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Home My WebLink AboutDSHW-2024-007503 DSHW-2024-007503 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. 711 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director July 29, 2024 William Simmons, Facility General Manager Clean Harbors Aragonite, LLC P.O. Box 1339 Grantsville, UT 84029-1339 RE: Class 1 Modification – Update Personnel Training and Contingency Plans UTD981552177 Dear Mr. Simmons: On July 1, 2024, Clean Harbors Aragonite (Aragonite) submitted a Class 1 permit modification request providing notification of updates to the Personnel Training and Contingency Plans in the permit. Specifically, the course numbers were removed from Personnel Training and were replaced by course narrative descriptions and contact information was updated for Emergency Coordinators in the Contingency Plan. The modification request has been reviewed and the applicable changes have been incorporated into the permit as enclosed. Aragonite should update its copy of the permit by making the following changes: • Replace Attachment 4 - Personnel Training with the enclosed copy. • Replace Attachment 6 - Contingency Plan with the enclosed copy. Also enclosed is an updated copy of the List of Permit Revisions. If you have any questions, please call Gabby Marinick at 385-499-0172. Sincerely, Douglas J. Hansen, Director Division of Waste Management and Radiation Control (Over) DJH/BAS/wa Enclosures: Attachment 4 - Personnel Training (DSHW-2012-011641) Attachment 6 - Contingency Plan (DSHW-2012-011644) List of Permit Revisions (DSHW-2023-005042) c: Jeff Coombs, Health Officer, Tooele County Health Department Bryan Slade, Environmental Health Director, Tooele County Health Department Annette Maxwell, U.S. EPA, Region 8 Natalie Cannon, U.S. EPA, Region 8 Bryan Lunt, Facility Operations Manager, Clean Harbors Aragonite (Email) Ken Banks, Senior Environmental Compliance Manager, Clean Harbors Aragonite (Email) Gabrielle Marinick, Division of Waste Management and Radiation Control, UDEQ Jordan Payne, Division of Waste Management and Radiation Control, UDEQ Kaci McNeill, Division of Waste Management and Radiation Control, UDEQ ATTACHMENT 4 PERSONNEL TRAINING Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page i UTD981552177 Table of Contents 1.0 Introduction ......................................................................................................................... 1 2.0 Outline of Training Program ............................................................................................... 1 2.0.1 Aragonite Personnel .......................................................................................... 1 2.0.2 Non-Aragonite Personnel.................................................................................. 1 2.1 Training Review...................................................................................................... 2 2.2 Training Personnel Records .................................................................................... 2 2.3 Training Coordinators ............................................................................................. 2 2.4 Training for Emergency Response .......................................................................... 2 2.5 Training Documentation ......................................................................................... 2 3.0 Job Titles and Duties ........................................................................................................... 5 3.1 Relevance of Training to Job Position .................................................................... 5 List of Tables Table 1 - List of Courses ..................................................................................................................4 Table 2 - Required Training .............................................................................................................7 Table 3 - Training Descriptions .......................................................................................................9 Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 1 UTD981552177 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 of a 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 of the training program is the responsibility of the Health and Safety Manager. 2.0 Outline of Training Program 2.0.1 Aragonite Personnel 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 the job 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 of assignment to Aragonite or within six months of a new position at Aragonite, whichever is applicable. Departmental qualification programs are not required to be completed within the six months of 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 1.3G explosives. 