbors intends to clean close the facility. 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Bristol, Connecticut APPENDIX E-1 DRAFT RCRA CLOSURE PLAN GUIDANCE FOR TREATMENT, STORAGE AND DISPOSAL FACILITIES: CONTAINER STORAGE AREAS AND TANK SYSTEMS NEICVP1493E01 Appendix A Page 574 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut STATE OF CONNECTICUT BUREAU OF WASTE MANAGEMENT ENGINEERING & ENFORCEMENT DIVISION 79 ELM STREET, HARTFORD CT 06106-5127 TEL. (860) 424-3366 TOLL-FREE (RCRA Questions Only): 1-888-424-4193 www.dep.state.ct.us/ DRAFT RCRA CLOSURE PLAN GUIDANCE FOR TREATMENT, STORAGE AND DISPOSAL FACILITIES CONTAINER STORAGE AREAS AND TANK SYSTEMS PREFACE This document was developed by the Department of Environmental Protection to guide all persons involved in preparing and reviewing closure plans for RCRA facilities used to store hazardous waste in containers and tanks for greater than 90 days. These facilities are subject to the provisions of the Connecticut Hazardous Waste Management Regulations and 40 CFR Part 265. This guidance is primarily for clean closures. If during the site characterization process it becomes necessary (for reasons discussed in the guidance) to close the regulated unit as a RCRA landfill under 40 CFR 265 Subpart N, additional regulations and guidance may apply. Facilities which have operated under interim status and are now closing, and facilities changing from interim status to generator status, i.e. less-than-90-day storage, will be the primary users of this guidance. Although not subject to the same closure requirements, RCRA generators could also use this document when closing. This guidance can be used by the facility to prepare a first-time closure plan submittal, or will be used as a generic Notice of Deficiency (NOD) by the Department of Environmental Protection (DEP) in lieu of a detailed site-specific NOD. It is intended to insure a measure of consistency for all RCRA closure plans. Ultimately it will minimize the number of DEP-comment/facility-response cycles, thereby reducing the review and approval time. DEP reserves the right to change the contents of this guidance. Closure plans prepared using this guidance may still need to be modified. The DEP welcomes input and/or constructive criticism regarding this document. If you have any questions, comments or suggested changes that will improve this guidance you may contact the DEP staff person currently assigned to your site. NEICVP1493E01 Appendix A Page 575 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE OF CONTENTS PREFACE.....................................................................................................................................1 INTRODUCTION........................................................................................................................4 Figure 1: Recommended Review and Approval Process ..........................................5 CLOSURE PLAN PART 1: FACILITY INFORMATION AND SITE CHARACTERIZATION WORK PLAN...................................................................................7 I. FACILITY INFORMATION ............................................................................................7 A. Introduction..................................................................................................................7 C. Environmental Setting.................................................................................................8 D. Description of regulated units.....................................................................................8 E. Part A Status ................................................................................................................9 F. Other Sources of Contamination................................................................................9 II. SITE CHARACTERIZATION WORK PLAN .................................................................9 A. Constituents of Concern ............................................................................................10 B. Identify All Potential Human Exposure Pathways.................................................12 C. Identify the Presence/Absence of Contamination Requiring Remediation..........13 Figure 2: Determination of the Presence/Absence of Contamination Requiring Remediation ..................................................................................................................15 D. Determine the Extent of Contamination in Structures and Soils..........................16 Figure 3: Illustration of an Idealized Contaminant Migration Pattern in the Unsaturated Zone .........................................................................................................17 CLOSURE PLAN PART 2: RESULTS OF SITE CHARACTERIZATION PROGRAM AND PROPOSED CLOSURE APPROACH ..........................................................................20 I. SITE CHARACTERIZATION SAMPLING AND ANALYSIS RESULTS........................................20 II. PROPOSED CLOSURE APPROACH.......................................................................................21 III. DEPARTURES FROM SITE CHARACTERIZATION WORK PLAN ............................................21 CLOSURE PLAN PART 3: REMEDIATION, VERIFICATION, QA/QC, CERTIFICATION .....................................................................................................................22 I. CLOSURE PERFORMANCE STANDARD ...............................................................................22 II. REMOVAL AND DISPOSAL/DECONTAMINATION OF WASTE, EQUIPMENT, STRUCTURES AND SOIL 22 III. REMOVAL AND DECONTAMINATION OF TANK SYSTEMS...................................................24 IV. QUALITY ASSURANCE AND QUALITY CONTROL PROCEDURES (QA/QC)..........................25 V. CLOSURE SCHEDULE.........................................................................................................25 VI. FINANCIAL ASSURANCE/CLOSURE COST ESTIMATES........................................................25 VII. CERTIFICATION OF CLOSURE ............................................................................................26 VIII.APPENDICES......................................................................................................................26 ATTACHMENT A: WIPE SAMPLING PROCEDURE.....................................................27 ATTACHMENT B: CALCULATION OF WORST-CASE AIR CONCENTRATIONS.28 NEICVP1493E01 Appendix A Page 576 of 612 2 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT C: SAMPLING AND ANALYSIS GUIDANCE ....................................29 TABLE 1-1: ANALYSIS OF WASTE FOR APPENDIX IX PARAMETERS ......................................29 TABLE 1-2: ANALYSIS OF SECONDARY CONTAINMENT STRUCTURES FOR APPENDIX IX CONSTITUENTS .........................................................................................................................30 TABLE 1-3: DEVELOPMENT OF BACKGROUND VALUES FOR MEDIA CLOSURE CRITERIA .....31 TABLE 1-4: SITE CHARACTERIZATION - DETERMINATION OF LATERAL EXTENT OF CONTAMINATION ......................................................................................................................32 TABLE 1-5: SITE CHARACTERIZATION - DETERMINATION OF VERTICAL EXTENT OF CONTAMINATION ......................................................................................................................33 TABLE 1-6: HAZARDOUS WASTE DETERMINATION - EQUIPMENT, STRUCTURES, SOILS DISPOSED OF OFFSITE ...............................................................................................................34 TABLE 1-7: POST-DECONTAMINATION SAMPLING OF SOILS.................................................35 TABLE 1-8: POST-DECONTAMINATION SAMPLING OF TANKS AND SECONDARY CONTAINMENT STRUCTURES WHICH ARE CONSTRUCTED OF POROUS MATERIAL .............................................36 TABLE 1-9: POST-DECONTAMINATION SAMPLING OF TANKS AND SECONDARY CONTAINMENT STRUCTURES WHICH ARE CONSTRUCTED OF NON-POROUS MATERIAL .....................................37 ATTACHMENT D: GUIDANCE ON DEVELOPING MEDIA CLOSURE CRITERIA38 I. GUIDANCE ON DEVELOPING MCCS BASED ON BACKGROUND SAMPLES ..........................38 II. EXPRESSION OF MEDIA CLOSURE CRITERIA AND RELATED ANALYTICAL DATA UNITS........38 NEICVP1493E01 Appendix A Page 577 of 612 3 Clean Harbors Environmental Services, Inc. Bristol, Connecticut INTRODUCTION This guidance document recommends that the nature and extent of contamination be determined and included as part of the closure plan, prior to approval. In doing so, the remedial measures will be based on an accurate assessment of the problem and post-approval modifications due to "unexpected events" will be minimized. CTDEP has developed a closure process designed to achieve this result. The following Figure 1 presents a recommended closure process which describes performing site characterization (nature and extent of contamination) prior to closure plan approval. In this process, the closure plan is submitted in three parts; CTDEP reviews and comments on the first two parts (if necessary) and then approves, disapproves, or modifies the 3-part closure plan. This 3-part process is not required by regulation but we have found that closure plans prepared in this way reach final approval in a more timely manner. In addition, because the site is more accurately characterized, post-approval "unexpected events" are minimized, thus avoiding a prolonged closure plan modification process. Closure Plan Part 1 is a work plan to characterize the nature and extent of any hazardous constituents released by the regulated unit. In addition, a general background of the facility and its environmental setting is provided. CTDEP will review Part 1 and will provide the facility with further site-specific guidance if needed. Once Part 1 is completed the work plan can be implemented. Closure Plan Part 2 is then submitted to summarize the site characterization results. Part 2 will also contain a proposal to close the unit "clean" or as a "landfill" based on the site characterization results. CTDEP again reviews this document and provides input prior to receiving Closure Plan Part 3. If clean closure is proposed, then Closure Plan Part 3 will be submitted which will include a plan to remove or decontaminate waste and/or waste residues and to verify that decontamination was successful. It will also include the remainder of the required closure plan contents, e.g. schedule, cost estimates, contents of closure certification report. CTDEP will approve of the completed 3-part closure plan after a 30-day public notice period. CTDEP prefers that Part 1 of the Closure Plan be submitted in a loose-leaf 3-ring binder that is large enough to allow the addition of Parts 2 and 3 of the closure plan. This guidance is organized into three sections which cover the requirements of Parts 1, 2 and 3 of the closure plan. The 3-part closure process is most applicable for sites which are actively closing. We recognize that this process may be impractical in certain situations and the following are recommended approaches for some common closure scenarios. 