Facility Audit: Coffeyville, KS

Facility Audit: Coffeyville, KS
Table of Contents
1.0 General Company Information ......................................................................................................................... 1
Introduction ......................................................................................................................................................... 1
2.0 Facility Information .......................................................................................................................................... 2
Facility Overview................................................................................................................................................ 2
Facility Site Plan ................................................................................................................................................. 3
Facility History ................................................................................................................................................... 4
Site Characterization ........................................................................................................................................... 4
Security ............................................................................................................................................................... 4
Directions to Facility........................................................................................................................................... 5
3.0 Operating Licenses and Permits........................................................................................................................ 6
Permit Summary ................................................................................................................................................. 6
Principal Operating Licenses/Permits ................................................................................................................. 6
Principal Contacts/Agencies ............................................................................................................................... 7
Compliance ......................................................................................................................................................... 7
4.0 Process Description ........................................................................................................................................... 8
General Description ............................................................................................................................................ 8
Transformer Decommissioning .......................................................................................................................... 8
Chemical Detoxification ..................................................................................................................................... 9
Storage/Transfer ................................................................................................................................................ 10
5.0 Closure Plan .................................................................................................................................................... 10
6.0 Insurance ......................................................................................................................................................... 10
7.0 Financial Information...................................................................................................................................... 12
8.0 Appendix ......................................................................................................................................................... 12
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 www.cleanharbors.com.
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2.0 Facility Information
Facility Overview
Clean Harbors PPM, LLC, a subsidiary of Clean Harbors, Inc. headquartered in Norwell,
Massachusetts, owns and operates a PCB commercial storage and disposal facility in Coffeyville,
KS. The facility also has a RCRA storage permit. This facility is a fully permitted facility by
the U.S. Department of Environmental Protection Agency to receive, store, treat and transfer a
variety of waste streams. The treatment methods utilized at this facility reduce the volume and
toxicity of waste materials.
Facility Name
Clean Harbors PPM, LLC
Location
2474 Hwy 169 North
Coffeyville, KS 67337
County
Montgomery
Facility Owner
Clean Harbors PPM, LLC
2474 Hwy 169 North
Coffeyville, KS 67337
Property Owner
Clean Harbors PPM, LLC
2474 Hwy 169 North
Coffeyville, KS 67337
Facility I.D. No.
KSD981506025
Permit Type
PCB Commercial Storage, PCB Disposal, RCRA Storage
Waste Description
PCBs
Services Provided
Chemical Detoxification of PCB oil
TSCA Commercial Storage, RCRA Storage Capabilities
Transformer Decommissioning
Loading/Unloading capability for all trucks & rail
NELAC certified laboratory
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Facility Site Plan
3
Facility History
Beginning in World War II, the site was part of an Army Air Force Base that was used to train
pilots. Prior to that time, the site had been used for agricultural purposes. Following the war in
the 1940’s, the site went through a number of changes in ownership with the use mainly directed
at aircraft parts manufacturing or similar activities.
The initial waste-related activity at the site started in 1984, when National Electric Inc. initiated a
transformer drain-and-flush business. This basic activity has continued over the years with some
additions under various owners and joint ventures. Incineration was started in 1985; and was
closed in 2001. Chemical detoxification and solvent recovery were started in 1986. Aptus
owned the facility in 1987, Rollins in 1995, Laidlaw in 1997, and Safety-Kleen in 1998. Clean
Harbors purchased the Chemical Services Division, which included this facility from SafetyKleen in 2002.
Site Characterization
The facility receives PCB contaminated waste in a variety of forms including: whole electrical
transformers, capacitors, switches, regulators, bushings, and ballasts; bulk and drummed oils and
wastewaters; and bulk and drummed solid waste such as soil, rocks, and debris.
Operations conducted in the facility consist of three PCB treatment/handling operations, which
include: transformer decommissioning, chemical detoxification, and storage/transfer.
This facility is an EPA-approved storage facility with a TSCA storage capacity of 8,700,000
pounds and a RCRA storage capacity of 107,800 gallons. The chemical detoxification and
transformer decommissioning processes were successfully demonstrated with EPA Region VII
representatives in attendance. The facility is authorized to handle all PCB materials for disposal.
The appropriate disposal/destruction/recycling processes are always selected to ensure
compliance with the regulations and satisfaction for the customer.