2.0.2 Non-Aragonite Personnel Additionally, other personnel at the site will be required to receive a level of training 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 OSHA 29 CFR 1910.120 Training, or its refresher course (if applicable) and the Pre-project Environmental, Health, and Safety Review. If the person will be using an Aragonite forklift, then forklift training, course or a comparable course 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 other non-Aragonite personnel will be required to receive basic orientation on the site, potential Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 2 UTD981552177 hazards and safety precautions, and evacuation procedures, prior to entering the site. This will be accomplished with an orientation film 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 of the following year of the 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 1.3G explosives. Refresher training for all topics on Table 1 occurs as noted. 2.2 Training Personnel Records Records will be kept in an electronic records training management system (i.e., 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: - Attendance record at training sessions - Qualification cards and examinations - Training received (Summary with title of course and date. Cross-indexed to course content file) - Previous training and education, i.e., certifications, certificates 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 Training Coordinators 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 Training Documentation Training will primarily be documented in an electronic records training management system (i.e., Oracle or equivalent program). Other forms of documentation will be used (e.g., attendance forms, certificates of completion, computer printouts, etc.) when applicable. Each employee has training records maintained in an electronic records training management system (i.e., Oracle 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 of the facility; training records on former employees must be kept for at least three years from the date the employee last worked at the facility. 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 Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 3 UTD981552177 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. 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 transient goods and services contractors who have received applicable training at other locations, training records will be available for review on ISN. If the transient goods and services contractor is not part of ISN, the employer will provide a letter certifying that this training has been completed by each of the employees that will be working at the facility. This letter will be kept on site. 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 permanently assigned to the Aragonite facility will be provided upon request. When working in areas where waste handling occurs, they will be assigned a job title from Table 2 and the training specified in that table will be required. For other persons not working in areas where hazardous waste handling occurs, if training in the courses listed in Table 1 is required, this will be documented and the records of successful completion of the required training will be provided upon request. Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 4 UTD981552177 Table 1 - List of Courses Course Title Duration Frequency OSHA 29 CFR 1910.120 24 hr Initial OSHA 29 CFR 1910.120 Refresher 7 - 8 hr Annual OSHA 29 CFR 1910.120 Refresher (Monthly Modules) 0.5 - 1 hr each Annual CPR and First Aid 3.5 - 4 hr Biennial Permit Part B and TSCA Training 4 -6 hr Initial Permit Part B and TSCA Training Refresher 0.5 - 1 hr Annual General Employee Training • Site Orientation 1 - 1.5 hr Initial • Industrial Safety 1 - 1.5 hr Initial • Fire Prevention 1 - 1.5 hr Initial Triennial - Hands-On Fire Extinguisher Training • Contingency Plan 1 - 1.5 hr Initial Annual Refresher • Site Orientation Refresher ≈ 0.25 hr Annual • Industrial Safety Refresher ≈ 0.25 hr Annual • Fire Prevention Refresher ≈ 0.25 hr Annual • Contingency Plan Refresher ≈ 0.25 hr Annual Compressed Gases ≈ 0.5 hr Initial Venting Lines ≈ 0.5 hr Initial Standard/Dual Wheel Forklift 6 – 8 hr Initial Standard/Dual Wheel Forklift Refresher ≈ 1 hr Annual Confined Space 2 - 2.5 hr Initial Confined Space Refresher1 ≈ 1 hr Annual Laboratory QC 2 hr Initial Laboratory Safety 2 hr Initial Explosives Compliance and Safety2 1 – 2 hr Initial – Prior to handling 1.3G Incineration Qualification Program3 - Initial Receiving Qualification Program3 - Initial Maintenance Qualification Program3 - Initial Production Qualification Program3 - Initial Lab Qualification Program3 - Initial Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 5 UTD981552177 Notes: 1 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 the required OSHA refresher modules. 2 Only required for employees that handle 1.3G explosives. 3 Department specific qualifications are developed, tracked, and maintained by each department and will be made available for review upon request. 3.0 Job Titles and Duties This section outlines the plant organization and required training. The job titles for the Aragonite site are listed in Table 2. These job titles correlate to job descriptions found in Table 3, 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 duty 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 to ensure all aspects of training are carried out effectively and consistently. Each department’s Qualification Program is available for review on-site. Employees that handle 1.3G 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 of Clearance. The Notice of Clearance is available on-site for review. For all personnel, except those in the Maintenance Department, 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 of the entire incineration system. Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 6 UTD981552177 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-time prevention. Annually, the Managers will review the training program with the General Manager. The annual review will consist of evaluating faculty, courses to determine their relevancy and quality, updates to course names 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 July 2024 Clean Harbors Aragonite, LLC page 7 UTD981552177 Table 2 - Required Training JOB TITLE COURSE TITLE The following are administrative support jobs that do not have any contact with hazardous waste: CPR and First Aid • Facility Administrator Site Orientation • Facility Purchasing Clerk Industrial Safety • Custodian Fire Prevention • Warehouse Technician Contingency Plan • Receiving Coordinator Site Orientation Refresher • Compliance Guard Industrial Safety Refresher • Facility Groundskeeper Fire Prevention Refresher Contingency Plan Refresher Qualification Program (Department specific qualifications if required for job title) The following are technical support jobs that have potential to work around hazardous waste: OSHA 29 CFR 1910.120 • General Manager CPR and First Aid • Compliance Manager Permit Training • Health & Safety Manager Site Orientation • Incineration Safety Supervisor Industrial Safety • Training Supervisor Fire Prevention • Facility Engineer Contingency Plan • Facility Incineration Manager OSHA 29 CFR 1910.120 Refresher • Operations Manager Permit Training Refresher • Facility Operations Manager Site Orientation Refresher • Incineration Blends Chemist Industrial Safety Refresher • Facility Shipping Coordinator Fire Prevention Refresher • Facility Foreman Admin Contingency Plan Refresher • Facility Maintenance Manager Explosives Compliance and Safety • Maintenance Planner Qualification Program (Department specific qualifications if required for job title) The following are jobs that routinely work around hazardous waste: OSHA 29 CFR 1910.120 • Facility Maintenance Supervisor CPR and First Aid • I&E Supervisor Permit Training • I&E Technician (I-III) Site Orientation • Electrician (I-III) Industrial Safety • Facility Maintenance Repair (I-IV) Fire Prevention • Facility Incineration Supervisor Contingency Plan Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 8 UTD981552177 JOB TITLE COURSE TITLE • Control Board Operator (CBO) (I-III) Compressed Gases • Incineration Operator (I-III, 1A, 1B) Venting Lines • Facility Operations Supervisor Standard/Dual Wheel Forklift • Facility Foreman Confined Space • Facility Technician (I-IV) OSHA 29 CFR 1910.120 Refresher • Receiving Chemist (I-III) Permit Training Refresher • Receiving Technician (I-III) Site Orientation Refresher Industrial Safety Refresher Fire Prevention Refresher Contingency Plan Refresher Standard/Dual Wheel Forklift Refresher Confined Space Refresher Explosives Compliance and Safety Qualification Program (Department specific qualifications if required for job title) OSHA 29 CFR 1910.120 • Laboratory Manager CPR and First Aid • Laboratory Supervisor Permit Training • Lab Chemist (I-III) Site Orientation • Lab Technician (I-II) Industrial Safety Fire Prevention Contingency Plan Compressed Gases Laboratory QC Laboratory Safety OSHA 29 CFR 1910.120 Refresher Permit Training Refresher Site Orientation Refresher Industrial Safety Refresher Fire Prevention Refresher Contingency Plan Refresher Qualification Program (Department specific qualifications if required for job title) Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 9 UTD981552177 Table 3 - Training Descriptions Course Title Description of Training OSHA 29 CFR 1910.120 (OSHA 24 BOC) Hazardous Waste Operations and Emergency Response (HAZWOPER) is a set of guidelines produced and maintained by the Occupational Health and Safety Administration (OSHA) which regulates hazardous waste operations and emergency services in the United States and its territories. Personnel hired at the Aragon ite Clean Harbors facility to work in areas of potential exposure to hazardous materials or waste will receive a total of 24 hours of HAZWOPER training online (O LT) before beginning work. The topics covered in the 24-Hour HAZWOPER training are those noted within specific regulations. The specific regulations will be divided throughout the year (monthly) into refresher online courses (Monthly Modules) to satisfy the requirement for the annual refresher of the HAZWOPER. CPR and First Aid All employees at the Aragonite Clean Harbors facility are trained in basic First Aid/Cardiopulmonary Resuscitation (CPR) and the use of an Automated External Defibrillator (AED). This training is provided under the guidance of a certified instructor under the American Heart Association and certification will be renewed every two years. Permit Part B and TSCA Permit Training The RCRA Part B permit is a State permit