1. Closure Plan On File at CTDEP and Awaiting Review by CTDEP: Many plans were submitted to CTDEP before this guidance was written. We recommend that these plans not be revised until a CTDEP staff person is assigned to review the plan; at that time we may request that the 3-part process be used. NEICVP1493E01 Appendix A Page 578 of 612 4 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Figure 1: Recommended Review and Approval Process NEICVP1493E01 Appendix A Page 579 of 612 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 2. Closure Plan is Currently Being Reviewed by CTDEP: CTDEP will ask that the 3-part closure process be used. 3. Closure Plan Being Written or Revised to Correct Deficiencies Found by a CTDEP Inspector: We recommend that the closure plan be written in a way that will adopt the three-part process when closure takes place. When the plan is reviewed by the CTDEP, we will ask that the 3-part process be used. 4. Closure Plan to be Implemented Voluntarily and Without CTDEP Approval: We recommend that closures which must be implemented prior to CTDEP approval follow the 3-part process even though DEP can not provide any input. However, when CTDEP reviews the plan revisions may be required. 5. Closure Plan Included With Part B Permit Application: Closure plans to be included in permits should follow the guidance to the extent possible without performing site characterization. The permit conditions imposed by CTDEP may specify that the facility must follow the 3-part process (to include CTDEP input) at the time of closure. This should be discussed with the permit writer assigned to your facility when the application is reviewed. NEICVP1493E01 Appendix A Page 580 of 612 6 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLOSURE PLAN PART 1: FACILITY INFORMATION AND SITE CHARACTERIZATION WORK PLAN Closure Plan Part 1 includes a general background of the facility and its environmental setting followed by a site characterization work plan. The work plan can be implemented after CTDEP reviews Part 1 and provides site-specific guidance if needed. I. FACILITY INFORMATION The following closure plan requirements have been compiled from the closure regulations and closure checklists. A. Introduction 1. State the reason for closing, e.g. property transfer, status change. 2. Cite applicable regulations, both state and federal. 3. Summarize regulatory events leading up to closure, e.g. RCRA inspections, enforcement actions. B. Facility Description 1. Describe products manufactured at the facility. 2. Provide the age of the facility, prior use of the property and dates of all historic property transfers. 3. Describe processes which generate hazardous wastes and where these wastes were stored. 4. Provide a topographic map showing a distance of 1000 feet around the facility at a scale of 1 inch equal to not more than 200 feet. Contours must be shown on the map. The contour interval must be sufficient to clearly show the pattern of surface water flow in the vicinity of each closing unit of the facility. The map shall clearly show the following: a Map scale and date, b Surface waters including intermittent streams, c Surrounding land uses (e.g. residential, commercial, agricultural, recreational), d Orientation of map (north arrow), e Legal boundaries of the site, f Withdrawal wells, public and private, NEICVP1493E01 Appendix A Page 581 of 612 7 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 5. All buildings and structures on site (e.g. manufacturing, office, closing regulated unit(s)), C. Environmental Setting 1. Describe the land use within a 1000-foot distance surrounding the facility. 2. Provide groundwater classification at the site. 3. Provide locations of drinking water supplies within a 1000-foot distance surrounding the facility. 4. Describe, using existing data and literature, the local and regional geologic and hydrogeologic setting including description and depth to bedrock, depth to and flow direction of groundwater in all potentially affected aquifers, and a description of site stratigraphy. 5. Describe and provide a map of local topography including surface water bodies. 6. Provide a map of surface drainage patterns and location of storm drains in the vicinity of the regulated units. D. Description of regulated units 1. Provide photographs of the regulated unit(s) to be closed. Clearly delineate all existing containment structures and exterior and interior components. 2. Identify regulated units closing and those remaining open. 3. Provide scale drawings of each regulated unit being closed including secondary containment structures, cross-sections, details e.g. sumps, drains, floor pitches. 4. Provide the design capacity (maximum inventory) of each regulated unit to be closed. 5. Describe the material of construction of the primary and secondary containment structures (e.g. steel, fiberglass for primary containment, and asphalt, concrete, aggregate, soil for secondary containment). If changed or upgraded any time during interim status period, describe and provide dates of changes. 6. Describe the floor coating and the date of application. 7. Describe all components and history of the "tank system" including: a Dimensions, capacity and materials of construction of each tank, b Secondary containment structure design and materials of construction, c All ancillary equipment directly connected to the tank or secondary containment structure, e.g. piping, pressure relief valves, instrumentation, NEICVP1493E01 Appendix A Page 582 of 612 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut valves, level sensors, d Provide a scale drawing of the tank system, include the process flow, e Provide the maintenance/repair/replacement history of the tank system, f Provide the age of the tank system, g Provide information on any spills which occurred during the life of the facility. E. Part A Status 1. Compare all RCRA-regulated units presently on site with those entered on the most recently submitted Part A permit application. 2. If necessary, resolve discrepancies between existing units, design capacities, and waste types with that which appears on the Part A by modifying and resubmitting the Part A as a separate stand-alone document. A modified Part A must be accompanied by an explanation of the changes. Attach a copy of the modified Part A as an appendix to Closure Plan Part I. 3. Include copies of the original Part A and all previous revisions to the Part A in an appendix to Closure Plan Part I. F. Other Sources of Contamination Describe and provide the location of all other sources of contamination which could potentially impact or interfere with characterization of releases from the regulated unit(s) at the site, e.g. spills adjacent to a regulated unit. II. SITE CHARACTERIZATION WORK PLAN The site characterization work plan must describe the steps that will be taken to determine the extent of contamination at the regulated unit. The primary concern is the release of hazardous constituents on/in structures and soil resulting from the storage of hazardous waste. DEP will review and provide input to this work plan before it is implemented. The objectives of site characterization are to: A. Develop a list of constituents of concern (COCs), B. Identify all potential human exposure pathways for each COC, e.g. direct ingestion of contaminated soil, C. Determine whether any contamination (COCs) is present or absent on structures or in soils and, if present, NEICVP1493E01 Appendix A Page 583 of 612 9 Clean Harbors Environmental Services, Inc. Bristol, Connecticut D. Determine the extent of the contamination. The following provides guidance on preparing a site characterization work plan (work plan) that will be used to address each of these objectives. A. Constituents of Concern Constituents of concern are defined as those hazardous constituents which are listed in 40 CFR Part 261 Appendix VIII and which could be present at the regulated unit as residual contamination or as degradation products of residual contamination. DEP would like to see as many COCs as possible presented in the work plan. At the time the work plan is submitted, please state whether analytical work still needs to be performed to complete the COC list. The following are various approaches to determining the COCs for a given site. One or a combination of these approaches can be used. If a particular source of information yields an accurate list of COCs then the other sources described below may not need to be used. As an example, if an active facility has a well organized and complete set of material safety data sheets (MSDS sheets) which date back to the start-up of the facility, then it may not be necessary to analyze the concrete pad for Appendix IX parameters. If however the facility is out of business and records are not available, Appendix IX may be the only option in determining the COCs. 1. Records Review a. A complete review of all Material Safety Data Sheets: i. On file at the site, ii. For all virgin materials used at the entire site, present and historic. This must include everything at the site, not just what was stored at the regulated unit; if a good argument for only including those constituents which were stored at the regulated unit is provided, then it will be evaluated on a case-by-case basis, iii. The COCs would be the hazardous constituent(s) listed on each MSDS. b. Present and historic manufacturing records, e.g. process formulations, virgin product purchasing records, c. Existing waste analysis records at facility or offsite licensed hazardous waste facility which received waste, if available, d. Groundwater monitoring parameters, if available, e. Other environmental permits, and f. Manifests 2. Analysis of representative samples of waste for Appendix IX constituents: NEICVP1493E01 Appendix A Page 584 of 612 10 Clean Harbors Environmental Services, Inc. Bristol, Connecticut a. The hazardous constituents listed in 40 CFR Part 264, Appendix IX are a subset of those constituents in Part 261 Appendix VIII. This list is an acceptable alternative to the Appendix VIII constituents. b. Waste may be analyzed prior to submitting the work plan to DEP, or the sampling and analytical plan can be provided in the work plan and implemented after DEP's review and input. If implemented after, then state that the COC list submitted with the work plan may expand pending this analysis. c. Only necessary if sufficient waste analysis data and generating process information is not available. d. Each waste type must be sampled in accordance with Test Methods for Evaluating Solid Waste, dated November, 1986, SW-846. The samples must be representative of all wastes stored at the regulated unit. See Attachment C - Table 1-1 for guidance on sampling and analysis of wastes. 