DSHW-2024-008900

Clean Harbors Aragonite, LLC 11600 North Aptus Road Aragonite, UT 84029
435.884.8100 www.cleanharbors.com
“People and Technology Creating a Better Environment”
October 24, 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
RE: Notification of Noncompliance Clean Harbors Aragonite, LLC EPA Number – UTD 981 552 177 Dear Mr. Hansen,

In accordance with condition 1.Q.1 of Clean Harbors Aragonite’s (CHA) State RCRA Permit, this correspondence serves as notification that ignitable hazardous waste was transferred into the Bulk Solids Tank. This is in violation of Module 4 Section 4.C.4.a, and Attachment 1 Section 3.2.4.

On October 18, 2024, during an internal review of manual dump logs into the Bulk Solids Building, it was discovered that the following A-Damper container was dumped into Tank 404B East:
• AG17-1 (Tracking # A00IG1I8) o This container was dumped into the Tank on 10/8/2024.

This was caused by operator error. The A-Damper in house dump sheet was delivered to the
incineration team as approved for dumping, despite this container testing positive for ignitability.
In addition, the container in question did not have an LEL performed prior to dumping.

As corrective actions, the A-Damper sheet will be modified so that a second Blends Chemist will verify that the chemistry meets the dump parameters. In addition, the Incineration team will
include LEL testing verbiage into the A-Damper Management Procedure.

I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision according to a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, 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 knowing violations.

Should you have any questions regarding this matter, please contact me at the number listed below.

Sincerely,

Kenneth Banks Senior Environmental Compliance Manager Clean Harbors Aragonite, LLC 11600 North Aptus Road
PO Box 1339
Grantsville, Utah 84029-1339 (o) 435.844.8233 (c) 435.579.5193 [e-mail]
www.cleanharbors.com