issued by the Division of Waste Management and Radiation Control (DWMRC) to treat, store, or dispose of hazardous waste under the Resource Conservation and Recovery Act (RCRA). This course provides an introduction and overview of the site-specific administrative and technical conditions and regulations (Title 40 Code of Regulations (40 CFR) and State of Utah Administrative Rules) under which waste at the Aragonite Clean Harbors facility must be managed. Initial training is completed in an instructor led (ILT) classroom setting, and a refresher course is required annually via online (OLT). The Toxic Substances Control Act (TSCA) enforced by the EPA , with portions handled by the State through a coordinated approval, to regulate certain substances and/or mixtures to reduce risk to public health and the environment. This course is an introduction and overview of the receiving, handling, and disposal of polychlorinated biphenyls (PCBs) at the Aragonite Clean Harbors facility. The TSCA requirements are found in Attachment l7 of the Aragonite Clean Harbors facility RCRA Part B State Permit, and the initial course is completed with the initial training on the RCRA Part B Permit in an instructor led (ILT) classroom setting and then a refresher course is required annually via online (OLT). Permit Part B and TSCA Permit Training Refresher Refresher of RCRA Part B Permit and TSCA permit, required annually via online course (OLT) for the Aragonite Clean Harbors facility. Site Orientation Introduction to the Aragonite Clean Harbors facility operations, management, and safety via online (OLT). Industrial Safety This course is designed to provide operators with site-specific training for the Aragonite Clean Harbors facility in workplace safety practices, hazards, and how to prevent/correct such hazards. The course will cover health and safety programs, fall protection, personal protective equipment (PPE), h azardous material guidance (handling, storage, use, and disposal of material), machine guarding, electrical safety, etc. Course is online (OLT), and is required annually Fire Prevention (Including Hands-On) This is an online course (OLT) that will teach the Aragonite Clean Harbors facility operators about fire safety and fire extinguisher awareness. The “Hands-On” training is an on-the-job course (OJT) for the Aragonite Clean Harbors facility that will go over the acronym P.A.S.S. for how to use a fire extinguisher. The course will also provide a simulation of a small fire, and the operator will demonstrate P.A.S.S. to put out the simulated fire. This course is required for renewal every three years. Attachment 4 -- Personnel Training July 2024 Clean Harbors Aragonite, LLC page 10 UTD981552177 Course Title Description of Training Fire Prevention Refresher This is a refresher course for the Clean Harbors Aragonite Facility personnel on fire safety and fire extinguisher courses. Refresher course is required annually. Contingency Plan This is an online course (OLT) that describes actions to be taken by Aragonite Clean Harbors employees during an emergency condition to minimize risk to human health, to the environment, and to the property. The course describes the action to implement the Incident Command (Emergency Response/Contingency Plan) system and also to comply with OSHA process safety management of highly hazardous chemicals (29 CFR 1920.119). Refresher course annually. Compressed Gases The Aragonite Clean Harbors facility utilizes many types of compressed 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 of the gases that operators will encounter on-site. No refresher course required. Venting Lines This instructor-led course (ILT) is designed to provide the Aragonite Clean Harbors employee with the information and skill they need to safely open process lines and equipment. This course also covers the line breaking policies and procedures. Standard/Dual Wheel Forklift This is an on-the-job course (OJT) that covers the types of forklifts onsite, all of the forklift attachments and their pertinent use(s), how to change/fill the fuel tanks of the forklifts as well as the inspections and safety equipment used while operating the vehicles. Standard/Dual Wheel Forklift Refresher This is an annual refresher training for the on-the-job course (OJT) that covers the types of forklifts onsite, all of the forklift attachments and their pertinent use(s), how to change/fill the fuel tanks of the forklifts, as well as the inspections and safety equipment used while operating the vehicles. Confined Space This instructor-led course (ILT) is designed to provide the Aragonite Clean Harbors employee with the information and skill they need to fulfill the roles of Confined Space Entrant and Attendant. The Clean Harbors Confined Space Entry Standard is used as the source content for this course. A refresher course is available but only required for those who write confined space permits. Confined Space Refresher This instructor-led course (ILT) is designed to provide additional training to personnel that are responsible for writing confined space entry permits. Laboratory QC This instructor-led course (ILT) covers Attachment 1 of the