3. Analysis of porous secondary containment structures (e.g. concrete) for Appendix IX constituents. See Attachment C - Table 1-2. a. Obtain chip samples for analysis. Perform mass analysis, no leach procedure. b. Sampling guidance for inorganics, metals, semi-volatiles: i. Sample locations selected randomly and judgmentally (e.g. stained areas, sumps). ii. Obtain one composite sample made up of samples taken at the rate of one per 100 square feet of floor space per regulated unit but no less than three samples for small areas. Limit ten samples per composite. iii. If incompatible wastes were segregated in separate storage areas, then each storage area must be sampled. Samples from two or more incompatible storage areas may be composited provided the samples are first evaluated for their compatibility. See 40 CFR 265.17 for a definition of compatibility. c. Sampling guidance for volatile organics: i. Sample locations judgmentally selected based on screening for VOCS (e.g. portable organic vapor analyzer) and visual staining and/or deterioration of containment structures. ii. One discrete sample per regulated unit; no compositing. d. The Appendix IX laboratory data must be appended to the closure plan. All data must be presented, including analytical detection limits and those parameters which are found to be below the detection limit. NEICVP1493E01 Appendix A Page 585 of 612 11 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 4. Conduct interviews with former employees in cases where a site has been closed and storage records are not available. 5. If there are non-hazardous constituents present at concentrations which could pose a risk to human health and the environment , e.g. aluminum, then include them on the COC list. B. Identify All Potential Human Exposure Pathways All potential human exposure pathways must be identified before designing a site characterization sampling and analysis plan. Once each pathway is known, the relevant media (e.g. soil, soil water, air) can be evaluated. In determining human exposure pathways, the post-closure use of the site must be considered as well as all available site specific information. For more specific guidance on identifying all applicable human exposure pathways for a given site, see the following guidance documents: Supplemental Risk Assessment Guidance for the Superfund Program, EPA 901/5-89-001, USEPA Region I, Draft Final June 1989, Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual (Part A), Interim Final, EPA/540/1-89/002, December 1989. (Available from NTIS, PB-90-155581.) The following are three typical examples of human exposure pathways followed by the related media that will need to be evaluated/analyzed: 1. Direct ingestion of contaminated soil or structures. Possible at sites where children could be present. Related media: soil, concrete, or potentially contaminated structural material. 2. Ingestion of groundwater contaminated by water (i.e. "soil water") leached through structures (e.g. concrete) or soil which surrounds or underlies the regulated unit. The Toxicity Characteristic Leaching Procedure (TCLP), found in 40 CFR 261 Appendix II, produces a representative sample of soil water for analysis. Related media: soil, structural material. 3. Inhalation of air impacted by COCs released from regulated unit structures or soils: a. Applies only to volatile COCs, e.g. organics and mercury. b. Applies to the indoor air space for enclosed regulated units. To assess the risk posed by contaminated structures or soil in enclosed units, a worst-case air concentration can be estimated by calculating as follows: i. Measure mass concentration of volatile COCs in structures or soil, ii. Assume the most conservative exposure scenario: 100 percent of each NEICVP1493E01 Appendix A Page 586 of 612 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut COC is released from the equipment, structures and soil to the air space and remains in the air for a 70-year exposure period. iii. See Attachment B for an example calculation. c. Applies to release of volatiles from water in an enclosed area, e.g. showering. d. Related media: concrete, porous floor, wall, or ceiling material. C. Identify the Presence/Absence of Contamination Requiring Remediation The Site Characterization Work Plan must describe how the regulated unit structures and soils will be assessed to determine whether contamination has been released by the regulated unit and requires remediation. Figure 2 on the next page provides a visual explanation of what is described below. If there is a record of a release, or there is physical or analytical evidence of a release of contaminants to structures or soils, then this step is not necessary; proceed to determination of the extent of contamination as described in the next section (IV). If there is no evidence of a release then verification sampling and analysis of structures and soils must be performed as follows: 1. Presence/Absence of Contamination on Structures Determine whether the structures have been contaminated by the following: a. Obtain a statistically representative number of samples of the structure, at randomly chosen locations, for analysis of the COCs. b. The sampling method should not impact sample integrity, e.g. chip is favored over core sampling to avoid loss of volatiles. c. Describe the sampling and analysis procedures. Indicator constituents can be used but the full COC list must be used if the indicator parameter results do not exceed media closure criteria (described below). Mass analysis can be used and leach values can be calculated if necessary. d. For metals, compare each discrete sample result to the relevant media closure criteria and exposure pathway (media closure criteria are described in Attachment D). If any result exceeds the media closure criteria (MCC), then determine the extent of contamination as described in the next section. For volatiles, any detectable level triggers the need to measure the extent of contamination. NEICVP1493E01 e. If the metals results are below MCCs and there are no detectable levels of volatiles then the structures can be considered free of contamination requiring remediation. Proceed to the determination of the presence/absence of contamination in soils, paragraph B below. Appendix A Page 587 of 612 13 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 2. Presence/Absence of Contamination in Soils From Secondary Containment Structures The work plan must describe how the structural integrity of secondary containment systems (e.g. container storage areas, tank systems) will be assessed for their potential impact to surrounding or underlying soils. Some considerations in this assessment are as follows: a. Inspect pad and perimeter berms for features, e.g. expansion joints, cracks (including hairline), gaps, deteriorating concrete, which could have allowed a release of contaminants. Make sure that resurfacing/recoating of pad has not concealed cracks, etc. b. Inspect for the above features after a dry sweep of the pad but prior to full decontamination, c. If any of the above features are present, determine if contaminants migrated to the subsoils using the following procedure: i. Bore a 4 inch core through the containment structure at the suspected conduit(s) and remove plug(s), ii. Inspect each plug cross section, iii. If feature (e.g. crack) extends through plug, sample each soil horizon down to groundwater, analyze (mass basis) each sample for the indicator COCs or full COC list if indicators are not detected. iv. If any metal exceeds MCCs in any soil type or any volatile is detected then determine the extent of the contamination as described in the next section. v. If crack does not extend through plug but volatile organics are on the constituent of concern list, use a portable organic vapor analyzer to measure soil vapors in the slab borehole. (a) If volatile organics are detected in the borehole, determine extent of the volatile contamination as described in the next section. (b) If volatile organics are not detected in the borehole, then further investigation for the extent of contamination in soil (described in the next section IV) is not necessary. vi. Regrout boreholes before proceeding with closure. NEICVP1493E01 Appendix A Page 588 of 612 14 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Figure 2: Determination of the Presence/Absence of Contamination Requiring Remediation NEICVP1493E01 Appendix A Page 589 of 612 15 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 3. Presence/Absence of Contamination in Soils from Tank Systems The following is specific to tank systems when assessing their structural integrity for potential impact to surrounding or underlying soils. A tank system integrity assessment can be conducted to prove that the tank system never leaked. If successful, subsoils need not be investigated for presence or extent of contamination. The completed integrity assessment must be appended to Closure Plan Part 2. If the tank is known to have leaked then the assessment is not necessary; proceed to determination of the extent of contamination. The tank system integrity assessment includes: a. A written assessment of the structural integrity of each tank system which is reviewed and certified by an independent, qualified, registered professional engineer. b. For non-enterable, underground tank systems including ancillary components, the assessment should include a leak test. State-of-the-art leak test methodology must be used. Select a leak test after consulting with a qualified, independent, registered professional engineer. c. All assessments must inspect each tank system component for cracks, leaks, corrosion, and erosion. d. For tank systems which had secondary containment for their entire operating life, provide a summary of the leak inspections or leak-detection system monitoring data to verify that no leaks ever occurred during the lifetime of the tank system. If this information is not available, conduct an integrity assessment as described above. e. If the tank integrity assessment indicates that there was a potential for leakage then determine the extent of the contamination as described in the next section. f. In addition to the integrity assessment, the operating practices, e.g. filling/emptying, must be evaluated for potential sources of contaminant release. D. Determine the Extent of Contamination in Structures and Soils If contamination is found to be present in either the structures