Facility Audit: Cleveland, OH
Table of Contents
1.0 General Company Information ......................................................................................................................... 1
Introduction......................................................................................................................................................... 1
Network of Services............................................................................................................................................ 1
2. 0 Facility Information ......................................................................................................................................... 2
Facility Overview................................................................................................................................................ 2
Facility Site Plan ................................................................................................................................................. 3
Facility History ................................................................................................................................................... 4
Site Characterization........................................................................................................................................... 4
Security ............................................................................................................................................................... 4
Directions to Facility........................................................................................................................................... 5
3.0 Operating Licenses and Permits........................................................................................................................ 6
Permit Summary ................................................................................................................................................. 6
Principal Operating Licenses/Permits................................................................................................................. 7
4.0 Process Description........................................................................................................................................... 8
Inorganic Aqueous Wastewater Treatment......................................................................................................... 8
Storage and Transfer of Waste Oils .................................................................................................................... 9
Container/Tank Storage/Transfer........................................................................................................................ 9
Waste Analysis.................................................................................................................................................... 9
5.0 Closure Plan ...................................................................................................................................................... 9
6.0 Insurance ......................................................................................................................................................... 10
7.0 Financial Information...................................................................................................................................... 11
8.0 Appendix......................................................................................................................................................... 11
1.0 General Company Information
Introduction
Clean Harbors is a publicly traded company who maintains a vast network of service centers and
waste management, treatment and disposal facilities, providing a broad range of environmental
services. Services include hazardous and non-hazardous waste transportation and disposal,
laboratory chemical packing, emergency response, and field services and industrial maintenance.
Since its inception in 1980, Clean Harbors has grown to become the leading provider of
environmental services in the country in North America and its locations span the United States
and Canada, and include locations in Mexico and Puerto Rico.
Network of Services
Strategically located across North America, Clean Harbors’ service centers are the primary
interface with customers and the focal point for providing waste management activities,
laboratory chemical packing services, and emergency response, field services and industrial
maintenance. From the service center Site Service crews and equipment are dispatched to
perform various planned work on customers’ sites, as well as emergency response. CleanPack
teams are also based at the service centers and provide customers with laboratory chemical
packing services.
Technical Services – Technical Services provides the pick up and transportation of
containerized and bulk wastes, as well as the categorizing, packaging and removal of laboratory
chemicals for disposal. Through a network of Technical Service Centers, trucks are typically
dispatched on predetermined schedules to pick up waste from customer locations for delivery to
a Clean Harbors Transfer, Storage and Disposal Facility. The Technical Service Centers also
dispatch CleanPack® chemists who go to customer locations to categorize, package and remove
various sized laboratory chemicals for disposal.
Transportation & Disposal - Clean Harbors’ network of company owned waste treatment,
storage and disposal facilities are located across North America and offer a broad range of
disposal, recycling and treatment technologies for hazardous and non-hazardous materials.
Technologies include:
• Incineration
• Water Treatment
• Landfill
• Recycling and Reuse
• Fuel Blending
• Lab Chemical Disposal
• Used Oil and Oil
Products Recycling
• PCB Disposal
• Explosives Management
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All of our disposal facilities uphold rigorous quality assurance programs to meet the highest
standards of both internal and external audits.
Waste streams handled by Clean Harbors can be in any form from gas to liquids, solids and
sludge. Clean Harbors can dispose of virtually any type of waste, hazardous or non-hazardous
from exotic water reactive wastes to typical paint or oil wastes.
Our transportation services handle everything from small one-time shipments to multiple large
shipments, and include drum, bulk and rail capabilities. Once you place your order and before
the picked up is even made, Clean Harbors begins the process of managing your waste. Your
order enters our Logistics center where your waste is designated for disposal via the least cost
routing. Company owned and operated trucks are assigned based on the most efficient route or
on pre-established schedules. Satellite tracking and communications allows trucks to be
dispatched on the fly from anywhere in the country. The disposal facility is determined based on
the most appropriate, yet lowest cost disposal method.
