DSHW-2024-007028

leanHa
o
RE
Clean Harbors Aragonite, LLC
I 1600 North Aptus Road
Aragonite, UT 84029
435.884.8 100
www.cleanharbors.com
luly 1.2024
Sent via email to [e-mail]
Mr. Douglas J. Hansen, Director
Division of Waste Management & Radiation Control
Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Class I Modification to update Personnel Training and the Contingency Plan
Clean Harbors, Aragonite, LLC
uTD98l 552 177
Dear Mr. Hansen.
In accordance with Utah Administrative Code (UAC) R3l5-270-42, Clean Harbors Aragonite,
LLC (CHA) is submitting a Class I permit modification to notifu the director of changes to both
Attachment 4 (Personnel Training) as well as Attachment 6 (Contingency Plan). These changes
fit the description of a Class I Modification under UAC R-315-270-42 Appendix I B.5.b, and
Appendix I B.6.d which state:
l.B.5.b - "Changes in the training plan: Other changes."
I.B.6.d - "Contingency plan: Changes in name, address, or phone number of coordinator or
other persons or agencies identified in lhe plan."
The current personnel training document in Attachment 4 lists our specific course codes that
apply to permit required training. The lacility's new online training management system is
moving away from course codes, so as an alternative CHA will be providing descriptions ofthe
training in a new table and updating the attachment. This portion of the modification will also
shorten the duration of initial RCRA Part B permit training.
The contingency plan does not have any listed contact numbers for the emergency coordinators
in Attachment 6. CHA intends to update this document to provide this information.
Enclosed are the following documents:
. Redline versions of Attachment 4 pages l-5, 7-10
o Redline versions of Attachment 6 pages I and 1l
"People and Technologt L'reating a Better Environment "
r
DSHW-2024-007028
IeanHa
IAJb
o
A notice of the modification request will be mailed to all persons on the faciliry mailing list and
appropriate units of State and local govemment within 90 days, as found in UAC R3l5-270-
a2(a)( I )(ii).
I hereby certifu under penalty ol law that this document was prepared under my direct
supervision in accordance with a system designed to assure that qualified personnel properly
gather and evaluate the information submitted. Based upon my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information
submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of
fine and imprisonment for known violations.
Should you have any questions regarding this matter, please contact me at the number listed
below.
Sincerely.
William L Simmons
Facility GM III
Clean Harbors Aragonite, LLC
I I 600 North Atpus Road
PO Box 1339
Grantsville, Utah 84029- I339
(o) 435.844.8351
(c) 870.310.6029
simmons.william@c Ieanharbors.com
ATTACHMENT 4
PERSONNEL TRAINING
Table of Contents
Introduction1.0
2.0 Outline of Training Program
2.0.1 Aragonite Personnel
2.0.2 Non-Aragonite Personnel
2.1 TrainingReview.............
2.2 Training Personnel Records.............
2.3 TrainingCoordinators.....
2.4 Training for Emergency Response
2.5 TrainingDocumentation.
3.0 Job Titles and Duties
3.1 Relevance ofTraining to Job Position..
List of Tables
Table I - List ofCourses
Table 2 - Required Training
Table 3 - Trainins Descriotions ....9
I
I
I
I
2
2
2
2
2
5
5
4
7
Attachment 4 -- Personnel Training
Clean Harbors Aragonite, LLC
une 30.2024
page l urD98l552l77
1.0 Introduction
Clean Harbors Aragonite (Aragonite) has in-house training programs for all employees. All
personnel receive a general orientation training including first aid and CPR. When personnel are
assigned to their respective groups, they receive specific job-related training. Until an employee
is a qualified duty area operator, he/she must work under the supervision ofa qualified area
operator. All employees must successfully complete the courses in Table 2 prior to working
unsupervised in the job title indicated.
Each department manager is responsible for the training and qualification of the individuals
reporting to him/her. Overall coordination ofthe training program is the responsibility ofthe
Health and Safety Manager.
2.0 Outline of Training Program
2,0.1 AragonitePersonnel
All Aragonite personnel will receive training as noted on Table 2. Also, non-Aragonite
personnel assigned to an Aragonite manager to work under his/her direct supervision (temporary
employees), will have or receive equivalent training as Aragonite personnel for thejob they are
performing. All personnel will have job titles from the list in Table 2 and will be required to
complete the training specified in Table 2.
The required training occurs within six months of date of hire or six months olassignment to
Aragonite or within six months of a new position at Aragonite, whichever is applicable.
Departmental qualification progftrms are not required to be completed within the six months oi
hire or six months after assignment, but the operator must have completed the applicable part of
the departmental qualification program to work a duty area unsupervised. The Explosives
Compliance and Safety training is also not required to be completed within six months of hire or
six months of assignment, but an operator must have completed Explosives Compliance and
Safety training before handling l.3G explosives.
2.0.2 Non-AragonitePersonnel
Additionally, other personnel at the site will be required to receive a level oftraining consistent
with their purpose at the site. These persons include contractors, Clean Harbors employees from
corporate offices or from other facilities, visitors, and any others for whom training would be
necessary. The following outlines the training required for these persons.
If the person will be working in areas where hazardous waste handling occurs, then the minimum
required training will include courses
and the Pre-
project Environmental, Health, and Safety Review. Ifthe person will be using an Aragonite
forklift, then forklift training, eeurse,{C€ee-or a comparable course (an4-{G}i0ii{
appiieable)-is required.
Visitors who may be in areas where hazardous waste handling occurs are not required to have the
training outlined above, provided they are constantly escorted by an appropriately trained
Aragonite employee. Other persons not working in areas where hazardous waste handling
occurs will have training consistent with their task. The minimum training required for each
person will be determined on a case-by-case basis. At a minimum. all contractors, visitors, and
Attachment 4 -- Personnel Training Ju+c-3O;?e?]June 30.20?'l
Clean Harbors Aragonite, LLC page I UTD98l552l77
other non-Aragonite personnel will be required to receive basic orientation on the site, potential
hazards and safety precautions, and evacuation procedures. prior to entering the site. This will
be accomplished with an orientation fi[m and documentation will be maintained on-site.