or soils of the regulated unit during the previously described exercise, the work plan must describe how the three-dimensional extent of contamination in both media will be determined. For unsaturated soils, you must determine the extent of contaminants which exceed naturally occurring background levels but, based on current toxicity information, pose no risk to human health. In addition, you must determine the extent of contaminants which pose a risk to human health and will need to be remediated. NEICVP1493E01 Appendix A Page 590 of 612 16 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Figure 3 illustrates these two "rings" of contamination that must be defined. If the regulated unit is designed to prevent lateral escape of hazardous wastes in the event of a spill, e.g. perimeter walls, and there are no historic records of spills released beyond these barriers, then sampling for the lateral extent of contamination beyond these barriers is not required. Soils directly beneath the unit, however, still must be characterized. For the extent of contaminants exceeding naturally occurring background but pose no risk to human health (see Attachment D for guidance on background determination) an estimate based on data gathered from field-screening techniques such as soil gas surveys or x-ray fluorescence may be acceptable. Figure 3: Illustration of an Idealized Contaminant Migration Pattern in the Unsaturated Zone The following provides guidance on determining the three-dimensional extent of contamination in structures and soils which pose a risk to human health. This exercise is more rigorous than the use of field-screening techniques. 1. Select a statistically representative number of samples to be located outside an estimated perimeter of the contamination caused by the regulated unit. Provide statistical methodology used to select sample number. 2. Sample and analyze the structures and/or soils at the estimated perimeter of NEICVP1493E01 Appendix A Page 591 of 612 17 Clean Harbors Environmental Services, Inc. Bristol, Connecticut the contamination. Sampling and analysis procedures must be described. 3. Sample borings should extend to mean seasonal low groundwater, and samples should be taken at each soil horizon. Illustrate the sample depth, concentration data, each soil type, and the location of groundwater on a crosssectional diagram. 4. General Sampling and Analysis Guidance for Determining the Extent of Contamination: a. Use of indicator parameters is allowed but the full constituent-of-concern list must be analyzed at the sampling round thought to be at the extent of contamination. b. Mass analysis is acceptable for the indicator parameters however all final samples must be analyzed for both mass and TCLP, or TCLP can be calculated by dividing the mass value by 20. c. Obtain discrete samples; no compositing. d. For sampling of organics in soil, take from 6 inches below the surface to avoid bias due to volatilization. e. Perform all site characterization sampling prior to decontamination or removal of containment structures. f. See Attachment C Tables 1-4 and 1-5 for further guidance on sampling and analysis. 5. Describe Decision Process to Conclude Sampling The work plan must describe how to determine whether the extent of contamination has been defined and no further sampling is necessary. Consider the following: a. Compare each discrete sample result with the Media Closure Criteria (MCC). MCCs are developed as described in Attachment D. b. If any sample result is in excess of the MCCs then move outward and/or deeper and resample. The extent of contamination requiring remediation is defined by the outermost or deepest set of samples which contain constituents of concern at concentration levels at or below established MCCs. Structures and soils requiring remediation are those which lie within this sampling perimeter. 6. Present all analytical results in Closure Plan Part 2. 7. One of the purposes of conducting site characterization before completing the NEICVP1493E01 Appendix A Page 592 of 612 18 Clean Harbors Environmental Services, Inc. Bristol, Connecticut closure plan is to determine if contamination is present which is unrelated to the activities of the regulated unit. If this occurs, DEP will evaluate these situations on a case-by-case basis. Some of the issues that will need to be addressed: a. Where does RCRA interim-status closure leave off and where does Corrective Action take over in cleaning up the non-RCRA contamination? b. Will the remediation standards be any different between the two programs? c. When will Corrective Action be implemented at the site? NEICVP1493E01 Appendix A Page 593 of 612 19 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLOSURE PLAN PART 2: RESULTS OF SITE CHARACTERIZATION PROGRAM AND PROPOSED CLOSURE APPROACH Once the Site Characterization Work Plan has been implemented the results should be presented in Closure Plan Part 2. Using these results, a proposal should be made in Closure Plan Part 2 to close the regulated unit "clean" or close it as a landfill*. The following provides guidance on each of these objectives. I. Site Characterization Sampling and Analysis Results A. Include all site characterization sampling and analytical results including summary tables, laboratory reports and chain-of-custody documentation. B. Although not required in this report, laboratory QA/QC data and chromatograms must be made available to DEP upon request. C. Include the Media Closure Criteria and flag those results which exceed the criteria. D. Analytical detection levels must be provided for all results presented. E. Data Presentation All media closure criteria and analysis data must be expressed in units which are clearly defined, labeled and used consistently throughout the closure plan and any appended laboratory reports. The following units must be used: 1. Inorganics: a. Mass analysis of soil - milligrams per kilogram (Mg/kg) b. Analysis of soil leachate - milligrams per liter (Mg/l) c. Air - milligrams per cubic meter (Mg/m3) 2. Organics: a. Mass analysis of soil - micrograms per kilogram (ug/kg) b. Analysis of soil leachate - micrograms per liter (ug/l) c. Air - micrograms per cubic meter (ug/m3) F. Illustrate the 3-dimensional contaminant profile in soil with contour maps and crosssectional diagrams. Include the location of the regulated unit, soil horizons, and depth to groundwater. NEICVP1493E01 Appendix A Page 594 of 612 20 Clean Harbors Environmental Services, Inc. Bristol, Connecticut II. Proposed Closure Approach A. Clean closure generally should be proposed if: 1. Surrounding and underlying soil has not been impacted by releases from the regulated unit or 2. Surrounding and underlying soil (which has been impacted) can be removed or decontaminated within the 180-day closure period. B. Landfill Closure* generally should be proposed if: 1. The underlying or surrounding soil has been impacted by the regulated unit and the facility has decided that removal and/or decontamination of the soil is not feasible. Once the Connecticut Clean-up Standard Regulations become promulgated they will define and limit those circumstances under which contamination may be left in place. 2. If soil is contaminated down to the seasonal low ground water elevation then it is likely that groundwater has been impacted. For these sites, DEP will determine the most appropriate closure approach on a case-by-case basis. III. Departures From Site Characterization Work Plan Describe and justify those portions of the completed site characterization program that departed from the accepted site characterization work plan. *Note: As stated in 40 CFR Part 265.197(b) regarding closure of tank systems: "If the owner or operator demonstrates that not all contaminated soils can be practicably removed or decontaminated......then the o/o must close the tank system and perform post-closure care in accordance with the closure and post-closure care requirements that apply to landfills (265.310)." Even though the regulations regarding closure of drum storage areas do not use this language, DEP will require that drum storage areas in similar situations be subject to closure as a landfill. NEICVP1493E01 Appendix A Page 595 of 612 21 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CLOSURE PLAN PART 3: REMEDIATION, VERIFICATION, QA/QC, CERTIFICATION Closure Plan Part 3 describes the steps to remove and dispose of the hazardous waste, and the steps to remove and/or decontaminate media identified in the site characterization phase of the process as being contaminated. Part 3 is the final document that will be submitted. We recommend that it be submitted so that it can be easily combined with Closure Plan Parts 1 and 2 to form the complete closure plan. The following Sections I and II provide general guidance on writing both container storage and tank closure plans. Section III provides specific guidance for tank systems. I. Closure Performance Standard A. The closure performance standard specified in 40 CFR 265.111 is a regulation stating the general objectives of closure. This must not be confused with the media closure criteria or risk-based standards. B. This requirement is satisfied by stating in the closure plan that closure will be carried out as required by this regulation, i.e. quote the regulation. II. Removal and disposal/decontamination of waste, equipment, structures and soil The closure plan must describe how the following activities will be performed: A. Remove and dispose of all hazardous waste inventory from the regulated unit. Provide the name and location of the licensed hazardous waste facility that will receive the waste. B. Decontaminate or remove and dispose of all equipment, structures and soils measured to be in excess of the media closure criteria. The following must be specified in the closure plan: 1. Method of decontamination and/or removal, 2. Means for collection and disposal of decontamination or removal residues, 3. Type of decontamination solutions to be used, 4. Method used to prevent the release of hazardous constituents to surrounding or underlying structures, soils, room air, or ambient air during decontamination and/or removal. As an example, if cracks or gaps were discovered during the site characterization phase of closure then they must be sealed prior to any decontamination procedures to prevent the release of residues to the subsoils, 5. An estimate of the volume of the decontamination and/or removal residues to be generated, NEICVP1493E01 Appendix A Page 596 of 612 22 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 6. Name and location of proposed off-site facility which will receive decontamination and/or removal residues, 7. Method used to perform a hazardous waste determination on the decontamination