Clean Harbors Aragonite RCRA Permit (Waste Analysis Plan), as well as Attachment 1 Appendix 1 (Quality Assurance Plan). This training ensures that all employees have an understanding of the quality analysis procedures from initial sampling to final reporting. Laboratory Safety This online course (OLT) is designed to cover general laboratory safet y, including the appropriate personal protective equipment (PPE) to be used, as well as what materials the personnel will generally be handling and its hazards. Explosives Compliance and Safety This online (OLT) course is designed to inform operators of both the hazards and the requirements when handling explosives on the property. This training is only required for personnel that will be handling 1.3G explosives. ATTACHMENT 6 CONTINGENCY PLAN Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page i UTD981552177 Table of Contents 1.0 Facility Information .............................................................................................................. 1 2.0 Purpose .................................................................................................................................. 1 3.0 Emergency Coordinators ...................................................................................................... 1 4.0 Definitions............................................................................................................................. 1 5.0 Implementation of Contingency Plan ................................................................................... 2 5.1 Assessment/Notification .................................................................................................... 3 5.2 Evacuation Plan ................................................................................................................. 3 5.3 Control Procedures ............................................................................................................ 4 5.3.1 Spills or Discharges .................................................................................................... 4 5.3.1.1 Liquids and Solids ................................................................................................ 4 5.3.1.2 Gases .................................................................................................................... 4 5.3.2 Explosions ................................................................................................................... 4 5.3.3 Fires............................................................................................................................. 5 6.0 Prevention of Recurrence or Spread of Fires, Explosions, or Releases ................................ 5 7.0 Storage and Treatment of Spilled or Discharged Liquid and Solid Material ....................... 5 8.0 Post-Emergency Equipment Maintenance ............................................................................ 5 9.0 Emergency Equipment .......................................................................................................... 6 10.0 Coordination Agreements .................................................................................................. 6 11.0 Required Reports ............................................................................................................... 7 EMERGENCY COORDINATORS ............................................................................................. 11 Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 1 UTD981552177 1.0 Facility Information Facility Name: Clean Harbors Aragonite, LLC Aragonite, Tooele County, Utah Facility Facility Operator: Clean Harbors Aragonite, LLC Site Plan: See site plan, drawing D-034-M-001, and plot plan, drawing D-034-M-002, in Attachment 10 Location: 11600 North Aptus Road, 2 miles south of I-80, Exit 56 The facility is designed as a transfer, storage, and treatment facility of RCRA and TSCA wastes and of non-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, afterburner chamber, and gas cleaning train. The facility occupies approximately 35 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 Emergency Coordinators Table 1 at the end of this attachment contains the roles, names, and extension numbers of those 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 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 1) will be designated as the Emergency Coordinator. At least one of the 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. 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 of containment 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 Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 2 UTD981552177 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 of buildings. 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. Refer to Drawing D-034-M-005 in Attachment 10. Authorized Fire: An approved (authorized) fire/open flame within any portion of the 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 July 2024 Clean Harbors Aragonite, LLC page 3 UTD981552177 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 reporting of emergency situations which occur or could foreseeably develop at the Aragonite facility. 