2.1 Training Review
Some courses require an annual or biennial refresher, such as First Aid and CPR. Annual
refresher courses must be taken in the same quarter ofthe following year ofthe initial training.
That is, if the initial training was January 15, then the refresher training must be taken no later
than the end of the first quarter. The OSHA 29 CFR 1910.120 Refresher (Monthly Modules)
will be completed on a calendar year basis. Explosives Compliance and Safety training must be
completed before an employee handles I .3G explosives. Refresher training for all topics on
Table i occurs as noted.
2.2 Training Personnel Records
Records will be kept in an electronic records training management system (i.e., tM$Oracle or
equivalent program) or in a file assessable at the facility for examination by the State of Utah and
the EPA. Included in these individual employee training records will be:
The minimum training record documentation is described in section 2.5.
Also, available on-site, but not in each training folder. are the duty area rosters by day, the work
orders for the Maintenance Department, the organization chart, and the course content files.
2,3 TrainingCoordinators
The training coordinators for the Aragonite facility are the department managers, or their
designees, who report to the facility general manager.
2.4 Training for Emergency Response
The contingency plan is the basis for emergency response training. Training is coordinated by
the Health and Safety Manager or other qualified persons.
2,5 TrainingDocumentation
Training will primarily be documented in an electronic records training management system
(i.e., tMSQfaq Iq or equivalent program). Other forms oldocumentation will be used (e.g.,
attendance forms, certillcates of completion, computer printouts. etc.) when applicable. e+- +he
Each employee has training records maintained in
an electronic records training management system (i.e., OracletMfi or equivalent program)
which is supplemented by a file maintained by each department, when needed. Training records
on current personnel must be kept until closure ofthe facility; training records on former
employees must be kept for at least three years from the date the employee last worked at the
facility.
Anachment 4 -- Personnel Training
Clean Harbors Aragonite. LLC
June2e,-2elf June 30. 202.1
page 2 UTD9E 1552 r77
Attendance record at training sessions
Qualifi cation cards and examinations
Training received (Summary with title ofcourse and date. Cross-indexed to
course content file)
Previous training and education, i.e., certifications, certificates
To ensure that the training program is effective, and people are properly trained, exams or other
measures of competency are used. If a person fails the exams or otherwise does not meet the
minimum requirements of the training course. additional training will be required before the
person is considered to have completed the course.
The following outlines the requirements for documenting compliance with the training
requirements for non-Aragonite personnel.
For transient goods and services contractors who have received applicable training at other
locations, training records will be available for review on ISN. Ifthe transient goods and
services conlractor is not part of ISN, the employer will provide a letter certifring that this
training has been completed by each of the employees that will be working at the facility. This
letter will be kept en-*i+cq:_qilg. Additionally. if requested by the Director of the Division of
Waste Management and Radiation Control, Aragonite will acquire the records of training for
specific individuals to demonstrate that the required training has indeed been completed.
Training records for Clean Harbors personnel who are not perrnanently assigned to the Aragonite
facility will be provided upon request. When working in areas where waste handling occurs,
they will be assigned ajob title from Table 2 and the training specified in that table will be
required.
Anachment 4 -- Personnel Training
Clean Harbors Aragonite. LLC page 3
Since the Pre-project Environmental, Health, and Safety Review is specific to the Aragonite
facility, this training will be conducted by the facility and records will be maintained on-site
documenting successful completion of the review for each person. However, other training may
be completed at other locations.
For other persons not working in areas where hazardous waste handling occurs, iftraining in the
courses listed in Table I is required, this will be documented and the records of successful
completion ofthe required training will be provided upon request.
+t*ne-:+.+e+;Jule-10,2024
uTD98l552 t77
Table I - List of Courses
Course Title €su+se lDl Duration Frequencl
0sHA 29 ( tjR 19t0.t20 I*till{{}tx
Hle+{xr
2,1hr lnitial
oSHA 29 CIjR 1910.120 Refresher t+Sf2(X]'or
++x!:e0
7-8hr Annual
OSHA 29 CFR 1910.120 Refresher (Monthly
Modules)
H563+r
HS6+04
0.5-rhr
each
CPR and First Aid Hlrl8o llicnnial
Permit Tmining S52e0+acd
sslg]rr
l 6 hr ln ir ial
Permit Training Reliesher Ss:egf-sid
A€1685
0.5- lhr Annual
General Employee Training
Site Orientation SS:++ls I - 1.5 hr lnitial
Industrial Sal'ety sri.21):+r - 1.5 hr ln itirl
Fire Prevention H5(n)3r I - 1.5 hr lnitial
Contingency Plan ss:ll5 I - 1.5 hr lnilial
Annual Relieshcr
. Site Orientation Refreshcr ss:+lH : 0.25 hr
Industrial Sallty Refresher ss?o??:0.25 hr
Fire Prevention Ret'resher Hs6031J :0.25 hr Annual
: 0.25 hr Annual
Compressed Gases ss-+01+:0.5 hr Initial
Vcnting Lincs :0.5 hr 1n il ial
Standard/Dual whccl Forklift 6 8hr lnitial
Standard/Dual Wheel Forkliil Refrcshcr :lhr Annual
Confined Space r+s#lxr 2-2.5hr Initial
Confined Space Rclicshef H56+1|t :lhr Annual
5S:4l r lhr lnitial
Laboratorv Safet\'ss:{{.+2hr lnirial
Explosives Compliance and Safeq l A€1686 I 2hr lnitial - Prior to handling l.lC
lncineration Qualillcation Programa lnitial
Receiving Qualifi cation Program4 lnitial
Maintenancc Qualifi cation Program4 lnitial
I'roduction Qualilication Programa lnitirl
Lab Qualifi cation I'rograma lnitial
Attachment 4 -- Personnel Training
Clean Harbors Aragonite, LLC page 4
Jrrtie:e-?o2lJ une 30. 2024
uTD9Et552l77
Annual
3.5-4hr
Annual
Ann ual
Contingency Plan Refresher ss2{,}:5
sst:.I:
+#xr
AGljOs
Laboratory QC
Notes:
I
2
Course IDs are subject to change but will be associated wilh an equivalent course.