and/or removal residues, (See Attachment C - Table 1-6), 8. Method to be used to decontaminate all equipment used in the decontamination and/or removal process, 9. Use manifest if decontamination and/or removal residues are hazardous waste, restricted from land disposal, or are Connecticut Regulated Wastes, 10. Obtain permission from DEP to dispose of decontamination and/or removal residues if they are non-hazardous waste and are to be disposed of at an in-state solid waste landfill, 11. Provide the location of the staging area for the decontamination and/or removal residues, 12. State that worker health and safety will be addressed in accordance with 29 CFR 1910.120. A complete health and safety plan is not necessary and CTDEP does not have the authority to approve them. C. Include the following sampling and analysis methods that will be used to confirm that decontamination and/or removal achieved stated media closure criteria, (also see Attachment C - Tables 1-7 and 1-8): 1. Statistically representative number of samples at a 95 percent level of confidence. See the following references for the statistical procedures for selecting sample size: Technical Guidance Document: Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, dated October, 1986, EPA/530-SW-86-031 Test Methods for Evaluating Solid Waste, SW-846 2. Sample locations chosen randomly and judgmentally, 3. Sample floor, walls and ceilings of storage area if these structures were decontaminated, 4. Obtain chip samples if porous media, wipe sample if non-porous media, 5. See wipe sampling procedure in Attachment A, 6. Clean-up criteria for wipe samples is non-detect for all COCs; in cases where interferences are encountered, e.g. metals detected from a steel tank, an alternative to the "non-detect" criteria may be proposed, NEICVP1493E01 Appendix A Page 597 of 612 23 Clean Harbors Environmental Services, Inc. Bristol, Connecticut 7. No compositing of samples; analyze all discrete samples individually, 8. Media closure criteria must be achieved for each COC at each sample point; comparison of a mean concentration to clean-up criteria is not acceptable. Remove or decontaminate again if media closure criteria is not achieved, 9. If subsoils are removed, describe how the floor and sidewalls of the excavation will be sampled and analyzed. D. Backfilling of excavations 1. Clean soil must be used; provide analysis results of representative samples of clean soil, and provide location and history of borrow site. 2. Backfilled soil must be compacted when placed in the excavation in such a manner as to prevent post-closure settlement. III. Removal and Decontamination of Tank Systems The following guidance is specific to tank systems. For more information read 40 CFR 265 Subpart J: A. As stated earlier, a "tank system" includes: 1. Tank, 2. Secondary containment structure, 3. All ancillary equipment directly connected to the tank or secondary containment structure, e.g. piping, pressure relief valves, instrumentation, valves, level sensors. B. Remove all hazardous wastes and residues from the tank system. C. Verify that decontamination of the tank system was successful using the same methods described for container storage areas. In most cases, the tank itself will be non-porous and will require a wipe test described previously. For tank system piping, triple rinse with an appropriate decontamination solution and analyze the final rinse for all constituents of concern to verify that all media closure criteria have been met. Also see Attachment C - Tables 1-8 and 1-9. D. Final disposition of tank system components can be accomplished by either: 1. Removing and disposing of tank if required by the State Fire Marshall, or 2. Abandoning in-place provided the tank is filled with an inert dry sand or equivalent media. E. If tank is to remain in service after completion of closure, specify the material to be stored. NEICVP1493E01 Appendix A Page 598 of 612 24 Clean Harbors Environmental Services, Inc. Bristol, Connecticut F. Remove or decontaminate contaminated soil in a manner similar to that described previously for container storage areas. G. For additional information on closing tank systems, see Chapter 12 of the Technical Resource Document For The Storage And Treatment Of Hazardous Waste In Tank Systems, dated December 1986, NTIS #PB87-134391. IV. Quality Assurance and Quality Control Procedures (QA/QC) Describe the procedures to be used to ensure that the closure will be completed in accordance with the approved closure plan A. Must be consistent with all applicable sections of: Technical Guidance Document: Construction Quality Assurance For Hazardous Waste Land Disposal Facilities , dated October 1986, EPA/530-SW-86-031. B. Identify the responsibility and authority of each individual or organization listed below who is involved with QA/QC: 1. Engineer, 2. QA/QC personnel, 3. Construction contractor. C. Describe the project meetings that will take place, including pre-closure meetings, and meetings to discuss deviations from the approved closure plan. D. Provide the qualifications of the QA/QC coordinator, the QA/QC inspectors, and the engineering consultant. E. Describe the QA/QC for sampling and chain-of-custody procedures. F. Specify that all laboratory analyses will be conducted using QA/QC procedures specified in the EPA document Test Methods for Evaluation Solid Waste, SW-846. V. Closure Schedule A. Provide a schedule of closure. B. State that closure activities will be completed within 180 days of approval of the closure plan. C. Are any extensions to the time limits anticipated? If so provide justification. D. Will seasonal conditions impact schedule? VI. Financial Assurance/Closure Cost Estimates A. Provide an estimate of the closure costs in accordance with 22a-449(c)-105 of the NEICVP1493E01 Appendix A Page 599 of 612 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut CTHWMR and 40 CFR 265.142. B. Provide documentation that financial assurance for closure has been obtained sufficient to cover the cost of closure. This must be in accordance with 22a-449(c)105 of the CTHWMR and 40 CFR 265.143. VII. Certification of Closure The closure plan must state that a closure certification report will be prepared after closure is complete and that the following will be included in the report: A. Provision for certification by owner or operator within 60 days following closure, B. Provision for certification by independent registered Professional Engineer that facility was closed in accordance with the approved closure plan, C. Provision for Closure Documentation Report to document closure activities, D. Summary of all QA/QC data collected during closure, E. Photographic record of each milestone event, (identify each event in the plan), F. List and justify all departures from approved closure plan, G. Certification statement, H. Verification sample results after decontamination or removal of equipment, structures and soil, I. If clean closure was achieved but there are other operating units at the facility, submit a revised Part A permit application by deleting the closed regulated unit, J. For a complete closure, i.e. all regulated units closed, the Part A must be withdrawn; the withdrawal request must be submitted with the closure certification document. VIII. Appendices A. Do not append previous revisions of the closure plan to the closure plan. B. Provide separating pages with tabs to divide each appendix. C. Submit legible copies. Last Updated: June, 2005 NEICVP1493E01 Appendix A Page 600 of 612 26 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT A: WIPE SAMPLING PROCEDURE The following procedure is used to sample non-porous material to verify that media closure criteria have been achieved after decontamination or removal has been completed. Examples of non-porous material are: steel or fiberglass tanks, structural steel (painted or unpainted). 1. Select an area of 1/2 square meter on the equipment/structure to be tested. 2. For analysis of constituents of concern, saturate a cotton gauze with: a. Methanol for volatiles, b. Hexane-acetone mix (1:1), or methylene chloride for semi-volatiles, c. Hexane for PCBs, d. Dilute nitric acid (1:4 nitric acid to deionized water) for metals, e. Dilute sodium hydroxide for cyanide. 3. Wipe the saturated gauze over half the sampling area (1/4 square meter) repeatedly in the vertical direction, applying moderate pressure. Turn the gauze over and wipe repeatedly in the horizontal direction. Repeat the procedure with the nitric acid-saturated gauze on the other half of the sampling area. 4. Place each gauze in a separate jar with a Teflon seal and submit the samples for laboratory analysis. 5. Analyze for all contaminants of concern Media closure criteria for wipe samples is non-detect for all contaminants of concern. Repeat the decontamination process and resample if necessary. Consider the potential for interferences from the material being sampled. Rev 11/93 NEICVP1493E01 Appendix A Page 601 of 612 27 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT B: CALCULATION OF WORST-CASE AIR CONCENTRATIONS To verify that the Media Closure Criteria for the air inhalation pathway have been achieved after remediation. 1. Measure the total mass of the concrete slab: Slab Volume * density of concrete Cubic Meters * Kilograms/Cubic meters = kg 2. Measure room dimensions and calculate volume of air in the storage area in cubic meters 3. Analyze a representative number of samples of concrete for each COC, on a mass basis (mg/kg). 