5.1 Assessment/Notification Any person discovering a situation which may require implementation of the Contingency Plan (e.g., fires, spills, etc.) shall immediately warn others working nearby and notify the Emergency Coordinator or CBO. The Emergency Coordinator will appraise the situation and determine whether to initiate the Contingency Plan. The Emergency Coordinator will initiate the appropriate alarm(s) and notify personnel on site of the situation through the plant PA system and radios. Incineration operation shall be shut down if, in the opinion of the 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 afterburner should also be cut off. Should the situation result in the spill or discharge of hazardous 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 of the 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). The facility has a system for identifying everyone within the facility. The designated person at the assembly point(s) will notify the Emergency Coordinator of any personnel that are known to be missing. Visitors shall be the responsibility of their Aragonite contact for accountability. Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 4 UTD981552177 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 transferred to approved storage or to a 90-day accumulation area. Spills may also occur outside of the 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 for containers is the preferred method. Prevent the spill from spreading by trenching or encircling the area with a dike of sand, absorbent material, or, as a last resort, dirt or rags, or other suitable material. If the spill is in an outside area and it is raining or rain is imminent, cover the spill with plastic sheeting, if feasible. 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. If the incinerator is down at the time the cylinder is leaking, the cylinder will be transferred to a remote area of the facility 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. If an explosion occurs where liquids are stored and a spill occurs, procedures for 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 of damages. Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 5 UTD981552177 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. If the 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 spilled or released material will be managed as hazardous waste. 8.0 Post-Emergency Equipment Maintenance 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 July 2024 Clean Harbors Aragonite, LLC page 6 UTD981552177 9.0 Emergency Equipment Section 2 of the 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 10 shows the location of the plant emergency equipment. 10.0 Coordination Agreements Aragonite has negotiated a written agreement with Tooele County. Representatives of Tooele County have been contacted, have received a copy of this Contingency Plan, and have received a plant walk-through 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: ● Tooele County road maintenance, ● Routine law enforcement, ● Fire response, ● Public health, ● Public safety, ● Hospital isolation unit, and ● Telecommunications. 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-through 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 Sheriff’s Department* Tooele, Utah 435-882-5600 Tooele County Emergency Management 435-833-8100 * The Sheriff’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 435-843-3600 University of Utah Hospital 801-581-2121 Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 7 UTD981552177 Airmed University of Utah 801-581-2500 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. 20510 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. 11.0 Required Reports As required by Utah Admin. Code R315-264-56(d) and 40 CFR §264.56(d), for major emergencies, Aragonite shall immediately notify 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 injuries, if any; and Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 8 UTD981552177 ● The possible hazards to human health or the environment, outside the facility. As required by Utah Admin. Code R315-264-56(i) and 40 CFR §264.56(i), Aragonite will record in the operating record any incident that requires implementing this Contingency Plan. In addition, Aragonite will submit a written report to the Director of the Division of Waste Management and Radiation Control (Director) within 15 days after an incident that required implementation of the Contingency Plan. The report will include: ● Name, address, and telephone number of the owner or operator; ● Name, address, and telephone number of the facility; ● Date, time, and type of incident; ● Name and quantity of material(s) involved; ● The extent of injuries, if any; ● An assessment of actual or potential hazard to health or the environment, and ● Estimated quantity and disposition of recovered material that resulted from the incident. For spills which require reporting under Utah Admin. Code R315-263-30 through 33, Aragonite shall immediately notify the Utah Department of Environmental Quality (UDEQ). The report will include: ● Name, telephone number, and address of person 