This course is only required for employees that fill out confined space permits. The individuals who are
required to take this training are indicated in the Organizational Chart. All other employees receive
refresher training through HS6304, which is part ofthe required OSHA refresher modules.
Only required for employees that handle l.3G explosives.
Department specific qualifications are developed. tracked, and maintained by each departrnent and will be
made available for review upon request.
3.0 Job Titles and Duties
This section outlines the plant organization and required training.
Thejob titles for the Aragonite site are listed in Table 2. These job titles correlate to job
descriptions ibund in Table i, which are maintained by the department managers. Table 2 also
lists the required training at the facility. A current organization chart is available on-site. The
chart specifies by name which person fills what job title.
For any job title. different training may be required depending on the duty area they are filling.
All departments, except the Maintenance Department, maintain a daily duty roster in their areas
to document which person is filling what duty area per day. When applicable, employees that
handle 1.3G explosives will be documented on each department's dutv roster. The Maintenance
Department maintains records of which employee completes each job through use of the work
order repair system (FAM or equivalent).
3.1 Relevance of Training to Job Position
All employees receive general employee training designed to focus on the overall purpose of the
Aragonite facility.
Employees with specific assignments under the same job title, receive training unique to their
area of responsibility. Specific course and On-the-Job training requirements are defined in each
department's Qualification Program. Qualification Programs are maintained by each
department. Each Qualification Program outlines the administrative and technical training
requirements for each given duty area. In addition, these programs contain guidance 10 ensure
all aspects oftraining are carried out effectively and consistently. Each department's
Qualification Program is available for review on-site.
Employees that handle l.3G explosives must have received clearance from the Bureau of
Alcohol, Tobacco. Firearms and Explosives (ATF) before being allowed to handle the material
Individuals that have received clearance are documented on the ATF License Notice ol
Clearance. The Notice ofClearance is available on-site for review.
For all personnel, except those in the Maintenance Depa(ment. there are specific duty areas to
which they may be assigned. These may change from day-to-day. The training requirements for
a person to be able to fill specific duty areas are specified in the department's Qualification
Program. No person may work unsupervised in one of these duty areas without having
completed the associated required training.
Cross-training is available to enhance career advancement and understanding ofthe entire
incineration system.
Attachment 4 - Personnel Training
Clean Harbors Aragonite, LLC
Jtffie30.3o2fJune30 2024
J
4
page 5 uTD98 | 552177
Courses described in this section are related to safety and waste handling and are offered to
promote compliance with regulations and to aid in loss+ime prevenrion.
Annually, the Managers will review the training program with the General Manager. The annual
review will consist ofevaluating faculty, courses to determine their relevancy and quality,
updates to course niunes and codes, and new or updated job titles. Adjustments will be made as
warranted, and any necessary permit modification request submitted.
Attachment 4 - Personnel Training
Clean Harbors Aragonite, LLC
Jirn{}:H:3June i0.2024
um981552177page 6
I Anachment 4 -- Personnel Training
Clean Harbors Aragonite, LLC
Table 2 - Required Training
JOB TITLE (€!RSE lt)COURSE NAME
Th€ followirg are administrative support
jobs that do not have any contact with
haza rdous waste:
H{-lo8e CPR and First Aid
ss+g]6 Site Orientation
ssae2+Industrial Safetv
s€6€e Fire Prevention
ssJ035 Contingency Plan
ss;eg Site Orientation Refresher
S€.]{4 Industrial Safety Refresher
HS6€e Fire Prevention Refresher
ss.lols Contingency Plan Refiesher
o FacilityAdministrator
. Facility Purchasing Clerk
o Custodian
o Warehouse Technician
o ReceivingCoordinator
o Compliance Guard
o FacilityCroundskeeper
Qualification Program Department specific qualifications if required for job title
The following are technical support jobs
that haYe potential to work around
hazardous waste:
H€3100er{*X2+O0 osHA 29 CFR 1910.120
HC ll)8{l CPR and First Aid
SS300&an*SS3{}ie Permit Training
ssEer6 Site Orientation
lndustrial Safetyss:#+
l+s6ele Fire Prevention
ssae25
I+S230+eri{+230+er
r{E630-l-+{s€e8 OSHA 29 CFR l910. 120 Refresher
SSleekn4.+C|685 Permit Training Refresher
Site Orientation Refresherss:eg
ssr04 lndustrial Safetv Refresher
HS6€e Fire Prevention Refresher
s5:0:5 Contingency Plan Refresher
A,G.I6'8.6 Explosives Compliance and Safety
Qualification Program Department specific qualifications if required for job title
The following are jobs that routinel)
work around hazardous waste:
I#;2+0Oer{*X.l+e0 osl lA 29 cFR I I r 0. t20
HC+08e CPR and First Aid
Ss:000and SAi.lg)Permit Training
ss2s]6 Site Orientation
ss-:o?+Industrial Safety
HS60:e Fire Prevention
Contingency Planss?e2:
page 7
+ffie++S0?3Jute 30-2024
uTD98 t 552r77
r Facility Maintenance Supervisor
. l&E Supervisor
