DSHW-2024-004989

March 11, 2024
William Simmons, Facility General Manager
Clean Harbors Aragonite, LLC
P.O. Box 1339
Grantsville, UT 84029-1339
RE:Class 1 Modification Approval – Incorporation of Comprehensive Performance Test Results and Minor Corrections/Updates to the Quality Assurance PlanUTD981552177
Dear Mr. Simmons:
On August 4, 2023, Clean Harbors Aragonite (Aragonite) submitted a Class 1 modification request seeking approval to update the Permit with test results from the Comprehensive Performance
Test conducted in May of 2023. About the same time, in a separate correspondence, Aragonite submitted a copy of the ComprehensivePerformance Test Report.
Though Aragonite did not set out to establish new incinerator operating limits in the test plan, through the course of testing and data evaluation, some of the demonstrated operating
limits did change from what was previously contained in the Aragonite permit.
During a recent review of the Aragonite Quality Assurance Plan as part of the process of getting the on-site lab certified by the Utah Department of Health, it was noted that some minor
updates in the plan were needed. Additionally, it was also noted that one of the method limits hadn’t been updated when the permit was renewed last year.
The modification request and the Comprehensive Performance Test Reporthave been reviewed and as provided by this notice the modification request is approved as enclosed.
It was noted in our review that the modified minimum pH limits proposed for the 1st and 2nd stage feeds to the scrubber were not correct. It appeared that incorrect test runs were averaged
to calculate the proposed changes. Accordingly, the 1st stage scrubber feed pH limit was updated to 4.99 and the 2nd stage pH limit was left unchanged at 6.25. There were also some
existing operating limits in Module 5 and/or Attachment 17 that were updated to match the results from the Comprehensive Performance Test, but that were not identified as being affected
in the modification request. These includeCombustion Gas Velocity and Total Organic Chlorine Feed Rate.
Aragonite should update its copy of the permit by making the following changes:
Replace Module 5 - Incineration with the enclosed copy.
Replace Attachment 1 - Waste Analysis Plan, Appendix 1, Quality Assurance Plan with the enclosed copy.
Replace Attachment 17 -Waste Management Plan for PCBs with the enclosed copy.
Also enclosed is an updated copy of the List of Permit Revisions.
If you have any questions, please call Boyd Swenson at [phone].
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BAS/wa
Enclosures:Module 5 - Incineration (DSHW-2012-011664)
Attachment 1 - Waste Analysis Plan, Appendix 1, Quality Assurance Plan (DSHW-2012-011625)
Attachment 17 - Waste Management Plan for PCBs (DSHW-2012-011637)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, US EPA, Region VIII
Natalie Cannon, US EPA, Region VIII
Bryan Lunt, Clean Harbors Aragonite (Email) [e-mail]
Ken Banks, Clean Harbors Aragonite (Email) [e-mail]
Gabrielle Marinick, Division of Waste Management and Radiation Control, UDEQ