DSHW-2024-005919

Clean Harbors Aragonite, LLC
11600 North Aptus Road
Aragonite, UT 84029
435.884.8100
www .cleanharbors .com
April 17, 2024
Sent via [e-mail]
Mr. Douglas J. Hansen
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: Responses to Compliance Advisory Letter No. 2402018
DWMRC 2023 Annual Inspection
UTD 981 552 177
Dear Mr. Hansen,
Clean Harbors Aragonite LLC (CHA) is in receipt of your letter dated March 19, 2024, regarding
the Compliance Evaluation Inspection conducted by the DWMRC in 2023.
As noted, many of these alleged violations were self-reported and corrective actions were taken
promptly when the issue(s) was discovered. For other alleged violations, CHA acted where
possible when notified by the DWMRC.
CHA is providing explanations and justification on the corrective actions requested by the
DWMRC. These responses are for finding numbers eight (8) and nine (9) found on Compliance
Advisory Letter No. 2402018.
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,
William L Simmons
Facility GM III
Clean Harbors Aragonite, LLC
11600 North Aptus Road
PO Box 1339
Grantsville, Utah 84029-1339
(o) 435.844.8351
(c) 870.310.6029
simmons. [e-mail]
www.cleanharbors.com
Compliance Advisory Letter No. 2402018
This docwnent is CHA's response to both corrective actions on Compliance Advisory Letter No.
2402018
Finding #8 -Section 1.2 of Attachment 8 requiring AG to ship rejected wastes no more
than 60 Days from the Plant Received date.
CHA Response:
•
•
Container A0070TX3
o This container was Plant Received on 11 /15/2022 and shows placed in OFFC on
12/7/2022 due to the container being a'!. extra on a shipment. The container was
Rejected to an Alternate facility and shipped out on 1/28/2023.
o CHA has been conducting Daily Pyrophoric Audits amongst the teams to prevent
containers in CR status from making it to CHA . This will also provide CHA
additional visibility on pyrophoric containers throughout the Clean Harbors
Network.
Container A0024QTC
o This container was Plant Received to CHA on 4/21/2022, was scanned to the
Receiving floor on 5/14/2022, and was placed in storage on 5/15/2022. The
container left CHA on 6/18/2022 on trailer 3202339, with a destination to WI
(container was on the property for 34 Days).
o On 9/8/2022, container A0024QTC arrived back onto the property, as was placed
in storage.
o Container A0024QTC was placed in the OFFC row for investigation on
1/22/2023 due to a profile issue and was resolved and Rejected to an Alternate
Facility within 15 Days. The container was finally sent off the property on
212/2023 with a new container number A007KPSK
o CHA shall retrain operators to mitigate the potential for these issues to occur.
• Container A006517V
o This container shows Plant received to CHA on 10/25/2022. However , this
container was not scanned to the floor , and was given permission prior to offload
to where it could be Rejected to an Alternate Facility. The manifest for the
container (0l 7935424FLE) was having IP issues, so a new manifest was created
for the container as well as a new container number generated (A005YNC9).
Finding #9 -Section 2 of Attachment 14 requiring annual inspections of the duct work
between the sludge pad direct burn system and the closed vent system.
CHA Response -CHA performs annual inspections of the duct work between the sludge pad
direct burn system and the closed vent system. CHA has attached the last two (2) annual
inspections on this system for reference . There may have been a miscommunication between
Page 1 of2
CHA and the DWMRC in regards to the new Drum Pumping station modification, as this new
process is not incorporated with the existing closed vent system, and this system is still not in
operation.
Page 2 of2
Area Information
Area: The duct work sections between sludge pad direct burn system and the closed vent
system.
When it can be inspected: While the sludge pad direct burn system is being operated and
incinerator is be in g o perated.
Inspection Information
Inspector Name: cJ > (J A ~ G µ-AIM. fv"\. 0~
Date of Inspection: It /6/ 2c£,3
j
Start Time: {!,· I 0 End Time: ({;30
Are there any leaks, holes, gaps, loose connections, corrosion, etc. that Yes ~ could lead to detectable emissions? (circle either yes or no)
PID Meter Readings
Background Result: o.o ppm Sample Result: o.o ppm
Actual Result (Background Result -Sample Result): 0-0 ppm
Note : Actual result must be below 500 ppm for nondetectable emissions
Comments: / ,l_, Sy.sf~ JuA ~ f ~ , ',.., 5'..et1.,v ta., ~ft,•~ f /4..t..
<j--w..1e,, Gv .... -p 61.uY u,,..>vt.:__Q S >...s1~+,~ J Mofl._1, ~J
0~ f ~ ~I__ f'1 tJ /'V\J.,,1" .. UL
r\
~ I )
Inspector Signature: IAJhr ~ ~
Area Information
Area: The duct work sections between sludge pad direct bum system and the closed vent
system.
When it can be inspected: While the sludge pad direct bum system is being operated and
incinerator is being operated .
Inspector Name:
Date of Inspection:
Start Time:
I nspection Information ,
(J L 11~{\J"'A G f~AIAA/IV\ CJ¾'
1
/ ~ / <~ ( Z-u -i-~
End Time:
Are there any leaks, holes, gaps, loose connections, corrosion, etc. that
could lead to detectable emissions? (circle either yes or no)
PID Meter Readings
Yes
Background Result: __ c_,._l ___ ppm Sample Result: U • ') ppm ------
Actual Result (Background Result -Sample Result):
r-i i.f _____ ->_· _____ ppm
Not e: Actual result must be below 500 ppm/or nondetectable emissions
Comments: fl, 5 .fy 1 I~ 1.v\. I,_ ,;JI) >J O t bzL~ 1 'I'--5"-e f__,V-' •-L /!J4,,t,J (
r,l_ f ";(.6' ;J.Lv.,1_,. ~C---~ ~ Ut.JJ ,~5~J,U'A_ J
JUc II--, l:.,----r IA..-t. 1-L. -+ le_ r 11.J /t v1t.-l-~ ,-1.....
A I f\
Inspector Signature: /,J /J; ~ ( ~/