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 of spill; and ● Emergency action taken to minimize the threat to human health and the environment. As required by Utah Admin. Code R315-263-33, Aragonite will submit a written report to the Director within 15 days for spills which require reporting under Utah Admin. Code R315-263-30 through 33. This report will include: ● 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, if any; ● An assessment of actual 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 §302.6, 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 Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 9 UTD981552177 Management and Radiation Control, Tooele County Office of Engineering and Department of Emergency Management, and the U.S. EPA, Region VIII. As required by Module 1, in the event of a release to the environment from a hazardous waste tank system, Aragonite will orally notify the Director within 24 hours and submit a written report within 30 days. The report will include: ● Likely route of migration of the release; ● Characteristics of the surrounding soil (soil composition, geology, hydrogeology, climate); ● Results of any 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. If plant 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 July 2024 Clean Harbors Aragonite, LLC page 10 UTD981552177 Reports to the Director will be sent to: Director Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, Utah 84114-4880 or dwmrcsubmit@utah.gov 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 15 East 100 South Tooele, Utah 84074 Tooele County Health Department 151 North Main Street 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 (801) 536-0200 (during office hours); or Utah Department of Environmental Quality (801) 536-4123 (24-hour answering service) Attachment 6 -- Contingency Plan July 2024 Clean Harbors Aragonite, LLC page 11 UTD981552177 Table 1 EMERGENCY COORDINATORS Facility Incineration Manager II – Ext. 8238 or Channel #1 on radio *James Sadler Facility Incineration Supervisors – Ext. 8352 or Channel #1 on radio Patrick Brady Jose Silva David Mota Ben Forrester Control Board Operator III – Ext 8354, or Dial 333, or Channel 1 on radio *David Yadon *Mark Shoemaker *Guy Thomas * Jake Vineyard *Mike Shugart *Cammeron Whitehouse *Bryce Hammond *Willard Hammond *Jesse Davis *Gary Johansen * Other personnel qualified to be Emergency Coordinator. List of Permit Revisions 1 July 2024 Part B Hazardous Waste Permit UTD 981 552 177 Clean Harbors Aragonite, LLC LIST OF PERMIT REVISIONS Permit Section Title Effective Date Module 1 Standard Conditions June 20, 2023 Module 2 General Facility Conditions December 19, 2023 Module 3 Storage and Treatment in Containers April 2024 Module 4 Storage and Treatment in Tanks June 20, 2023 Module 5 Incineration March 11, 2024 Attachment 1 Waste Analysis Plan April 2024 Attachment 1, Appendix 1 Quality Assurance Plan March 11, 2024 Attachment 2 Security Procedures June 20, 2023 Attachment 3 Inspection Plan April 2024 Attachment 4 Training Plan July 2024 Attachment 5 Preparedness and Prevention Plan June 20, 2023 Attachment 6 Contingency Plan July 2024 Attachment 7 Closure Plan June 2024 Attachment 7, Appendix 1 Closure Cost Estimate June 2024 Attachment 8 Waste Storage, Processing, and Tracking April 2024 Attachment 9 Tank Tables June 20, 2023 Attachment 10 Design Drawings April 2024 Attachment 11 Equipment Specifications February 22, 2024 Attachment 12 Waste Feed Cutoff Systems Testing Procedures April 2024 Attachment 13 Instrument Calibration April 2024 Attachment 14 Fume Management April 2024 Attachment 15 QACPP for CO and O2 Continuous Emissions Monitors June 20, 2023 Attachment 16 Data Monitoring and Recording System October 4, 2023 Attachment 17 Waste Management Plan for PCBs March 11, 2024 List of Permit Revisions 2 July 2024 Part B Hazardous Waste Permit UTD 981 552 177 Clean Harbors Aragonite, LLC LIST OF PERMIT MODIFICATIONS Document Number Description of Modification Effective Date DSHW-2022-017562 Modify Sludge Pad and Truck Unloading Direct Burn Pumping Stations to Accommodate Totes – Approved Sludge Pad Separately and First October 4, 2023 DSHW-2023-002440 Add Additional Docks to Buildings E-1 and E- 5 October 18, 2023 DSHW-2022-023304 Add Additional Compressed Gas Waste Types December 19, 2023 DSHW-2023-210037 Update Flow Meters for Saturator and Scrubber February 7, 2024 DSHW-2023-213173 Replace Baghouse, Update Baghouse Specifications February 22, 2024 DSHW-2023-207441 Incorporate Comprehensive Performance Test Results, Update WAP QAP March 11, 2024 DSHW-2023-004999 Update WAP Incineration Chemistry Determinations for Certain Waste Types - Consolidation Containers, Lab Packs, and Routine Wastes Received in Containers Equal to or Less Than Five Gallons April 2024 DSHW-2023-005459 Add an Additional Container Pumping Station and Add the Ability to Store Containers in the E-4 Decant Area April 2024 DSHW-2024-006380 Adjust Closure Cost Estimate for Inflation Using 2023 Inflation Factor June 2024 DSHW-2024-007028 Update Personnel Training to Remove Course Numbers, Update Contact Info for Emergency Coordinators in Contingency Plan July 2024