. l&E Technician (l-lll)
o Electrician (l-lll)
. Facility Maintenance Repair (l-lv)
. FaciliU lncineration Supervisor
. Ceneral Manager
. Compliance Manager
o Health & Safety Manager
o lncineration Safety Supervisor
o Training Supervisor
o Facility Engineer
. Facility Incineration Manager
. Operations Manager
. Facility Operations Manager
. Incineration Blends Chemist
. facility Shipping Coordinator
. Facility Foreman Admin
o Facility Maintenance Manager
. Maintenance Planner
Contingency Plan
JOB TITLE COURSE NAME
. ConEol Board Operator (CBO) (l-lll)
. Incineration Operator (l-lll, lA, I B)
. Facility Operations Supervisor
o Facility Foreman
. Facility Technician (l-lV)
o Receiving Chemist (l-lll)
r Receiving Technician (l-lll)
554+16 Compressed Gases
ssi+13 Venting Lines
Standard/Dual Wheel Forklift
HS6+0e Confined Space
*S$0e++-*X2:e0-er
HSffi OSHA 29 CFR 1910.120 Refresher
S.Sae0+-a€#+685 Permit Training Refresher
sseo+7 Site Orientation Refresher
Industrial Safety Refresher
Fire Prevention Refiesher
ss205 Contingency Plan Refresher
A{'S Standard/Dual Wheel Forklift Refresher
HS6f0+Confined Space Refresher
Affi Explosives Compliance and Safety
Qualification Program Department specific qualifications if required for job title
. Laboratory Manager
. Laboratory Supervisor
o Lab Chemist (l-lll)
o Lab Technician ( l-tl)
osHA 29 CFR 1910. t20
CPR and First AidHCIO80
Ss::e0-atldssa$e Permit Training
Site Orientation
Industrial Safety
ss:et6
SW
Fire Prevention
Sg Contingency Plan
ss40l6 Compressed Gases
ss;480 Laboratory QC
SS:88+Laboratory Safety
HS220Oer-+D(230+er
HS€effi OSHA 29 CFR 1910.120 Refresher
SS20Ol-an++GI585 Permit Training Refiesher
S€AE]+Site Orientation Reftesher
ss:o:+lndustrial Safetv Refresher
HS60])Fire Prevention Refresher
Contingency Plan Refresherss305
Qualification Program Department specific qualifi cations if required for job title
I Attachment 4 -- Personnel Training
Clean Harbors Aragonite. LLC
Junele-l024june l0 2024
page 8 uTD98 | 552 t77
€euRss lD
AW
ssJel+
HS60l0
*tS3{00er-ttX2+00
HS5030
Hazardous Waste Onerations and E mersency ResDonse (HAZWOPER) is
a set of cuidelines nroduced and ntained bv the Occuoational Health
and Salbtv Administration (OS HA) which resulates hazardous waste
ns and em services in the United States and its terrie ltc
Personnel hired at the Arasonile Clean Harbors facilitv to work in areas of
tential ex surc to ous n.I e will receive a total of24
WOPER trainin online OL betbre nnln work
topics covered in the 24-Hour HAZWOPER trainin g are those noted within
soecific requlations. The soecific re ulations rvill be divided throuqhout
the vear (monthlv) ir.rto refiesher online courses (Monthly Modules) to
satisf\' the requiremenl lbr the annual reliesher of the HAZWOPER.
All emoloyees at the Araconite Clean Harbors facility are trained in basic
Fi tAi P lannIe use
Automated Extend Defibrillator (AED). This trainins is orovided under the
suidance of a certified instructor under the American Heart Association
and certilication rr ill be renewed even two vears
Permit Part B Trainins RCRA Part B Permit is a lederal permit issued by the Deoartment of Waste
Manasement and Radiation Control (UDEQ/DWMRC) to treat. store. or
dispose of h:rzardous uaste under the Resource Consen'ation and
Recovery ACT (RCRA). This course provides an introduction and
orenieu ofthe site-speciflc administratire and technical conditions and
regulations (Title 40 Code olFederal Resulations (40 CFR)) under which
waste at the Aragonite Clean Harbors faciliw must be manased. Initial
trainins is completed in an instructor led (lLT) classroom settins. and
refresher course is required annuallv via online (OLT).
Permit Part B Traininq
Refresher
Retiesher of RCRA Part B Permit. required annuallv via onlme course
(OLT) for the Aragonite ebao Harbars ajli&.
Site Orientation lntroduction to the Araqonite Clean Harbors facility operations.
I]I n \'1 nlin LT
Industrial Safetr This course is designed to provide operators with site-specific training for
the A ra!,onite ('lean Ilarbors lacili t\in work n lace sa etv n ractlces
hazards. and how to prevenV corre ct such hazards. The course will cover
health and safety programs. fall pro tection. Dersonal Drotective equiDment
(PPE). hazardous material suidance (handling. storage. use and disposal of
material), machine suardins. electrical salety. etc. Course is online (OLT).
and is required annually
I Attachment 4 -- Personnel Training
Clean Harbors Aragonite, LLC
Jttee-le. le3June 30, 2024
page 9 uTD981552177
'l'able 3 - Training Descrintions
Course Title Definition of trainins
osHA 29 CFR 19t0.120
(OSHA 24 BOC)
CPR and First Aid
TSCA Pe rmit Trainine The Toxic Substances Control Act (TSCA) enforced bv the EPA to
reeulate chemical substances and,/ or mixtures to reduce risk to public
health or the environment. This course is an introduction and overview of
the receivine. handling of. and disoosal ofpolychlorinated biphenyls
(PCBs) at the Arasonite Clean Harbors faciliw. The TSCA Permit is found
in Attachment l7 of the Araeonite Clean Harbors facilitv's RCRA Part B
Permit. and therefore the initial course traininq is completed with the initial
trainine of RCRA Part B Permit in an instructor led (lLT) classroom
settins. and then a refresher course required annually via online (OLT).
This is an online course (OLT) that will teach the Aras onite Clean Harbors
facilitv tors about flre safew and fire ex uisher awareness.o nera t1 ng
Refresher course annually.
