Facility Audit: Baton Rouge, LA

Transcription

1 Facility Audit: Baton Rouge, LA

2 Table of Contents 1.0 General Company Information... 1 Introduction Facility Information... 2 Facility Overview... 2 Facility Site Plan... 3 Facility History... 4 Site Characterization... 4 Security... 4 Directions to Facility Operating Licenses and Permits... 5 Permit Summary... 5 Principal Operating Licenses/Permits... 5 Principal Contacts/Agencies Process Description... 7 Organic Aqueous Waste Treatment... 7 Inorganic Aqueous Waste Treatment... 7 Container/Tank Storage/Transfer... 8 Railcar Storage/Transfer... 8 Stabilization/Solidification of Characteristic Waste... 8 Container Management... 8 Wastewater Treatment... 9 Waste Analysis Closure Plan Insurance Financial Information Appendix... 11

3 1.0 General Company Information Introduction Clean Harbors is North America s leading provider of environmental, energy and industrial services serving over 50,000 customers, including a majority of the Fortune 500 companies, thousands of smaller private entities and numerous federal, state, provincial and local governmental agencies. Within Clean Harbors Environmental Services, the company offers Technical Services and Field Services. Technical Services provide a broad range of hazardous material management and disposal services including the collection, packaging, recycling, treatment and disposal of hazardous and non-hazardous waste. Field Services provide a wide variety of environmental cleanup services on customer sites or other locations on a scheduled or emergency response basis. Within Clean Harbors Energy & Industrial Services, the company offers Industrial Services and Exploration Services. Industrial Services provide industrial and specialty services, such as highpressure and chemical cleaning, catalyst handling, decoking, material processing and industrial lodging services to refineries, chemical plants, pulp and paper mills, and other industrial facilities. Exploration Services provide exploration, rental, oil and gas field services, and directional boring services to the energy sector serving oil and gas exploration, production, and power generation. Headquartered in Norwell, Massachusetts, Clean Harbors has more than 175 locations, including over 50 waste management facilities, throughout North America in 38 U.S. states, seven Canadian provinces, Mexico and Puerto Rico. The Company also operates international locations in Bulgaria, China, Sweden, Singapore, Thailand and the United Kingdom. For more information, visit 1

4 2.0 Facility Information Facility Overview Clean Harbors Baton Rouge, LLC, a subsidiary of Clean Harbors, Inc. headquartered in Braintree, Massachusetts, owns and operates a hazardous waste storage, treatment and disposal facility located in Baton Rouge, Louisiana. The facility is located on approximately 642 acres two miles north of I-110 on Highway 61 (Scenic Highway) in Baton Rouge, Louisiana. The permitted area includes approximately 192 acres. The facility has a RCRA Part B Permit, a consolidated Air Permit, an NPDES Discharge Permit, as well as a 10-Day Transfer Facility Authorization. The site property averages approximately 75 feet above mean sea level. The surrounding property is a combination of rural, agricultural, residential areas, industrial plants, and forested swamps. Waste management areas at the facility include storage tanks, container storage units, waste treatment tanks, a secure landfill, and numerous closed units. Various hazardous wastes are processed at the facility mostly originating from hazardous waste generators in the South-central United States. Regulated Hazardous Waste Management Units at the Facility Container Storage South Mix Pit (S&E) Dolly Down (30 day Rolloff/Tanker Storage) Landfill (internal use only) Leachate Tank (internal use only) 2

5 Facility Site Plan 3

6 Facility History Prior to 1968, a portion of the property on which the site is located was used as pastureland, while most of the remaining property was woodlands. Efforts were begun in the late 1960 s to develop the property into a waste management complex that included an incinerator, landfarm, landfills, surface impoundments, and various storage units. The site was known as Rollins-Purle and eventually became known as Rollins Environmental Services. A reverse acquisition took place in 1997 whereby Rollins Environmental Services purchased Laidlaw Environmental Services. That transaction was followed in 1998 by the purchase by Laidlaw Environmental Services of Safety- Kleen (wherein Laidlaw assumed the name of Safety-Kleen). Following Safety-Kleen s 2000 bankruptcy declaration, the facility was purchased by Clean Harbors Environmental Services in Site Characterization The total size of the site is approximately six hundred, forty-two (642) acres. It is located two miles north of I-110 on Highway 61 (Scenic Highway) in Baton Rouge, Louisiana. The permitted area includes approximately 192 acres. The site property averages about 75 feet above mean sea level. Security Security is provided at the facility by uniformed guards who are present 24 hours per day. Periodically, the security guards make rounds to ensure that the facility remains secure during off hours. In addition, the entire property is fenced, and the property line is lighted at night. Directions to Facility From New Orleans: Take I-10 west toward Baton Rouge. Exit onto I-110 (spur) toward North Baton Rouge. Follow I-110 to the end and exit toward Natchez (Exit 8B). You will be on Scenic Highway. Continue traveling approximately two miles, and look for the facility s sign on the left. From Lafayette: Take I-10 east toward Baton Rouge. Exit onto I-110 (spur) toward North Baton Rouge. Follow I-110 to the end and exit toward Natchez (Exit 8B). You will be on Scenic Highway. Continue traveling approximately two miles, and look for the facility s sign on the left. 4