The PPM processes are designed for worker and environmental safety. The processes operate at
ambient temperature and pressure. Equipment construction conforms to industrial safety codes,
and equipment hazards are minimized. The detoxification equipment is blanketed with nitrogen
to avoid reaction side products and to eliminate fire hazards.
Security
The facility meets the requirements of 40 CFR 264.14 Security. The facility is completely
surrounded by an 8’ chain link fence with three strands of barbwire along the top of the fence.
There are gates at specific locations throughout the facility that are designated as entrance/exit
ways used by employees or visitors requiring access to the facility. Frequently used gates are set
up with remote controls so that they can be opened or closed from the Security Office or the
Main Office. All other gates are secured by lock and chain and are only used in cases of
emergency or maintenance. Remote cameras are used to monitor the most active gate from the
Main Office. Exterior lights are located throughout the facility and are set up to automatically
light at dusk. Daily inspections of the perimeter of the active area are performed to ensure that
fences and gates are intact and secure. All buildings are individually secured with locks when
they are not occupied. A security service performs security inspections during off-hours on
weekends and holidays. Only key employees are issued keys so that they have access to the
facility.
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Directions to Facility
The facility is located in an industrial park in Montgomery County, near Coffeyville, Kansas.
Coffeyville is located in southeast Kansas approximately 5 miles north of the Oklahoma border.
The facility is located 3.5 miles north of Coffeyville on US Highway 169. The property owned
by the facility consists of 406 acres. The area designated as the active portion of the facility is
equal to 66 acres; surrounding land use is agricultural and light industrial.
Site address: 2474 Highway 169 North
Coffeyville, KS 67337
(620) 251-6380
From the North:
1.
Take US Hwy 169 South from Chanute. The facility is on the left side.
From the South:
2.
Take US Hwy 169 North from Coffeyville. The facility is on the right side.
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3.0 Operating Licenses and Permits
Permit Summary
Clean Harbors PPM, LLC, is currently permitted by the U.S. Environmental Protection Agency
and the Kansas Department of Environmental Protection for the collection, storage, analysis,
treatment, and storage of hazardous waste with subsequent transfer off-site.
Permit Type/Governing Agency
Permit No.
Expiration Date
RCRA (Storage)
KSD 981 506 025
4/12/2020
HWSA (Storage) / USEPA Region 7
KSD 981 506 025
4/12/2020
TSCA (Commercial Storage) / USEPA
Region 7
KSD 981 506 025
04/08/2012
TSCA (Oil Detoxification)/ USEPA
Region 7
KSD 981 506 025
11/24/2018
TSCA (Transformer Decommissioning)/
USEPA Region 7
KSD 981 506 025
04/08/2012
Title V Air Permit/ KDHE
1250049
10/24/2014
NPDES-Stormwater
G-VE09-0006,
KSR000308
Indefinite
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 are
attached at the end of this audit in Section 8.0.
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Principal Contacts/Agencies
The list of contacts below can provide additional information regarding Clean Harbors
Coffeyville facility operations or compliance:
Operations
Compliance
RCRA (Storage)
HWSA
(RCRA Part II)
TSCA
(Commercial Storage)
(Oil Detoxification)
(Transformer
Decommissioning)
Title V (Air Permit)
Stormwater
Rich Bevans, Facility General Manager
Clean Harbors PPM, LLC
2474 Highway 169 North
Coffeyville, KS 67337
(620) 252-1297
Bonnie Martin, Sr. Compliance Manager
Clean Harbors
13733 West 108th Street
Lenexa, KS 66215
(913) 491-4051
Mostafa Kamal
Kansas Department of Health & Environment
1000 SW Jackson, Suite 320
Topeka, KS 66612
(785) 296-1609
Ken Herstowski
USEPA Region 7
901 North 5th Street
Kansas City, KS 66101
(913) 551-7631
Mazzie Talley
USEPA Region 7
901 North 5th Street
Kansas City, KS 66101
(913) 551-7518
Vick Cooper
Kansas Department of Health & Environment
1000 SW Jackson, Suite 310
Topeka, KS 66612
(785) 296-1561
Eric Staab
Kansas Department of Health & Environment
1000 SW Jackson, Suite 420
Topeka, KS 66612
(785) 296-4347
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4.0 Process Description
General Description
The facility receives PCB contaminated waste in a variety of forms including: whole electrical
transformers, capacitors, switches, regulators, bushings, and ballasts; bulk and drummed oils and
wastewaters; and bulk and drummed solid waste such as soil, rocks, and debris.