Furthermore, plant inventories are centrally monitored real-time and our facilities know in
advance and begin load planning for efficient processing of incoming waste. All this upfront
work is managed centrally and electronically to provide the most cost effective and efficient
handling of orders, and waste transportation and disposal, in the industry.
CleanPack® Laboratory Chemical Packing Services - Clean Harbors’ staff of professionally
trained CleanPack chemists work on customers’ sites to collect, label and package unwanted
laboratory quantities of chemicals and wastes for disposal in compliance with local, state, and
federal regulations. Additionally, CleanPack teams provide reactive material handling services
and cylinder and compressed gas management for the proper handling and disposal of highly
reactive and dangerous chemicals, laboratory move services. The teams also manage the moving
of entire laboratories, as well as assist in facility closures. Our household hazardous waste
collection program offers a cost effective and safe manner for States, Provinces, Cities and
Towns to keep their resident’s free of unwanted old and obsolete pesticides, paints, fertilizers
and other potentially harmful materials.
Site Services – The Site Services is responsible for providing trained, skilled labor and specialty
equipment to perform various services on a customer’s site or other location. Field Service
crews and equipment are dispatched on a planned or emergency basis to manage routine cleaning
in hazardous environments or emergencies such as a chemical or oil spill clean up. Industrial
Service crews focus on industrial cleaning and maintenance projects that typically require fast
turnaround, as well as large-scale cleaning project requiring specialty onsite processing
equipment.
Field Services - Working in hazardous and non-hazardous environments, Field Service crews
and equipment are dispatched on a planned or emergency basis to perform services such as
emergency response, vacuum services, tank cleaning, site decontamination, product recovery and
transfer, demolition services, marine services, used oil and oil products recycling, PCB
management and disposal, and remediation and environmental construction.
Industrial Services - Industrial Services teams use advanced industrial cleaning technologies
including sodium bicarbonate blasting, hydroblasting, and steam-cleaning along with vacuum
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services to accomplish fast turnaround during time-critical plant shutdowns. The teams also
perform onsite material processing services, and dewatering and pressing, and container
management services.
2. 0 Facility Information
Facility Overview
Clean Harbors Environmental Services, Inc., a subsidiary of Clean Harbors, Inc. headquartered
in Norwell, Massachusetts, owns and operates a Clean Water Act (CWA) treatment and disposal
facility located in Cleveland, Ohio. This facility has been licensed by the Ohio Environmental
Protection Agency, Division of Water Pollution Control, to receive, store, and treat a variety of
wastewater streams. The treatment methods utilized at this facility reduce the volume and or
toxicity of waste materials to a level that meets specifications for discharge into a publicly
owned treatment works (Northeast Ohio Regional Sewer District).
Facility Name Clean Harbors Environmental Services, Inc.
Location 2900 Rockefeller Ave. Cleveland, Ohio 44115
County Cuyahoga
Clean Harbors Environmental Services, Inc.
Facility Owner 2900 Rockefeller Ave.
Cleveland, Ohio 44115
Clean Harbors Environmental Services, Inc.
Property Owner 2900 Rockefeller Ave.
Cleveland, Ohio 44115
Facility I.D. No. OHD 000 724 153
Permit Type Centralized Wastewater Treatment Facility, CWA System
Waste Description Aqueous organic and inorganic wastewaters
Chemical Precipitation
Chemical Oxidation/Reduction
Acid/Base Neutralization
Services Provided Phase Separation
Sludge Dewatering/Fixation
Non-Hazardous Waste Oil Storage
Bulk and Drum Transportation and Disposal
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Facility Site Plan
3
Facility History
The Cleveland facility, approximately 5.5 acres, is located in an industrial area of the Cuyahoga
River Valley of Cuyahoga County. Until its acquisition by Clean Harbors in January, 1989, the
facility had been licensed, constructed, owned and operated by ChemClear, Inc., a publicly-held
company providing hazardous waste treatment and management services in the East and
Midwest. Prior to 1979 the land was owned and operated as an oil distribution terminal by
Standard Oil.