This is an on-the-iob course (OJ for the Arasonite Clean Harbors
facilitv. that will so over the acron ym P.A.S.S. for how to use a fire
extinsuisher. The course will also provide a si mulation of a small fire, and
operator will demon strate P.A.S.S. to p ut out the simulated fire. This
urse rs re uired for renewal ev tl.rr
This is an onl lne course (OLT )that describes actions to be taken bv
Arasonite Clean Harbors emolovees durin g an emerqency condition to
minimize risk to human health. to the environment and to the DroDert\,. The
course will describe the action to implement the Incident Command
(Emersencv Resoonse/Continsencv Plan) system and also to complv with
OSHA nroc ess sat'et v manas ement of hichlv hazardous materials
(29CFR I 910. I l9). Refresher course annually.
Compressed Gases The Arasonite Clean Harbors lacili ty utilizes many types ofcomDressed
gases. each with its'own hazards and uses. This online course (OLT) is
designed to introduce operators to the container types, gases. storage
requirements. and potential hazards olthe gases that operators will
encounter on-site. No refresher course required
This instructor-led course (lLT) is desiened to provide the Araqonite Clean
Harbors employee with the information and skill they need to safely open
rocess lines and e ul ent. This course also covers the line breaki
policies and Drocedures
Standard/Dual Wheel Forklift This is an on-the-iob course (OJT) that covers the tvDes of forklifts onsite.
all ofthe forklift attachnents and their pertinent use(s). how to chanse/fill
the tuel tanks ofthe forklitts. as well as the inspections and saf-etv
equiDment used w'hile operating the vehicles
Confined SDace This instructor-led course (lLT) is desisned to provide the Arasonite Clean
Harbors employee with the information and skill they need to fulfill the
roles ofConfined Space Entrant and Aftendant. The Clean Harbors
Co Ent I n r
course.co
permrts.
This instructor-led course (ILT) covers Attachment 1 ofthe Clean Harbors
Aragonite RCRA Permit ( Waste Aralysis Plan). as well as Attachment 1
Appendix I (Oualitv Assurance Plan). This trainins ensures that all
emplovees have an understating ofthe quality analysis procedures from
lnl liel samn I fi nal rennrtino
Laboratorv Safett This online course (OLT) is desisned to cover seneral laboratorv safetv.
including the appropriate personal protective equipment (PPE), as well as
what materials the personnel will senerallv be handline and their hazards.
Exolosives Comnliance and
Safetv
This online c OLT is de I to inform to e
hazards and requirements to handle explosives on the properry. This
trainins is onlv required for personnel that will be handlins 1.3G
explosives
I Attachment 4 -- Personnel Training
Clean Harbors Aragonite, LLC
Jljne31]=l+?fJune 30 2024
page l0 1tTDg8t552t77
Fire Prevention
Fire Prevention (Hands-On)
Continsencv Plan
Ventine Lines
Confi ned Space Refresher This instructor-led course (lLT) is designed to provide additional training
to personnel that are resoonsible lor writing confined space entry permits.
Laboratorv OC
ATTACHMENT 6
CONTINGENCY PLAN
Table of Contents
1.0 Facility Information....................
2.0 Purpose
3.0 EmergencyCoordinators
4.0 Definitions
5.0 Implementation of Contingency P1an...................
5.1 AssessmenLNotification.............
5.2 Evacuation Plan...................
5.3 Conlrol Procedures.....................
5.3.1 Spills or Discharges
1
I
I
I
2
3
J
4
4
4
4
4
5
5
5
5
6
6
'7
5.3.1.1 LiquidsandSolids................
5.3.1.2 Gases
5.3.2 Explosions
5.3.3 Fires
6.0 Prevention of Recurrence or Spread of Fires. Explosions. or Releases
7 .0 Storage and Treatment of Spilled or Discharged Liquid and Solid Material
8.0 Post-Emergency Equipment Maintenance......
9.0 EmergencyEquipment
10.0 CoordinationAgreements
ll.0 RequiredReports.............
EMERGENCY COORDINATORS
Attachment 6 - Contingency Plan
Clean Harbors Aragonite, LLC
ll
une 30 l0l4
page i uTD98l552 t77
Facility Name:
Location:
Aftachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC
Clean Harbors Aragonite, LLC
Aragonite, Tooele County, Utah Facility
Clean Harbors Aragonite, LLC
See site plan, drawing D-034-M-001, and plot plan, drawing
D-034-M-002, in Attachment 10
1 1600 North Aptus Road,2 miles south of I-80, Exit 56
The facility is designed as a transfer, storage, and treatment facility ofRCRA and TSCA wastes
and ofnon-hazardous wastes. Waste is stored in either tank farms, container storage buildings,
or other permitted storage areas. The treatment process (high temperature incineration) consists
of a kiln, afterbumer chamber, and gas cleaning train. The facility occupies approximately 3 5
acres of the 1060 acres under Clean Harbors Aragonite (Aragonite) ownership.
2,0 Purpose
This Contingency Plan outlines the emergency procedures that will be employed to minimize
risks to human health and the environment.
The provisions of this plan will be carried out as specified in Section 5.0.
3.0 EmergencyCoordinators
Table 1 at the end of this attachment contains the roles. names and extension numbers ofthose
persons qualified to act as Emergency Coordinator. This list will be updated, as necessary. All
Emergency Coordinators have the authority to call on outside assistance or call upon Aragonite
resources to respond to the emergency and to commit requisite resources to implement this plan.
The duties of the Emergency Coordinator are to assess the situation and take steps necessary to
protect human health and the environment. The Emergency Coordinator is responsible for the
coordination ofcontainment and recovery operations following an emergency or a major
emergency. The responding Emergency Coordinator is responsible for the complete written
report of the incident. The Environmental Manager will be responsible for forwarding the report
to the appropriate regulatory agencies.