Operations conducted in the facility consist of three PCB treatment/handling operations, which
include:
transformer decommissioning, chemical detoxification, and storage/transfer.
Approximately 6 million pounds of transformers are decommissioned at this facility per year.
An additional 11 million pounds of liquid and solid materials in bulk or drums are detoxified
and/or stored onsite annually until transferred offsite for recycling or final disposal.
All waste generated from our processes is only disposed of at other Clean Harbors facilities.
Primarily, these facilities include the Clean Harbors incinerator in Deer Park, TX and the Clean
Harbors landfill in Grassy Mountain, UT. Should a need arise to utilize a non-Clean Harbors
facility, company policy dictates that the outside facility must be audited and approved by an
internal audit team prior to any shipments.
Transformer Decommissioning
The Transformer Decommissioning Process is basically a two-step process: a) draining and
flushing, followed by b) dismantling and degreasing. All operations are conducted indoors in the
main process building. When transformers are decommissioned, most of the internal parts are
recycled, along with the empty transformer housing units or “carcasses.” Roughly 80% of a
typical transformer’s weight consists of steel, copper, and/or aluminum, and most parts are
recyclable.
Transformers containing oil with PCB concentrations greater than 50 ppm are decommissioned
using the Hi-Part process. Transformers containing oil with PCB concentrations less than 50 ppm
are decommissioned using the Lo-Part process.
The Hi-Part transformer decommissioning area consists of five major components: Receiving,
Tip and Drain, Dismantling, Degreasing, and Clean Metal Staging. Transformers are unloaded
in the receiving areas utilizing overhead cranes and/or forklifts. The transformers are checked
into inventory and placed into a designated area of the warehouse to wait for processing. The
Tip and Drain Area consists of a process table and storage tanks. This area is used to drain oil
from the transformers. The Dismantling Area consists of two buildings where the transformer
components are dismantled prior to the final degreasing operation. The Degreasing operation
consists of a vapor degreaser where transformer carcasses are cleaned and a tumbler where
transformer components are cleaned. The Clean Metal Staging Area is used to temporarily store
clean metals awaiting sample analysis verification prior to shipment off site for recycling.
The operators begin the Hi-Part decommissioning process by transferring a transformer using
cranes, forklifts, or other appropriate equipment onto one of the two work platforms located on
the Tip and Drain Station. Oil from the transformer is drained into a sump and then pumped into
a storage tank. The oil is either detoxified onsite or incinerated offsite at our Clean Harbors Deer
Park, TX facility.
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The drained transformer is transferred to the Dismantling Area. The Dismantling Area consists
of two small, insulated buildings. The transformer enters a cutting station where welded tops are
cut open along the top welding line using an abrasive blade. The transformer is then moved to
the Hi-Part Disassembly building. The transformer cores are removed and dismantled. The
transformer carcass and metal support bars are sent to the vapor degreaser where they are
immersed in a n-propyl bromide vapor, which thoroughly removes all remaining oils and PCBs.
The dismantled cores are sent through the Granulator. The granulated metals are then sent to the
tumbler where they are washed with n-propyl bromide solvent. The cleaned metals are staged in
the Clean Metals area to await sample verification prior to being sent offsite to a secondary
smelter. The spent solvent is recovered onsite through the use of a distillation column and a
reclaimer. The still bottoms, which result from this solvent recovery process, are incinerated at
our Clean Harbors Deer Park, TX facility.
The Lo-Part decommissioning area consists of the Lo-Part Aqueous Washer. A transformer
classified as Lo-Part is placed on a roller conveyor and the oil is decanted off into a storage tank.
The oil is either detoxified onsite or incinerated offsite at our Clean Harbors Deer Park, TX
facility.
The transformer is then cleaned utilizing the Lo-Part Aqueous Washer. The Lo-Part Aqueous
Washer utilizes a hot aqueous/soap solution, which is sprayed through nozzles inside an
enclosure. The water collects in the bottom of the enclosure. The solution is filtered, the pH is
adjusted, and metals precipitated out of solution. The solid residues are incinerated at our Clean
Harbors Deer Park, TX facility. The remaining solution is recycled for re-use. The resulting
clean transformer will be transferred to the Clean Metals area to await sample verification prior
to shipment offsite to a secondary smelter.