Site Characterization
Soil at and near the ground surface at the site has been characterized as alluvium, consisting of
sediment, including a mixture of fine and medium sand, clay and silt, deposited by a river in its
delta. Based on studies by the State of Ohio, bedrock is expected to be several hundred feet
below the ground surface and consist predominantly of shale.
Based on topographic features of the area, groundwater flow of the general area is expected to be
to the west, towards the Cuyahoga River. Most operations performed at the facility are
conducted indoors or within secondary containment areas; any resulting storm waters collected
from outdoor process areas are gravity strained in sumps, tested and treated "on-site" through
routine treatment processes.
Security
The Cleveland facility is completely fenced and secured 24 hours per day, 7 days per week, and
365 days per year.
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Directions to Facility
2900 Rockefeller Ave.
Cleveland, Ohio 44115
(216) 429-2402
From the South (I-77):
1. Take I-77 North to Broadway Exit.
2. Turn left onto Broadway Avenue, go to third traffic light.
3. Turn left on Rockefeller Avenue past I-490 West entrance. The plant entry drive is
on the left for deliveries of waste. Visitors should bypass plant entry and turn left on
Independence Ave.
4. Office located at 2930 Independence Rd. on right.
From I-71 and Hopkins Airport:
1. Take I-71 North to I-490 East.
2. Take I-490 to Broadway Exit, left at traffic light, left at next traffic light
(Rockefeller Ave.).
3. Repeat directions 3 & 4 above.
From I-480:
1. I-480 is South of Cleveland and intersects both I-71 and I-77. Take I-71 or I-77
North and follow directions above.
From I-90 Westbound:
1. Take I-77 South to first exit which is Broadway, East 30th and Woodland.
2. Turn right at first traffic light (E. 30th). Turn left at next traffic light (Broadway
Ave.). Turn right at second traffic light (Rockefeller Ave.) and follow directions
above.
From I-90 Eastbound:
1. Take I-490 East to Broadway Exit and follow directions from I-71 and Hopkins
Airport.
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3.0 Operating Licenses and Permits
Permit Summary
Clean Harbors Environmental Services, Inc. Cleveland facility is currently permitted by the Ohio
EPA and the Northeast Ohio Regional Sewer District for the collection, storage, analysis and
treatment of industrial wastewaters.
Expiration
Permit Type/Governing Agency Permit No.
Date
Hazardous Waste Exemption Letter
Not
Division of Solid & Hazardous Waste Management- Not Applicable
Applicable
Ohio EPA (Attached)
Northeast Ohio Regional Sewer District
Industrial User Administrative Order / Equivalency 4953-200-437ES06-R 12/10/2011
Permit (Cover Attached)
Wastewater Permit to Install
Not
Division of Water Pollution Control- Ohio EPA 02-612
Applicable
(Attached)
Permit to Operate Air Contaminant Source 1318006093P001 06/20/94*
Bureau of Engineering Services (WWTP)
Division of Air Pollution Control- Ohio EPA 1318006093P003 01/06/98*
(Reactor)
1318006093P004 01/06/98*
*Clean Harbors has submitted timely permit renewal applications. (Reactor)
While these applications are under review, the facility continues to 1318006093P006 09/23/97*
operate pursuant to the terms and conditions of the expired permit.
(Lime Silo)
Final Permit to Install Modification for Oil Paint Can Not
13-03672
Crushing & Bulking Operation Applicable
Permit to Operate 6093G001 7/31/2009
City of Cleveland 6093P001 7/31/2009
Bureau of Air Pollution Control 6093P003 7/31/2009
6093P004 7/31/2009
6093T001 7/31/2009
6093T003 7/31/2009
6093T004 7/31/2009
6093T005 7/31/2009
6093T012 7/31/2009
6093T013 7/31/2009
6093T015 7/31/2009
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Principal Operating Licenses/Permits
Copies of existing permits which detail types of waste management licensed capacities and waste
types accepted are available for inspection upon request at the site. Selected permit pages may
be attached at the end of this audit under Appendix 8.0.