4. Calculate the room air concentration for each COC, for each sample point, assuming the total constituent mass is released to the room air at one instant, and remains there for a 70-year exposure period: CRA = Cc * Mc VRA Where: CRA = Concentration of room air for a given constituent (mg/m3) Cc = Mass Concentration of a given constituent in the concrete (mg/kg) Mc = Mass of concrete slab (kg) VRA = Volume of room air (m3) 5. Compare CRA to the media closure criteria for each COC. NEICVP1493E01 Appendix A Page 602 of 612 28 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT C: SAMPLING AND ANALYSIS GUIDANCE TABLE 1-1: Analysis of Waste for Appendix IX Parameters Number of Samples: 1 per waste type, or 1 composite of all waste types if compatible and there are no analytical interferences. Selection of Sample Locations: Waste containers or tanks Sampling Methodology Composite: Discrete: Chip (Porous media): Wipe (Non-Porous media): Yes, if compatible Yes, if incompatible N/A N/A Analysis Parameters Target Parameters: N/A Complete COC List: N/A Analysis of: Total Constituent Mass: Yes Extract from Leach Procedure: No VOC screening (Portable organic vapor analyzer): N/A NOTE:Analysis of waste for Appendix IX parameters is only necessary if waste analysis data is not available. NEICVP1493E01 Appendix A Page 603 of 612 29 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-2: Analysis of Secondary Containment Structures for Appendix IX Constituents Number of Samples: Inorganics: Organics: 1 per 100 square feet of surface area, but no less than 3 total 1 per regulated unit Selection of Sample Locations: Inorganics: Organics: Random and judgmental Use portable organic vapor analyzer to locate most elevated levels for sample Sampling Methodology: Composite: Discrete: Chip (Porous media): Wipe (Non-Porous media): Yes, for inorganics only Yes, for organics only Yes Yes Analysis Parameters: Target Parameters: N/A Complete COC List: N/A Analysis of: Total Constituent Mass: Yes Extract from Leach Procedure: No VOC screening (Portable organic vapor analyzer): Yes, for organics NEICVP1493E01 Appendix A Page 604 of 612 30 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-3: Development of Background Values for Media Closure Criteria Number of Samples: Statistically representative number Selection of Sample Locations: In an area believed to be unaffected by the activities of the regulated unit Sampling Methodology: Composite: No Discrete: Yes Chip (Porous media): Yes Wipe (Non-Porous media): N/A Analysis Parameters: Target Parameters: Complete COC List: Yes, only those for which a media closure criteria is needed, but exclude all volatile organics No Analysis of : Total Constituent Mass: Extract from Leach Procedure: Yes, if needed If needed VOC screening: (Portable organic vapor analyzer): N/A NEICVP1493E01 Appendix A Page 605 of 612 31 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-4: Site Characterization - Determination of Lateral Extent of Contamination Number of Samples: Arbitrary but must be demonstrated to be statistically representative using SW-846 Volume II Chapter 9 Selection of Sample Locations: At or beyond estimated lateral extent of contamination. Move outward if contaminants found Sampling Methodology: Composite: Discrete: Chip (Porous media): Wipe (Non-Porous media): No Yes Yes if structure, N/A if soil N/A Analysis Parameters: Target Parameters: Complete COC List: Analysis of : Total Constituent Mass: Extract from Leach Procedure: VOC screening: (Portable organic vapor analyzer): Yes Yes, at outermost sample point Yes Yes or can calculate (Mass/20) Contractor's discretion NOTE: Not necessary to sample beyond berms or walls if: 1) There is no record of spills outside containment area and 2) berms and walls have no cracks, gaps or deterioration NEICVP1493E01 Appendix A Page 606 of 612 32 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-5: Site Characterization - Determination of Vertical Extent of Contamination Number of Samples: 1 per potential contaminant conduit (e.g. crack, gap) per each soil horizon until extent of contamination is reached Selection of Sample Locations: At potential contaminant conduits Sampling Methodology: Composite: No Discrete: Yes Chip (Porous media): N/A Wipe (Non-Porous media): N/A Analysis Parameters: Target Parameters: Complete COC List: Analysis of : Total Constituent Mass: Extract from Leach Procedure: Yes At deepest sample Yes Yes or can calculate (Mass/20) VOC screening: (Portable organic vapor analyzer): Yes, sample for vapor in bore hole in cases where conduit does not extend through plug removed from concrete slab. This verifies that organics never migrated through the porous concrete NEICVP1493E01 Appendix A Page 607 of 612 33 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-6: Hazardous Waste Determination - Equipment, Structures, Soils Disposed of Offsite Number of Samples: 1 per 20 cubic yards Selection of Sample Locations: Random and judgmental Sampling Methodology: Composite: No Discrete: Yes Chip (Porous media): Yes Wipe (Non-Porous media): N/A Analysis Parameters: Target Parameters: Complete COC List: Yes As needed Analysis of : Total Constituent Mass: No Extract from Leach Procedure: Yes VOC screening: (Portable organic vapor analyzer): N/A NEICVP1493E01 Appendix A Page 608 of 612 34 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-7: Post-Decontamination Sampling of Soils Number of Samples: Arbitrary; must be demonstrated to be statically representative using SW-846 Volume II, Chapter 9 Selection of Sample Locations: Random and judgmental Sampling Methodology: Composite: No Discrete: Yes Chip (Porous media): N/A Wipe (Non-Porous media): N/A Analysis Parameters: Target Parameters: Complete COC List: Screening only Yes Analysis of : Total Constituent Mass: Extract from Leach Procedure: Yes Yes, or calculate (Mass/20) VOC screening: (Portable organic vapor analyzer): Contractor discretion NEICVP1493E01 Appendix A Page 609 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-8: Post-Decontamination Sampling of Tanks and Secondary Containment Structures which are Constructed of Porous Material Number of Samples: Arbitrary but must be demonstrated to be statistically representative using SW-846 Volume II Chapter 9 Selection of Sample Locations: Random and judgmental Sampling Methodology: Composite: No Discrete: Yes Chip (Porous media): Yes Wipe (Non-Porous media): N/A Analysis Parameters: Target Parameters: Complete COC List: Only for screening Yes Analysis of : Total Constituent Mass: Extract from Leach Procedure: Yes Yes or calculate (Mass/20) VOC screening: (Portable organic vapor analyzer): Contractor discretion NEICVP1493E01 Appendix A Page 610 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut TABLE 1-9: Post-Decontamination Sampling of Tanks and Secondary Containment Structures which are Constructed of Non-porous Material Number of Samples: 1/2 square meter per regulated unit Selection of Sample Locations: Judgmental Sampling Methodology: Composite: N/A Discrete: N/A Chip (Porous media): N/A Wipe (Non-Porous media): Yes Analysis Parameters: Target Parameters: No Complete COC List: Yes Analysis of : Total Constituent Mass: Yes Extract from Leach Procedure: No VOC screening: (Portable organic vapor analyzer): Contractor Discretion Notes: 1. 2. Closure criteria for wipe sampling is the lowest analytical detection level for all COC's See Attachment A for Wipe Sampling Procedure NEICVP1493E01 Appendix A Page 611 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut ATTACHMENT D: GUIDANCE ON DEVELOPING MEDIA CLOSURE CRITERIA Media closure criteria (MCCs) are contaminant concentrations in environmental media that will pose no risk to human health and the environment. MCCs are used to define the extent of contamination that must be remediated, and they are used to verify that the remediation was successful. An MCC must be developed for each constituent of concern (COC) and each applicable media, (soil, soil water, i.e. water leached from soil, concrete, air), as defined by the human exposure pathways at a given site. Using this procedure usually results in two or three MCCs developed for each COC to address each exposure pathway. The numeric criteria found in the Remediation Standard Regulations (RSRs), adopted by the Commissioner pursuant to RCSA Sections 22a-133k and 22a-133q, are the source of media closure criteria for closure. All media closure criteria must be developed consistent with the RSRs. Go to http://www.dep.state.ct.us/wtr/regs/remediationregs.htm to access the RSRs on the web. Please use the soil criteria in the RSRs as the media closure criteria for concrete. I. Guidance on Developing MCCs Based on Background Samples Refer to the RSRs for determining media closure criteria based on background concentrations in soil for naturally-occurring substances. II. Expression of media closure criteria and related analytical data units All media closure criteria and related analytical data must be expressed in units which are clearly defined, labeled and used consistently throughout the closure plan and any appended laboratory reports. The following units must be used: A. Inorganics: 1. Mass analysis of soil - milligrams per kilogram (mg/Kg) 2. Analysis of soil leachate - milligrams per liter (mg/l) 3. Air - milligrams per cubic meter (mg/m3) B. Organics: 1. Mass analysis of soil - milligrams per kilogram (mg/Kg) 2. Analysis of soil leachate - micrograms per liter (g /l) 3. Air - micrograms per cubic meter (g /m3) NEICVP1493E01 Appendix A Page 612 of 612 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix B Wastewater Treatment Flow Diagram (1 page) NEICVP1493E01 File Path: J:\DWG\P91\91323\H12\Process Controls\Working\Complete PFD.dwg Layout: FIG. 1 Plotted: Tue, August 25, 2020 - 5:27 PM User: spadget LAYER STATE: Plotter: DWG TO PDF.PC3 CTB File: FO.STB MS VIEW: No. NEICVP1493E01 DATE DESCRIPTION SEAL SEAL DESIGNER REVIEWER SCALE: DATUM: HORZ.: N.T.S. VERT.: HORZ.: VERT.: Appendix B Page 1 of 1 1550 MAIN STREET, SUITE 400 SPRINGFIELD, MA 01103 413.452.0445 www.fando.com BRISTOL CLEAN HARBORS FACILITY FLOW, LINE, AND BALANCE DIAGRAM 51 BRODERICK ROAD PROJ. No.: 01991323.H12 DATE: 8/3/2020 CONNECTICUT FIG. 1 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix C Inspection Photographs (25 pages) NEICVP1493E01 VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 1 Tank 14 12/6/2022 10:55:25 AM PC060213.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 2 Carbon cans intended to collect vapors from tank 14 12/6/2022 10:55:52 AM PC060214.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 3 Hazardous waste satellite accumulation drum in area M2 12/6/2022 11:02:52 AM PC060215.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 1 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 4 Label on hazardous waste drum in photo 3 12/6/2022 11:03:26 AM PC060216.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 5 Hazardous waste oilbased paint accumulation container in area M2 12/6/2022 11:08:56 AM PC060217.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 6 Label on paint container in photo 5 12/6/2022 11:09:09 AM PC060218.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 2 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 7 Tote containing F006 hazardous waste with discrepant DOT label in area K6 12/6/2022 11:19:53 AM PC060219.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 8 Label on hazardous waste tote in photo 7 12/6/2022 11:20:14 AM PC060220.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 9 Additional F006 hazardous waste totes in area K6 12/6/2022 11:20:53 AM PC060221.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 3 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 10 Tank 29 12/6/2022 11:58:03 AM PC060222.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 11 Instructional sign inside the container storage building 12/6/2022 2:12:14 PM PC060223.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 12 Seven bulk containers of hazardous waste paint 12/6/2022 2:12:55 PM PC060224.