7 3.0 Operating Licenses and Permits Permit Summary Clean Harbors Baton Rouge; LLC is currently permitted by the U.S. Environmental Protection Agency-Region 6 and the Louisiana Department of Environmental Quality for the treatment, storage, and disposal of various hazardous and non hazardous wastes. Permit Type/Governing Agency Permit No. Expiration Date RCRA Part B Permit USEPA-Region 6 and LADEQ Air Permit (Small Source) LADEQ LAD OP-RN-1 01/29/ N/A LPDES LADEQ LA /01/ Day Transportation Permit LADEQ LAD /25/2014 Air Permit for Batch Treatment LADEQ 3007 N/A Consolidated Air Permit LADEQ N/A Principal Operating Licenses/Permits Copies of existing permits which detail types of waste management licensed capacities and waste types accepted are available for inspection upon request at the site. Selected permit pages may be attached at the end of this audit under Appendix

8 Principal Contacts/Agencies The list of contacts below can provide additional information regarding the operation and compliance of Clean Harbors Baton Rouge, LLC: Operations Regulatory William J. Clark General Manager Clean Harbors Baton Rouge, LLC Scenic Highway Baton Rouge, LA (225) James Laubsted Environmental Compliance Manager Clean Harbors Baton Rouge, LLC Scenic Highway Baton Rouge, LA (225)

9 4.0 Process Description Organic Aqueous Waste Treatment The facility utilizes highly refined processes that remove heavy metals, suspended solids and organics from liquid wastes and render the effluents safe for discharge into the Mississippi River. Organic Wastewater Treatment - Aqueous wastes that contain metals and/or low organics concentrations are treated via precipitation filtration and activated carbon adsorption. Treated wastes are discharged to the Mississippi River. Metals are precipitated using predetermined treatment chemicals. Sludge and solids are removed via a gravity clarifier and disposed according to applicable regulations. Disposal options include landfill or incineration. Additionally, acids and bases are also neutralized in this system using caustics or acids to adjust the ph to discharge requirements. Organics that are physically separated from waters are analyzed and fuels blended or incinerated. Inorganic Aqueous Waste Treatment The facility utilizes highly refined, multi-stage, chemical precipitation processes that remove heavy metals, suspended solids and residual organics from liquid wastes and render the effluents safe for discharge into municipal sewer systems. Resulting precipitated residues are dewatered with a filter press, and then disposed in an approved landfill. Chemical Precipitation All aqueous wastes are eventually mixed together and processed on a continuous flow basis through a multi-compartmental specially-designed treatment unit, where predetermined amounts of treatment chemicals are added and thoroughly mixed to effect precipitation of heavy metals and coagulation of suspended particles. Coagulated solids are removed in the form of sludge by gravity separation through high efficiency clarifiers. Chemical Oxidation/Reduction Waste needing pretreatment to remove specific contaminants prior to its mixing with other wastes, is batch processed into a specially designed reactor vessel fitted with dual scrubbing towers. Adding chemical reagents specific to the batch as determined by the laboratory simulation as achieves the desired reaction. Upon completion of the reaction, each batch is tested to confirm the end result of the treatment, prior to its transfer into storage tanks for final precipitation treatment. Types of reactions carried out are: oxidation of cyanides and phenols, ammonia removal, chelating agent removal from wastes such as boiler cleaning solutions, reduction of hexavalent chromium to trivalent chromium, acid/base neutralization, etc. Sludge Dewatering/Fixation Sludge produced upon treatment of the aqueous wastes and batch treatment of slurry wastes, are first thickened by gravity. Settled sludge from the bottom of the thickener is pumped to a batch conditioning tank where chemical reagents are added to aid the dewatering and to stabilize the 7