Principal Contacts/Agencies
The list of contacts below can provide additional information regarding Clean Harbors of
Cleveland’s facility operations or compliance:
Michael Petkovich, General Manager
Clean Harbors Env. Services, Inc.
Operations 2900 Rockefeller Avenue
Cleveland, Ohio 44115
(216) 429-2402 ext. 209
Susan Sevy
Facility Compliance Manager
Regulatory Clean Harbors Env. Services, Inc.
2900 Rockefeller Avenue
Cleveland, Ohio 44115
(216) 429-2402 ext. 227
Nyall McKenna, Env. Spec. II
Ohio EPA, Division of Hazardous Waste Mgmt.
(LQG/RCRA Northeast District Office
Compliance) 2110 East Aurora Rd.
Twinsburg, Ohio 44087
(330) 963-1272
Richard Connelly, Superintendent
Environmental Services, Water Quality & Industrial Surveillance
Northeast Ohio Regional Sewer District
(Water Quality) Env. & Maintenance Services Center
4747 E. 49th St.
Cuyahoga Heights, Ohio 44125-1011
(216) 641-6000
Lian Ang, Engineer
City of Cleveland
Division of the Environment
(Air Quality) Bureau of Air Pollution Control
1925 St. Clair Ave.
Cleveland, Ohio 44114
(216) 664-2148
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4.0 Process Description
Inorganic Aqueous Wastewater Treatment
The facility utilizes highly refined, multi-stage, chemical precipitation processes that remove
heavy metals, suspended solids and residual organics from liquid wastes and render the effluents
safe for discharge into municipal sewer systems. Resulting precipitated residues are dewatered
with a filter press, and then disposed of in an approved landfill.
• Chemical Precipitation
All aqueous wastes are eventually mixed together and processed on a continuous flow basis
through a multi-compartmental specially-designed treatment unit, where predetermined amounts
of treatment chemicals are added and thoroughly mixed to effect precipitation of heavy metals
and coagulation of suspended particles. Coagulated solids are removed in the form of sludge by
gravity separation through high efficiency clarifiers.
Clarified effluent is stored in effluent storage tank and is discharged into the Northeast Ohio
Regional Sewer System upon confirmation of discharge permit parameters from on-site
laboratory analysis. Additionally, the Northeast Ohio Regional Sewer District monitors
discharge.
• Chemical Oxidation/Reduction
Waste needing pretreatment to remove specific contaminants prior to its mixing with other
wastes, is batch processed into a specially designed reactor vessel fitted with dual scrubbing
towers. Adding chemical reagents specific to the batch as determined by the laboratory
simulation as achieves the desired reaction. Upon completion of the reaction, each batch is
tested to confirm the end result of the treatment, prior to its transfer into storage tanks for final
precipitation treatment. Types of reactions carried out are: oxidation of cyanides and phenols,
ammonia removal, chelating agent removal from wastes such as boiler cleaning solutions,
reduction of hexavalent chromium to trivalent chromium, acid/base neutralization, etc.
• Acid/Base Neutralization
Although this can be a final treatment method, neutralization is often used in conjunction with
other treatment processes such as chemical precipitation, phase separation and
oxidation/reduction treatment processes.
Neutralization involves the addition of an acid or a base to a solution to adjust the pH, usually to
a level between 6 and 9. Alkaline neutralization usually involves the addition of Sodium
Hydroxide, Potassium Hydroxide or slaked lime to an acidic wastewater to adjust the pH.
Likewise, acidic neutralization involves the addition of a concentrated acid (such as Sulfuric,
Hydrochloric or Nitric) to an alkaline wastewater.
