                                       
MEMORANDUM

Date:		June 5, 2013

Subject:	Report of May 29, 2013 Site Visit to Clean Harbors Inc., Dolton, IL

From:		Lesley Stobert, EC/R Incorporated
		
To:		Mary Tom Kissell, U.S. Environmental Protection Agency



      This memo summarizes the site visit to the Clean Harbors Inc. facility in Dolton, IL, which was conducted on May 29, 2013.  The purposes of this visit were to:
      
          * Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 
          * Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
          * Clarify any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility.

	The participants in the site visit included the following:

      Clean Harbors Inc.
      James Laubsted  -  Facility Compliance Manager 
      Bill Schade  -  Facility Manager
      
      US EPA
      Mary Tom Kissell
      
      EC/R Incorporated 
      Lesley Stobert
      Tanya Parise
      
This memo includes a brief overview of this project, an overview of the Clean Harbors facility, and is followed by a description of the specific information gathered during the visit.  

BACKGROUND
      
      Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, CAA section 112(d) requires us to promulgate technology-based national emission standards for each major source category listed under section 112(c).  These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards.  The National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Off- Site Waste and Recovery Operations were promulgated on July 1, 1996 (61 FR 34140), and codified at 40 CFR part 63, subpart DD. The final rule was amended on July 20, 1999 (64 FR 38950).  
      
      In the second stage of the regulatory process, the EPA is then required under CAA section 112(d)(6) to review these technology-based standards and revise them "as necessary (taking into account developments in practices, processes, and control technologies)" no less frequently than every eight years. In addition, within 8 years after promulgation of the MACT standards, CAA section 112(f)(2) requires the EPA to promulgate standards, if required, to provide an ample margin of safety to protect public health or to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect.
This second stage in standard setting is referred to as the residual risk and technology review (RTR) for the standards.

      The EPA is in the process of conducting the RTR for the OSWRO MACT standards. As part of the RTR process, this Clean Harbors Inc. production facility was selected for a site visit for three primary reasons: (1) it is one of several OSWRO facilities in the Chicago, IL area, which would enable the EPA to see several facilities in one trip, (2) based on available emissions data in the EPA's National Emissions Inventory (NEI), this facility had one of the higher emission rates of the OSWRO facilities identified in that database, and (3) discussion with Clean Harbors company representatives suggested that this facility had more diverse operations than the other Chicago-area Clean Harbors facility.  

PLANT SITE OVERVIEW
      
      The Clean Harbors Inc. facility is located at 633 East 138[th] Street, Dolton, IL, which is in the greater Chicago, IL area. At this site, Clean Harbors receives waste, including solvents, solvent mixtures, solid and semi-solid materials, and aqueous chemicals, and processes the waste through material handling, evaporation, and fractional distillation equipment for resale where possible. Where this is not possible, the waste is sent offsite for incineration or other means of disposal. Some of the primary business lines for this facility include aqueous and solvent parts cleaning, waste processing and fuel blending. The operations are continuous, with operations occurring 24 hours a day, 7 days a week. The facility receives waste from many businesses (i.e., over 1,000). This facility is subject to the OSWRO MACT (subpart DD) and also Resource Conservation and Recovery Act (RCRA) regulations. Clean Harbors facility representatives stated that the closest residential area is a few hundred feet away on the south side, and there is a small fishing lake where some people fish south of the facility across the train tracks. 

INFORMATION GATHERED DURING VISIT

	The following section describes the information gathered in relation to the three stated purposes of the visit. 

   1. Enhance understanding of current processes and emission controls for the off-site waste and recovery operations (OSWRO) at the facility. 

 This facility was a Safety Kleen facility, which was recently acquired by Clean Harbors, Inc.  Due to the acquisition of Safety Kleen by Clean Harbors, some changes may be made in the future regarding the types of operations that will be performed at the various facilities now owned by Clean Harbors.
 Most material received is liquid in small quantities rather than bulk quantities, with 80% of the materials received in 50 gallon drums or smaller.
 The facility samples every container received, or composites of up to 20 drums, to test for material characteristics, such as BTU value, and also for VOCs, PCBs and non-conforming material.
 The facility has a 35,000 CFM regenerative thermal oxidizer that is the primary control device for most operations. There is a flare that is used a back-up when the thermal oxidizer is not operational. The facility representatives indicated that the use of the flare is very rare, and that the plant operations stop if the thermal oxidizer is not working.
 The facility has 110 tanks, most of which are 15,000 gallons in size.  Some of these tanks have pressure relief devices, and some are vapor balanced.
 The facility has three LUWA thin film evaporators. One of these is routed to the thermal oxidizer, and the other two are routed to glycol condensers, but they will be routed to the thermal oxidizer in the future (expected during 2015).
 The facility has pot stills that are also controlled with thermal oxidizer.
 Emissions from the distillation column at the facility are controlled with the thermal oxidizer. The "lights" from this process are sold to customers, and the "bottoms" are sent to cement kilns to be used as a fuel.
 The facility has a metal shredding tower, and this operation is routed to the thermal oxidizer for emissions control. The clean metal is sold as scrap.
 The facility has received approval to operate a dry metal wash system that is also routed to the thermal oxidizer.

   1. Gain an understanding of the other applicable Clean Air Act regulations for the facility, including 40 CFR 264, 265, 279 and 40 CFR Parts 60, 61 and 63.
            
 The facility complies with the RCRA standards at 40 CFR part 264, subparts AA, BB, and CC. The facility representatives indicated that the requirements of the RCRA standards were nearly identical to the 40 CFR part 63, subpart DD standards, and that by complying with the RCRA standards, only an additional report or two was required to comply with subpart DD.

   1. Clarify any questions the U.S. EPA has regarding the response received from the recent information collection request for this facility.
            
 In response to questions about missing information in the company's ICR response for this facility, Mr. Laubsted stated that he would provide the EPA and EC/R with the requested tank information. 