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 4 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 13 Hazardous waste satellite accumulation drum in container storage building 12/6/2022 2:18:04 PM PC060225.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 14 Roll-off container of solidified nonhazardous waste in mix tub area 12/6/2022 2:43:49 PM PC060226.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 15 Label of roll-off container in photo 14 12/6/2022 2:44:11 PM PC060227.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 5 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 16 Blind sump in mix tub area 12/6/2022 2:51:47 PM PC060228.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 17 Mix tub 12/6/2022 2:52:36 PM PC060229.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 18 Mix tub 12/6/2022 2:53:08 PM PC060230.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 6 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 19 Bulk liquid unloading pipes 12/6/2022 3:04:11 PM PC060231.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 20 Bulk liquid unloading pad 12/6/2022 3:04:47 PM PC060232.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 21 Stabilized hazardous waste in roll-off container CHRT26905 12/6/2022 3:55:59 PM PC060233.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 7 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 22 Roll-off container CHRT26905 12/6/2022 3:56:30 PM PC060234.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 23 Staging sample S01 in roll-off container CHRT26905 12/7/2022 9:45:39 AM PC070235.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 24 Collected sample S01 12/7/2022 9:51:47 AM PC070236.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 8 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 25 Staging sample S02 in roll-off container CHRT26905 12/7/2022 9:56:22 AM PC070237.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 26 Collected sample S02 12/7/2022 10:01:03 AM PC070238.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 27 Staging sample S03 in roll-off container CHRT26905 12/7/2022 10:05:34 AM PC070239.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 9 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 28 Collected sample S03 12/7/2022 10:10:02 AM PC070240.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 29 Staging sample S04 in roll-off container CHRT26905 12/7/2022 10:14:40 AM PC070241.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 30 Collected sample S04 12/7/2022 10:20:12 AM PC070242.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 10 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 31 Staging sample S05 in roll-off container CHRT26905 12/7/2022 10:23:50 AM PC070243.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 32 Collected sample S05 12/7/2022 10:28:05 AM PC070244.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 33 Contents inside rolloff container CHRT26905 12/7/2022 10:29:35 AM PC070245.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 11 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 34 Outside roll-off container CHRT26905 12/7/2022 10:30:03 AM PC070246.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 35 Hazardous waste label on roll-off container CHRT26905 12/7/2022 10:30:33 AM PC070247.JPG Zach Schlachter OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 36 Staging sample S01 for splitting 12/7/2022 11:00:31 AM PC070248.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 12 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 37 Completed splits of sample S01 12/7/2022 11:08:08 AM PC070249.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 38 Staging sample S02 for splitting 12/7/2022 11:10:24 AM PC070250.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 39 Completed splits of sample S02 12/7/2022 11:18:46 AM PC070251.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 13 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 40 Staging sample S03 for splitting 12/7/2022 11:20:58 AM PC070252.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 41 Completed splits of sample S03 12/7/2022 11:28:01 AM PC070253.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 42 Staging sample S04 for splitting 12/7/2022 11:30:05 AM PC070254.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 14 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 43 Completed splits of sample S04 12/7/2022 11:36:22 AM PC070255.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 44 Staging sample S05 for splitting 12/7/2022 11:38:47 AM PC070256.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 45 Completed splits of sample S05 12/7/2022 11:45:43 AM PC070257.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 15 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 46 Hazardous waste batch 1798 prior to stabilization in mix tub 12/8/2022 8:34:43 AM PC080258.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 47 Addition of portland cement during hazardous waste stabilization 12/8/2022 9:00:35 AM PC080259.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 48 Addition of lime and ferrous sulfate during hazardous waste stabilization 12/8/2022 9:06:53 AM PC080260.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 16 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 49 Excavator mixing hazardous waste and reagents during stabilization 12/8/2022 9:10:48 AM PC080261.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 50 Contents of mix tub after mixing with excavator in photo 49 12/8/2022 10:08:35 AM PC080262.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 51 Addition of first of five excavator buckets of paper pulp to mix tub during hazardous waste stabilization 12/8/2022 10:12:23 AM PC080263.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 17 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 52 Contents of mix tub after mixing in paper pulp 12/8/2022 10:36:42 AM PC080264.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Photo Number Description Date/Time File Name Photographer Make Model Attributes 53 Mix tub operator sample jar of stabilized waste (left) transferred to amber jar (right) for analysis at third-party laboratory 12/8/2022 10:58:29 AM PC080265.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Attributes 54 Rinsing and decontaminating of mix tub after hazardous waste stabilization 12/8/2022 11:56:34 AM PC080266.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 18 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 55 Hazardous waste satellite accumulation container for laboratory ICP instrument 12/9/2022 11:35:25 AM PC090267.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 56 Satellite container accumulating hazardous PCB and hexane waste in laboratory hood 12/9/2022 11:35:41 AM PC090268.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 57 Satellite container accumulating hazardous waste solid debris in the laboratory 12/9/2022 11:35:56 AM PC090269.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 19 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 58 Two containers accumulating hazardous waste liquids in laboratory hood 12/9/2022 11:36:24 AM PC090270.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 59 Satellite container near tank 2 used to consolidate waste seen in containers in photos 55 and 58 12/9/2022 11:44:32 AM PC090271.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 60 Wastewater centrifuge and solids hopper 12/12/2022 1:56:03 PM PC120272.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 20 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 61 Floor underneath wastewater filter press with visible solids and free liquid 12/12/2022 2:07:11 PM PC120273.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 62 Non-hazardous filter cake in a hopper 12/12/2022 2:07:45 PM PC120274.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 63 Filter press B with visible liquid in drain pan underneath unit 12/12/2022 2:10:56 PM PC120275.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 21 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 64 Filter press B with visible liquid in drain pan underneath unit and filter cake on catwalk 12/12/2022 2:11:21 PM PC120276.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 65 Wastewater hydrocyclone with hopper to accumulate purged solids 12/12/2022 2:28:18 PM PC120277.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 66 Contents of solids hopper in photo 65 12/12/2022 2:28:37 PM PC120278.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 22 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 67 Effluent tank 2B 12/12/2022 2:43:37 PM PC120279.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 68 Discharge pipe from tank 2B 12/12/2022 2:44:07 PM PC120280.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 69 Effluent tank 1B 12/12/2022 2:45:17 PM PC120281.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 23 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 70 Discharge pipe from tank 1B 12/12/2022 2:46:00 PM PC120282.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 71 Empty chemical cans for scrap steel or trash 12/12/2022 2:49:30 PM PC120283.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 Photo Number Description Date/Time File Name Photographer Make Model Attributes 72 Tank 10 12/13/2022 8:50:19 AM PC130284.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 24 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut VP1493 Clean Harbors Bristol Photo Number Description Date/Time File Name Photographer Make Model Attributes 73 Connection underneath tank 10 12/13/2022 8:51:07 AM PC130285.JPG Brian Kennedy OLYMPUS CORPORATION TG-6 NEICVP1493E01 Appendix C Page 25 of 25 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix D NEIC Hardcopy Document Log (1 page) NEICVP1493E01 NEICVP1493E01 wv i.j _c 11RoCofIl_-A_C le- Oocun,bo,.r-+_S& _doLLJ c!}_T!LPJ5Ilf1T_L E Pl_ fl A{i )J (, i) CH0D2 - f//ife_ HL_{..,., - 11c,...-(r,tS a)__t5 J./. Y) CHO 03- F,-ci/;t, .f/_14 6"',J 6J<-h--JLo._,. C /-Io ol{ - 11 !_LT(/1 &_E.Loi,-(_ C'' t (! f--,_J-<-)_ M)e)_ 5)_Cj/OO- v/Jl}f5 _/Yb. C.Hl-f6JS958 {5g_ts) :k)HOO/, . . w11f5 Afc_. kl 1./0J:313 Lf-.gs_)___ ,s) 7)c1100 7 - W_fl f5_ _fj_o._0{ 1. "I 1_91()_8 _( Lf--'-8 )CHcog- Wflf5_ No, CJ-J3g7{3PJA_[? f'e,s)___ 9)CJOD<:l--:._;'lj_x _TU-l_c #-' 21)_ (11 peL) u _1o)u-1010- 1,:1. rH6 Eo-.Je-1.. # n9s.:,._ PJ-fL)- _ _l1) CJ{Qj }_::_Lj)R }hJ. h-,..j, ForM (:.fl,. -0 (.HSliJ.filJlYJ_((il_fj f,-,/..D _/012. - Prof.'l,c fy__,.,ph f,,.,{<f ff'} CJi12':lf>9l46-2_ ULP-9<J) &I/ _IJ)i_HO 13 - fro f:/.( _F-(._,,f /< /J&-lj_ fJJ CH/f'//8Uf> UO fo.jtL) _l)CH__0/'7 - frcf:/,1 Fxa11A ltk t-1 55807-062B_(iJf5>jts)__ J5)cHOl5- froP.I-< n"'fj-L /ci-1 t fN (H&JJ'lf_/j_'L f--"jt.S.)