Chemical Detoxification
The dielectric fluid (oil) drained from transformers with PCB concentrations amenable for
detoxification (<4,100 ppm) can be sent to the facility’s detoxification unit to remove the PCBs.
The detoxification process is an EPA approved alternative treatment for the destruction of the
polychlorinated biphenyls (PCB) in oil. This alternative treatment process renders the oil nonPCB, which then allows the oil to be recycled back into the secondary oil market. The
detoxification process consists of three parts: pre-treatment, decontamination, and clarification.
In the pre-treatment portion of the process, a batch of oil has the water content reduced to
acceptable levels using a vacuum drying system. In the second step, decontamination, the PCBs
are destroyed through the use of elemental sodium in a non-thermal chemical method. A sodium
reagent is added stepwise (under a dry nitrogen atmosphere) to PCB-contaminated oil at a
nominal temperature of 60ºF and atmospheric pressure. A mixing prop agitates the mixture until
sample analysis verifies that the PCB concentration is <2 ppm. Mixing time is dependent on the
PCB concentration in the contaminated oil. Higher PCB concentrations require longer mixing
times.
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Another tank is used to hold the detoxified oil while the excess sodium reagent is neutralized by
the addition of water. The reaction produces two separate streams: clean oil (PCB concentration
<2 ppm) and caustic brine. The clean oil is clarified using a variety of filters to remove any
sludge or solids in the oil. The clarified clean oil is pumped into any of nine clean oil tanks
located inside the main warehouse building. Tanker trucks and rail cars are periodically loaded
from these tanks and the clean oil transported to companies that buy waste oil for the purposes of
waste derived fuel or oil feed stock. The caustic brine is shipped off-site to be recycled in a
neutralization process.
Storage/Transfer
The facility is capable of receiving PCB contaminated waste in a variety of forms including:
whole electrical transformers, capacitors, bushings, switches, regulators, and ballasts; bulk and
drummed oils and wastewaters; and bulk and drummed solid waste such as soil, rocks, and
debris. The facility offers transloading capabilities should a generator prefer their waste to be
incinerated at a TSCA-approved Clean Harbors incinerator in either Deer Park, TX or Aragonite,
UT; or landfilled at the TSCA-approved Clean Harbors landfill in Grassy Mountain, UT.
5.0 Closure Plan
Comprehensive facility closure plans have been developed in accordance with RCRA and TSCA
requirements and are available at the site for inspection upon request. Certificates of Insurance
guarantee 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.
In addition, Clean Harbors purchases an insurance program for Closure (Post-Closure and
Corrective Action where so required) in amounts that meet regulatory requirements.
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Clean Harbors Casualty Insurance Program Summary
Policy
Limits of Liability
Workers Compensation & Employer’s
Liability
Statutory
$1,000,000 Each Accident
Business Automobile Liability
(Includes MCS-90 Endorsement)
$1,000,000 Each Occurrence
$5,000,000 MCS-90
Comprehensive General Liability
$1,000,000 Each Occurrence
$3,000,000 Aggregate
Excess (Umbrella) Liability
(Follow Form)
$30,000,000 Each Occurrence
$30,000,000 Aggregate
Wharfingers Liability
$10,000,000 Any one Vessel/Any one Accident
Contractor’s Pollution Liability
(Off-Site)
$10,000,000 Each Occurrence
$10,000,000 Aggregate
Protection and Indemnity
$1,000,000 Each Occurrence/Any one Vessel
Environmental Impairment Liability
(Coverage for Clean Harbors Facilities)
$3,000,000 Each Occurrence
$6,000,000 Aggregate
Excess Pollution Liability
(Sudden and Accidental Occurrences)
$30,000,000 Each Occurrence
$30,000,000 Aggregate
Total coverage for Pollution incidences that
occur during transportation related activities
$30,000,000 Limit
For more detail concerning Clean Harbors’ coverage, please contact the Clean Harbors Risk
Management Department at (781) 792-5000.
Facility Closure Certificates
http://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=640&ft=1
Certificate of Liability Insurance
http://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=98&ft=1
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7.0 Financial Information
Financial information on Clean Harbors and its subsidiaries are available from the Clean Harbors
website in the Investor Relations section.
http://www.cleanharbors.com/investor_relations/investment_materials.html
8.0 Appendix
If applicable, supporting facility documentation will follow.
2474 Hwy 169 Coffeeville, KS 67337
1-800-248-0442 www.cleanharbors.com
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