4.0 Definitions
Major Emergency: Any explosion, fire. spill, discharge, or natural disaster which threatens
human health or has damaged or destroyed, or threatens to damage or destroy, plant property. or
impair plant operations. or results in a discharge of waste material into the environment and is
page I
1.0 Facilitylnformation
Facility Operator:
Site Plan:
The on-site Shift Supervisor, also identified as the Incinerator Supervisor, is normally the
Emergency Coordinator. When no Shift Supervisor is on site, another qualified individual
(identified with an asterisk (*) on Table l) will be designated as the Emergency Coordinator. At
least one ofthe individuals qualified to act as Emergency Coordinator will be on site at all times.
The Control Board Operator (CBO) will know the identity of the Emergency Coordinator.
June3e. le23June 30. 1024
uTD98t552177
beyond the capability of on-site personnel and equipment to control. A major emergency may
originate from an on-plant event, such as spills, fires, explosions, etc., or an off-plant incident,
such as an aircraft crash on plant property, fire from neighboring property, or natural disasters.
Emergency: Similar to a major emergency except that no outside assistance is needed or
summoned to deal with the situation. This includes spills or discharges outside of containment
areas reportable under section 11.0 of this plan, explosions, or fires (except authorized fires) in
areas where waste management occurs (i.e., areas south of main street, truck staging areas, the
lab, etc.).
Spill or Discharge: A spill is defined as any release which includes any spilling, leaking,
pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or
disposing into the environment. This definition applies to all materials that are released
(i.e., hazardous and non-hazardous waste, raw materials, by-products, residues, etc.).
Specifically excluded from the definition of "release" is any release which does not enter the
environment or any federally permitted release (e.g., permitted air emissions).
Contained Spill or Discharge: A spill or discharge which is contained means that the spill is
contained within an area which provides a barrier to prevent a release from contacting the ground
or surface waters. This includes paved areas where no runoff occurs, secondary containment
structures and the inside ofbuildings.
Emergency Signal: An audible alarm initiated by the Emergency Coordinator, alerting all
personnel on site that an emergency or a major emergency exists. The fire alarm is a siren
(undulating), whereas the plant evacuation signal is a yeow (warbling high-low) blast.
Shutdown of Operations: Curtailing of incinerator operations, with the exception of the air
pollution control system. by stopping all waste feed to the incinerator. Buildings are closed to
prevent wind or rain from entering, and all unloading operations are ceased, as needed.
Maintenance and contractor's machinery will be shut down, as needed.
North Assembly Point: The parking area to the north of the administrative building. Refer to
Drawing D-034-M-005 in Attachment 10.
South Assembly Point: The area south of the plant. Refer to Drawing D-034-M-005 in
Attachment 10.
West Assembly Point: The area west of the plant. Reler to Drawing D-034-M-005 in
Attachment 10.
Authorized Fire: An approved (authorized) firelopen flame within any portion ofthe facility,
such as fire set for fire response training, designated smoking areas, or in the incinerator.
5.0 Implementation of Contingency Plan
The Contingency Plan will be implemented whenever there is a major emergency. emergency,
whenever there is a contained spill or discharge which threatens human health (i.e., a spill or
Attachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC
June-2O;?O23J u n e 30.2024
page 2 uTD98 1552 I 77
discharge resulting in one or more individuals requiring medical treatment or evaluation), or any
other time the Emergency Coordinator feels it is appropriate. The purpose of this Contingency
Plan is to outline the actions which operating personnel will take in response to emergencies,
such as fires, explosions, leaks, spills, natural disasters, or discharges of hazardous substances. It
establishes guidelines for the orderly handling and repo(ing ofemergency situations which
occur or could foreseeably develop at the Aragonite facility.
5.1 Assessment/Notification
The Emergency Coordinator will initiate the appropriate alarm(s) and notify personnel on site of
the situation through the plant PA system and radios.
lncineration operation shall be shut down ii in the opinion ofthe Emergency Coordinator, the
threat to human health or the environment warrants this action. The Emergency Coordinator can
determine if the non-hazardous waste fuel to the kiln and afterbumer should also be cut off.
Should the situation result in the spill or discharge ofhazardous waste, the spill prevention
control and countermeasures procedure shall be followed.
If there is a spill or discharge, the worker(s) discovering it will immediately notify the
Emergency Coordinator and assess the characteristics ofthe spill or discharge and promptly
initiate a plan to stop the source of the leak. The Emergency Coordinator will initiate measures
so as to protect human health and the environment.
Information about waste stored on-site or in-process is tracked in the waste tracking database.
All wastes, either stored or in process, on-site are tracked by facility personnel.
5,2 Evacuation Plan
In the event that an evacuation is necessary, an evacuation signal will be sounded. The
evacuation routes should be upwind or crosswind of the emergency and culminate at the
designated assembly point(s). The CBO, who can be reached by dialing 333, will announce the
appropriate assembly point(s) over the plant PA system and radios. All non-essential personnel,
visitors, and contract personnel shall evacuate the area and assemble at the appropriate assembly
point(s).
Attachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC page 3
Jueef$,4elfJ un e 30. 2024
uTD98l552l77
Any person discovering a situation which may require implementation of the Contingency Plan
(e.g., fires, spills, etc.) shall immediately wam others working nearby and notiry the Emergency
Coordinator or CBO.
The Emergency Coordinator will appraise the situation and determine whether to initiate the
Contingency Plan.
The facility has a system for identifuing everyone within the facility. The designated person at
the assembly point(s) will notifo the Emergency Coordinator ofany personnel that are known to
be missing. Visitors shall be the responsibility oftheir Aragonite contact lor accountability.
5.3 Control Procedures
5.3.1 Spills or Discharges
5.3.1.1 Liquids and Solids
Spilled material will normally be contained in the area where the spill occurs. All spills will be
collected and subsequently transf'erred to approved storage or to a 90-day accumulation area.
Spills may also occur outside ofthe containment berms, such as where the containment area has
been damaged, or the spill occurred when the waste was not in a containment area. All material
will be kept from entering storm drains, water courses, wells. water systems. and navigable
waterways, if possible.