10 constituents of concern. The conditioned sludge is pumped into a recessed chamber filter press to achieve a stable filter cake suitable for landfill. Filtrate produced is sent back to the head of the system for reprocessing while the filter cake is collected into a dump trailer for its disposal into an approved landfill. Acid/Base Neutralization Although this can be a final treatment method, neutralization is often used in conjunction with other treatment processes such as chemical precipitation, phase separation and oxidation/reduction treatment processes. Neutralization involves the addition of an acid or a base to a solution to adjust the ph, usually to a level between 6 and 9. Alkaline neutralization usually involves the addition of Sodium Hydroxide, Potassium Hydroxide or slaked lime to an acidic wastewater to adjust the ph. Likewise, acidic neutralization involves the addition of a concentrated acid (such as Sulfuric Hydrochloric or Nitric) to an alkaline wastewater. Container/Tank Storage/Transfer A wide variety of wastes not acceptable for on-site treatment can be received for consolidation and transfer to other Clean Harbors sites or select audited and approved non company-owned sites. The facility includes storage areas for tanks and containers meeting all RCRA requirements. Railcar Storage/Transfer The facility has the ability to receive, store and ship railcars of hazardous waste. The storage area meets all RCRA requirements. Stabilization/Solidification of Characteristic Waste The facility is authorized to solidify non hazardous waste and stabilize various hazardous wastes. The resulting decharachterized waste is then subject to management in accordance with Subtitle D of RCRA. The physical absorption method of solidification utilizes clay based absorbents and/or synthetic polymers to absorb liquids. Cement type stabilization is the process of blending high calcium-oxide limes with liquids/ solids to generate a gypsum-like solid. The process enables the hazardous waste to be contained in the gypsum-like matrix. These processes are performed in tanks, generally. Container Management Methods of treatment in containers may include neutralization, solidification, product adulteration, carbon adsorption and blending compatible wastes. RCRA regulated liquids are consolidated and shipped off-site for incineration. Container treatment and storage occurs in several permitted areas throughout the facility. 8

11 Wastewater Treatment Wastewater and oil-water emulsions are further treated through an acidification reactor where the oil-water emulsion is chemically "cracked" to promote gravitational separation. An oil-water separator removes oil from the surface returning it to the oil process tanks for future processing. This separator also removes gross solids. In the second stage reactor lime slurry is added to enhance heavy metal precipitation. The final step is to flocculate and separate solids. Solids and sludge are dewatered and the filter cake is disposed of in a licensed landfill. Waste Analysis The Waste Analysis Plan for the facility outlines pre-qualification and on-site acceptance analysis requirements. Pre-Qualification Prior to acceptance and treatment of a specific waste, Waste Material Profile Sheet must be submitted to and approved by Clean Harbors prior to any waste shipment. Waste profile can be completed and submitted online on Clean Harbors website at Once the waste material is accepted for treatment/disposal, this information becomes part of the permanent record in the generator's file and the waste may be scheduled for shipment. On-Site Analysis/Acceptance With each delivery of approved waste, a sample is taken from the load and tested to determine whether the waste is the same as the previously submitted sample. If this analysis differs significantly from the advance sample, the waste will be deemed non-conforming. All nonconforming wastes are further analyzed to determine the best treatment alternatives, whether onsite handling at an adjusted price or transshipment to an alternative treatment facility. The customer is contacted regarding any non-conforming waste and given the option for alternate handling or return of their waste. On specification shipments are processed with one or more of the storage or treatment operations previously identified. 5.0 Closure Plan A comprehensive facility closure plan has been developed in accordance with RCRA requirements and is available at the site for inspection upon request. A Certificate of Insurance guarantees financial assurance for closure. 6.0 Insurance Clean Harbors and its subsidiaries maintain General Liability and Automobile Liability insurance with aggregate limits of $30,000,000. The Company purchases Environmental Impairment Liability insurance for its waste facilities with limits of $30,000,000 insuring the Company against liability for sudden and accidental occurrences from the time waste is picked up from a customer, while being handled at the Company s treatment and transfer facilities, through its delivery to a disposal site. See attached copy of Certificate of Liability Insurance. 9

12 In addition, Clean Harbors purchases an insurance program for Closure (Post-Closure and Corrective Action where so required) in amounts that meet regulatory requirements Clean Harbors Casualty Insurance Program Summary Policy Workers Compensation & Employer s Liability Business Automobile Liability (Includes MCS-90 Endorsement) Comprehensive General Liability Limits of Liability Statutory $1,000,000 Each Accident $1,000,000 Each Occurrence $5,000,000 MCS-90 $1,000,000 Each Occurrence $3,000,000 Aggregate $30,000,000 Each Occurrence $30,000,000 Aggregate $10,000,000 Any one Vessel/Any one Accident $10,000,000 Each Occurrence $10,000,000 Aggregate $1,000,000 Each Occurrence/Any one Vessel $3,000,000 Each Occurrence $6,000,000 Aggregate $30,000,000 Each Occurrence $30,000,000 Aggregate $30,000,000 Limit Excess (Umbrella) Liability (Follow Form) Wharfingers Liability Contractor s Pollution Liability (Off-Site) Protection and Indemnity Environmental Impairment Liability (Coverage for Clean Harbors Facilities) Excess Pollution Liability (Sudden and Accidental Occurrences) Total coverage for Pollution incidences that occur during transportation related activities For more detail concerning Clean Harbors coverage, please contact the Clean Harbors Risk Management Department at (781) Facility Closure Certificates Certificate of Liability Insurance 10

13 7.0 Financial Information Financial information on Clean Harbors and its subsidiaries are available from the Clean Harbors website in the Investor Relations section Appendix If applicable, supporting facility documentation will follow Scenic Highway. Baton Rouge, Louisiana

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