_ _l)CH0/6 - IA/1'1 f5 No. CHJt51'188_{j fiyt1) {l {1 CL-{o/7. M:x 7u( 13..-lt) # 1718 8f pc-tb_et w;)s /' .i,1 !!} f ) - I -=-=c_- - , z5 CJf O / 9 - Of'"';] J.:.r1{ A,(4 ft,, - ro9e.r J.9}cllo 3 - J EJ(_'>,.--if& Jr>C9i-2J {)fl c- e::11-fs__l,1 0.. )to-rl_ ii_) r t../,-Jr .1l}jCl-t0,2.0 iloJ-l ((cv-.f l'ff-(,- ws5 {lA./1 /:5/-,l f-..Jd) )l)CH02(-f}-c_ bfo,}r,J,_.Vl f fur ct-lOD1.._('/>o-j,) .1J)}1 tO 2. 2_ - ( 1--'/ f._,'f?5...__ 1 0Ef__ )jt_ 2!Lzf)ll PCL I1i 2!J/ (Lf-'(j )))G/-fo'l) - W1t l-J<'fri,j 1>-J:,; { tk,:lc,t # 0Y,530JE.fL/;-(S7 P'-1 Pr,N-c # CH1651488 :1'1)1-t C"..Y - )Of (!:cJ< .)cr(u, us +-> (5M<s)__ - - - _'l'i)/-101-soP l1__fJu,_Jv..r<,..f-(bl''j-r). -- , )b1CH07.. SOP ocki,:",Jc} };fri,)J AI\P,!'Js; ":. u" (,rJ fJPf}r.11 .n)cH011 -sor "'J.1:00..c+;v;Jy Y:_"l(11 (t..ff"'-J<-l) -1 CH028- 3 (o-;/-<,,J ble-Le().kS_(i:L f-"'jd f,la-J) 29)cHD'.lq Currt.. 1- T""h. DucripTio,-.,s(tp...5c.) Appendix D 1 of 1 Clean Harbors Environmental Services, Inc. Bristol, Connecticut OOL Appendix E Sample Chain of Custody Record (1 page) NEICVP1493E01 NEICVP1493E01 Appendix E Page 1 of 1 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix F Laboratory Photographs and Sample Physical Description (8 pages) NEICVP1493E01 VP1493 Clean Harbors Bristol File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0341.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0341.JPG Sample Receipt -Locked Cooler File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0342.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0342.JPG Sample Receipt - Locked Cooler NEICVP1493E01 Appendix F Page 1 of 8 Clean Harbors Environmental Services. Inc Bristol, Connecticut File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0343.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 VP1493 Clean Harbors Bristol IMG_0343.JPG Sample Receipt - Samples - COC File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0344.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0344.JPG Sample Receipt - Sample -COC NEICVP1493E01 Appendix F Page 2 of 8 Clean Harbors Environmental Services. Inc Bristol, Connecticut File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0345.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 VP1493 Clean Harbors Bristol IMG_0345.JPG Sample Receipt - COC File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0346.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0346.JPG Sample Receipt - Samples File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0347.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0347.JPG NEICVP1493E01 Appendix F Page 3 of 8 Sample Receipt - Samples Clean Harbors Environmental Services. Inc Bristol, Connecticut File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0348.JPG Sample Receipt 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 VP1493 Clean Harbors Bristol IMG_0348.JPG Sample Receipt - Samples File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0349.JPG Chain of Custody 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0349.JPG Chain of Custody - N14904 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0350.JPG Samples 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0350.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. NEICVP1493E01 Appendix F Page 4 of 8 Samples S01 - S05 Clean Harbors Environmental Services. Inc Bristol, Connecticut VP1493 Clean Harbors Bristol File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0351.JPG Samples 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0351.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S05 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0352.JPG Samples 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0352.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S05 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0353.JPG Samples 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0353.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. NEICVP1493E01 Appendix F Page 5 of 8 Samples S01 - S05 Clean Harbors Environmental Services. Inc Bristol, Connecticut VP1493 Clean Harbors Bristol File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0354.JPG Samples 12/20/2022 Canon Canon PowerShot SX620 HS R Martinez VP1493 IMG_0354.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S05 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0841.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0841.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S05 NEICVP1493E01 Appendix F Page 6 of 8 Clean Harbors Environmental Services. Inc Bristol, Connecticut VP1493 Clean Harbors Bristol File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0842.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0842.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S05 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0843.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0843.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S01 - S03 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0844.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0844.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. NEICVP1493E01 Samples S01 - S04 Appendix F Page 7 of 8 Clean Harbors Environmental Services. Inc Bristol, Connecticut VP1493 Clean Harbors Bristol File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0845.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0845.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S02 - S05 File Name Title Date Stamp Make Model VP1493 Clean Harbors Attributes IMG_0846.JPG Samples 02/09/2023 Canon Canon PowerShot SX740 HS R Martinez VP1493 IMG_0846.JPG Sample Physical Description Solid soil like material with a clay texture. Dark brown in color with off-white fibrous material throughout sample. Tan color clumps of material that break apart with hand pressure. Samples S03 - S05 NEICVP1493E01 Appendix F Page 8 of 8 Clean Harbors Environmental Services. Inc Bristol, Connecticut Appendix G Eversource Waste Material Profile Sheet No. CH8387BWMA (5 pages) NEICVP1493E01 NEICVP1493E01 Appendix G Page 1 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix G Page 2 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix G Page 3 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix G Page 4 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix G Page 5 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix H Stabilization Batch No. 1798 Documentation (8 pages) NEICVP1493E01 NEICVP1493E01 Appendix H Page 1 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 2 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 3 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 4 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 5 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 6 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 7 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix H Page 8 of 8 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix I Select 2022 Stabilization Batch Sheets (12 pages) NEICVP1493E01 NEICVP1493E01 Appendix I Page 1 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 2 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 3 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 4 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 5 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 6 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 7 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 8 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 9 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 10 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 11 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix I Page 12 of 12 Clean Harbors Environmental Services, Inc. Bristol, Connecticut Appendix J Keymark Hazardous Waste eManifest 016377424FLE (1 page) NEICVP1493E01 Please print or type. UNIFORM HAZARDOUS 1. Generator ID Number WASTE MANIFEST NYD003959251 5. Generator's Name and Mailing Address Keymark Corporation PO Box 626 Fonda NY, 12068 Generator's Phone: 518-853-3421 6. Transporter 1 Company Name Clean Harbors Environmental Services, Inc. 7. Transporter 2 Company Name 2. Page 1 of 3. Emergency Response Phone 1 800-483-3718 Form Approved. OMB No. 2050-0039 0DQLIHVW7UDFNLQJ1XPEHU 016377424FLE Generator's Site Address (if different than mailing address) Route 334 Fonda NY, 12068 U.S. EPA ID Number MAD039322250 U.S. EPA ID Number 8. Designated Facility Name and Site Address Clean Harbors of Connecticut Inc 51 Broderick Road Bristol CT, 06010 Facility's Phone: 860-583-8917 9a. 9b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number, HM and Packing Group (if any)) 1. UN1824, SODIUM HYDROXIDE SOLUTION, 8, PG III 2. U.S. EPA ID Number CTD000604488 10. Containers No. Type 1 TT 11. Total Quantity 4300 12. Unit Wt./Vol. G 13. Waste Codes T GENERATOR 3. 4. 14. Special Handling Instructions and Additional Information Line 1: Profile: CH365148B ; TR ANSPORTER INT'L 15. GENERATOR'S/OFFEROR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. If export shipment and I am the Primary Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent. I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true. Generator's/Offeror's Printed/Typed Name Signature Month Day Year DALE RULISON DALE RULISON 12 12 2022 16. International Shipments Import to U.S Transporter signature (for exports only): 17. Transporter Acknowledgment of Receipt of Materials Transporter 1 Printed/Typed Name OAKLIEGH SMITH Export from U.S. Port of entry/exit: _________________________________________________________ 'ate leaving U.S.: Signature OAKLIEGH SMITH Month Day Year 12 12 2022 Transporter 2 Printed/Typed Name Signature Month Day Year 18. Discrepancy 18a. Discrepancy Indication Space 18b. Alternate Facility (or Generator) Quantity Type Residue Partial Rejection Full Rejection Manifest Reference Number: U.S. EPA ID Number DESIGNATED FACILITY Facility's Phone: 18c. Signature of Alternate Facility (or Generator) Month Day Year 19. . Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems) 1. 2. 3. 4. H070 20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a Printed/Typed Name Signature STEVEN BRYLOW STEVEN BRYLOW Month Day Year 12 12 2022 EPA Form 8700-22 (Rev. 12-17) Previous editions are obsolete. NEICVP1493E01 Appendix J Page 1 of 1 DESIGNATED FACILITY TO EPA's e-MANIFEST SYSTEM Clean Harbors Environmental Services, Inc. Bristol. Connecticut Appendix K Keymark Waste Material Profile Sheet No. CH365148B (5 pages) NEICVP1493E01 NEICVP1493E01 Appendix K Page 1 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix K Page 2 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix K Page 3 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix K Page 4 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut NEICVP1493E01 Appendix K Page 5 of 5 Clean Harbors Environmental Services, Inc. Bristol, Connecticut