Incompatible wastes are segregated via concrete curbs, containment bays, and fire doors. Thus,
the probability of incompatible wastes commingling is not high, and, if possible. spills will be
segregated and will be cleaned up immediately to prohibit commingling of wastes.
The following steps are taken to contain and clean up spills and discharges:
Dress in appropriate protective equipment
Prevent further leaking by repositioning the container, overpacking, applying a temporary seal to
the leak, or closing master valves or pet cocks on any tanks that might be leaking. Simple
overpacking lor containers is the preferred method.
Prevent the spill from spreading by trenching or encircling the area with a dike olsand,
absorbent material, or, as a last resort, dirt or rags, or other suitable material. Ilthe spill is in an
outside area and it is raining or rain is imminent, cover the spill with plastic sheeling, iffeasible
The spill area is cleaned up and tested for contamination, as appropriate. If the spill area is not
in a containment area (i.e.. on dirt) the contaminated material will be removed.
5.3.1.2 Gases
Compressed gas cylinders determined to be leaking upon arrival or during storage will be
transferred to the glove box at the cylinder feed station and the cylinder contents vented to the
incinerator. lf the incinerator is down at the time the cylinder is leaking, the cylinder will be
transferred to a remote area olthe lacility and allowed to leak until empty.
5.3.2 Explosions
In the event of an explosion, the Emergency Coordinator will immediately shut down all
equipment that may be affected and initiate waste feed cut-offs as necessary. Ifan explosion
occurs where liquids are stored and a spill occurs, procedures lor spill containment will
commence. Explosions involving other plant areas will require evacuation, possible first aid for
injured personnel. securing the area to prevent unauthorized entry, and assessment ofdamages.
Aftachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC
June-f0=?e?3J un e 30 2024
page 4 uTD981552 I 77
In all cases, the Emergency coordinator must be notified as soon as equipment and waste storage
areas are secured.
5.3.3 Fires
In the event of a fire, the automatic sprinkling system and water cannons may be activated. Fire
extinguishers are located in all buildings and on the perimeter of the process equipment. In the
event a fire cannot be extinguished using the stationary equipment, fire hoses may be hooked to
the hydrants or the fire truck and activated. The water falling on the hazardous waste storage
area would primarily be contained through the containment sump systems.
6.0 Prevention of Recurrence or Spread of Fires, Explosions, or Releases
During an emergency, the Emergency Coordinator must take all reasonable measures necessary
to ensure that additional fires. explosions, and releases do not occur, recur, or spread to other
hazardous waste at the facility. These measures must include, where applicable, stopping
processes and operations, collecting and containing release waste, and removing or isolating
containers.
Ifthe facility stops operations in response to a fire, explosion. or release, the Emergency
Coordinator must monitor for leaks. pressure buildup. gas generation, or ruptures in valves.
pipes, or other equipment. wherever this is appropriate.
At least twice a year, plant personnel will have a practice drill on an emergency situation.
In order to protect the facility from the possibility of range fires, a firebreak will surround the
entire facility.
7.0 Storage and Treatment of Spilled or Discharged Liquid and Solid Material
Post event sampling and analyses will be performed after containment, clean-up, and
decontamination procedures have been completed.
All spilted or released material will be managed as hazardous waste.
8.0 Post-EmergencyEquipmentMaintenance
All equipment used during an emergency, major emergency, or contained spill or discharge will
be cleaned or replaced, when necessary, for any future occurrence. The emergency equipment
will be checked as necessary for completeness and operability.
Attachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC page 5
Jtmele;fe33J une 30. 2024
uTD98l552l77
a
a
a
a
a
a
a
9.0 EmergencyEquipment
Section 2 ofthe Preparedness and Prevention Plan, Attachment 5, lists the emergency equipment
at the site along with a physical description and outline of its capabilities. Drawing
D-034-M-005 in Attachment l0 shows the location of the plant emergency equipment.
10.0 CoordinationAgreements
Aragonite has negotiated a written agreement with Tooele County. Representatives of Tooele
County have been contacted, have received a copy ofthis Contingency Plan, and have received a
plant walk+hrough to familiarize them with the plant layout and function. Annual re-orientation
is offered at the plant site for Tooele County representatives. By the terms of the written
agreement, Tooele County has agreed to provide the following services:
Aragonite has also negotiated agreements with other local agencies to provide assistance in the
event that additional equipment and manpower are required at the plant. Representatives of each
agency below have been contacted. Each has received a copy of this Contingency Plan and has
received a plant walk+hrough to familiarize each agency with the plant layout and function.
Also. annual re-orientation is offered at the plant site to the following agencies:
Tooele County Sherifls Department*
Tooele, Utah
435-882-5600
Tooele County Emergency Management
435-833-8100
* The Sherifl s Department is the designated primary coordinating agency.
The following agencies may be used for additional resources should the need arise:
U.S. Bureau of Land Management
Salt Lake District Office
801-539-4001
Mountain West Medical Center
43s-843-3600
University of Utah Hospital
801 -581 -21 2 I
Aftachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC
tunefe*eliJun e i0 :02.1
page 6 uTD98r552|77
Tooele County road maintenance,
Routine law enforcement,
Fire response,
Public health,
Public safety,
Hospital isolation unit, and
Telecommunications.
Airmed
University of Utah
801-58 I -2s00
Spill contractors that may be contacted, as necessary:
Veolia
801-294-2992
Clean Harbors Field Services
435-843-4840
Other emergency assistance and advice can be solicited from
Clean Harbors Transportation Related Emergencies
800-645-8265
National Response Center
U.S. Coast Guard
400 Seventh Street. S.W.
Washington, D.C. 205 l0
800-424-8802
ChemTrec (Chemical Transportation Emergency Center)
800-262-8200
Chlorep, which is part of ChemTrec (Chlorine Incidents)
800-424-9300
National Pesticide Information Center
800-858-7378
This plan will be reviewed annually. updated as necessary, and forwarded to Tooele County
Emergency Management and the Tooele County Health Department.
I 1.0 Required Reports
As required by Utah Admin. Code R3l5-264-56(d) and 40 CFR $264.56(d), for major
emergencies, Aragonite shall immediately notif, the Utah Department of Environmental Quality.
The report will include:
Name and telephone number of reporter;
Name and address of facility;
Time and type of incident, e.g., discharge, fire;
Name and quantity of material(s) involved, to the extent available;
The extent of iniuries, if any; and
a
a
a
a
a
Attachment 6 -- Contingencl Plan
Clean Harbors Aragonite. LLC
Jtme-3$.4e2fJ une 30 2024
page 7 uTDg8 t 552177
. The possible hazards to human health or the environment, outside the facility.
As required by Utah Admin. code R3l5-264-56(i) and 40 cFR 9264.56(i), Aragonite will record
in the operating record any incident that requires implementing this Contingency ptan. In
addition, Aragonite will submit a written report to the Director of the Division of Waste
Management and Radiation control (Director) within l5 days after an incident that required
implementation of the Contingency Plan. The report will include:
a
a
a
a
a
a
a
For spills which require reporting under Utah Admin. Code R3l5-263-30 through 33, Aragonite
shall immediately notit/ the Utah Department of Environmental Quality (UDEQ). The report
will include:
Name, telephone number, and address ofperson responsible for the spill;
Name, title, and telephone number of individual reporting;
Time and date of spill;
Location of spill;
Description contained on the manifest and the amount of material spilled;
Cause ol spill; and
Emergency action taken to minimize the threat to human health and the environment.
The person's name, address. and telephone number:
Date, time, location, and nature of incident;
Name and quantity of material(s) involved;
The extent of injuries, ifany;
An assessment ofactual or potential hazards to human health or the environment, where
this is applicable; and
The estimated quantity and disposition of recovered material that resulted from the
incident.
Contained spills or discharges that do not threaten human health need not be reported. However,
they will be recorded in the operating record.
As required by 40 CFR 9302.6, spills on site involving reportable quantities (RQ) will be
reported to the National Response Center. They will also be reported to the Division of Waste
a
a
a
a
a
a
Aftachment 6 -- Contingency Plan
Clean Harbors Aragonite. LLC
Jutle2{i.+e}i June 30 ,202.1
page E uTD98l552l77
o Name. address. and telephone number ofthe owner or operator:r Name. address, and telephone number ofthe facility;. Date, time, and type of incident;
r Name and quantity of material(s) involved:o The extent ofinjuries, ifany;
. An assessment ofactual or potential hazard to health orthe environment, ando Estimated quantity and disposition ofrecovered material that resulted from the incident.
As required by Utah Admin. Code R3l5-263-33, Aragonite will submit a w tten report to the
Director within l5 days for spills which require reporting under Utah Admin. Code R315-263-30
through 33. This report will include:
a
a
a
a
a
Management and Radiation control, Tooele county office of Engineering and Department of
Emergency Management, and the U.S. EPA. Region Vlll.
As required by Module l. in the event ofa release to the environment from a hazardous waste
tank system. Aragonite will orally notiry the Director within 24 hours and submit a written report
within 30 days. The report will include:
Likely route of migration ofthe releasel
Characteristics ofthe surrounding soil (soil composition, geology, hydrogeology,
climate);
Results ofany monitoring or sampling conducted in connection with the release if
available, or as soon as available;
Proximity to downgradient drinking water, surface water. and populated areas; and
Description of response actions taken or planned.
Ifplant operations were suspended due to Contingency Plan implementation, operations will
resume after plant management has determined that all safety-related questions have been
satisfactorily addressed.
Attachment 6 -- Contingency Plan
Clean Harbors Aragonite, LLC page 9
June30-2e$J u ne 30. 202.1
uTD98l552l77
Reports to the Director will be sent to:
Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake Ciry, Urah 841l4-4880
or
[e-mail]
Reports to EPA Region VIII will be submitted to:
Regional Administrator
U.S. EPA - Region VIII
1595 Wynkoop Street
Denver. Colorado 80202
Reports to Tooele County will be submitted to:
Tooele County Emergency Management
l5 East 100 South
Tooele. Utah 84074
Tooele County Health Department
l5 I North Main Streel
Tooele. Utah 84074
Immediate reporting of certain events to the Utah Department of Environmental Quality, as
outlined in this section, shall be made to the following:
Utah Division of Waste Management and Radiation Control
[phone] (during office hours); or
Utah Depa(ment of Environmental Quality
(801) 536-41 23 (24-hour answering service)
Attachment 6 - Contingency Plan
Clean Harbors Aragonite, LLC page l0
June30;?eliJ un e 30.2024
uTD98l552l77
Table I
EMERGENCY COORDINATORS
ili Incin Man er II t. 8238 or l#l on
Jalr.res Saddler
David Mota Ben Forrester
Control Board Onerato r II Ext.tt 354. or Dial 333. or Channel #l on radio.
*David Yadon +Mark Shoemaker
*Guy Thomas *Jake Vineyard
* l\,!ike Shusart +Cameron Whitehouse
+ Brl ce Hammond *Willard Hanrmond
*Jesse Davis tGarv Johansen
D^r-;^t. a-^,1,*p-,,-- LI^--^-,{i( \l/: ll^-.t Lr^--^-,
* t--..- n-,,:-*/.1^-, I^L^-^^-
{.n,:l,- eL,,,,^i
+ Other personnel qualified to be Emergency Coordinator.
Attachment 6 - Contingency Plan
Clean Harbors Aragonite. LLC page ll
hne-aq:g?3Jue 30,2024
uTD98t 552l77
Facilitv Incineration Suoervisors - Ext. 8352 or Channel #1 on radio.
Patrick Brad-v Jose Silva
*/-r...,'rL^-^^,* I^1.^ 1/:-^.,^-l I:* ct ^ l,lt ^-
*David Yaden *€arnmeron Whitehotrse +Jesus Mota