• Sludge Dewatering/Fixation
Sludge produced upon treatment of the aqueous wastes and batch treatment of slurry wastes, are
first thickened by gravity. Settled sludge from the bottom of the thickener is pumped to a batch
conditioning tank where chemical reagents are added to aid the dewatering and to stabilize the
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constituents of concern. The conditioned sludge is pumped into a recessed chamber filter press
to achieve a stable filter cake suitable for landfill. Filtrate produced is sent back to the head of
the system for reprocessing while the filter cake is collected into a dump trailer for its disposal
into an approved landfill.
Storage and Transfer of Waste Oils
Waste industrial lubricating and fuel oils are stored on-site. The use of gravitational separation
of oil from water and solid components produces oil suitable for reclamation. Once a sufficient
quantity is accumulated, the waste oil is shipped off-site for reclamation. Wastewater generated
from this separation process is transferred to the wastewater treatment system.
Container/Tank Storage/Transfer
A wide variety of wastes not acceptable for on-site treatment can be received for consolidation
and transfer to other Clean Harbors' sites or select audited and approved non company-owned
sites. The facility includes storage areas for tanks and containers meeting all RCRA
requirements.
Waste Analysis
The Waste Analysis Plan for the facility outlines pre-qualification and on-site acceptance
analysis requirements.
• Pre-Qualification
Prior to acceptance and treatment of a specific waste, Waste Material Profile Sheet must be
submitted to and approved by both Northeast Ohio Regional Sewer District and Clean Harbors
Environmental Services, Inc. prior to any waste shipment. Waste profile can be completed and
submitted online on Clean Harbors’ website at www.cleanharbors.com. Once the waste material
is accepted for treatment/disposal, this information becomes part of the permanent record in the
generator's file and the waste may be scheduled for shipment.
• On-Site Analysis/Acceptance
With each delivery of approved waste, a sample is taken from the load and tested to determine
whether the waste is the same as the previously submitted sample. If this analysis differs
significantly from the advance sample, the waste will be deemed non-conforming. All non-
conforming wastes are further analyzed to determine the best treatment alternatives, whether on-
site handling at an adjusted price or transshipment to an alternative treatment facility. The
customer is contacted regarding any non-conforming waste and given the option for alternate
handling or return of their waste. On specification shipments are processed with one or more of
the storage or treatment operations previously identified.
5.0 Closure Plan
As a RCRA-exempt facility, Clean Harbors Environmental Services, Inc., Cleveland Facility is
not required to prepare a closure plan. See below for Environmental Impairment Liability
insurance coverage.
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6.0 Insurance
Clean Harbors and its subsidiaries maintain General Liability and Automobile Liability
insurance with aggregate limits of $30,000,000. The Company purchases Environmental
Impairment Liability insurance for its’ waste facilities with limits of $30,000,000 insuring the
Company against liability for sudden and accidental occurrences from the time waste is picked
up from a customer, while being handled at the Company’s treatment and transfer facilities,
through its delivery to a disposal site.
Clean Harbors Casualty Insurance Program Summary
Policy Limits of Liability
Workers Compensation & Employer’s Statutory
Liability $1,000,000 Each Accident
Business Automobile Liability $1,000,000 Each Occurrence
(Includes MCS-90 Endorsement) $5,000,000 MCS-90
$1,000,000 Each Occurrence
Comprehensive General Liability
$3,000,000 Aggregate
Excess (Umbrella) Liability $30,000,000 Each Occurrence
(Follow Form) $30,000,000 Aggregate
Wharfingers Liability $10,000,000 Any one Vessel/Any one Accident
Contractor’s Pollution Liability $10,000,000 Each Occurrence
(Off-Site) $10,000,000 Aggregate
Protection and Indemnity $1,000,000 Each Occurrence/Any one Vessel
Environmental Impairment Liability $3,000,000 Each Occurrence
(Coverage for Clean Harbors Facilities) $6,000,000 Aggregate
Excess Pollution Liability $30,000,000 Each Occurrence
(Sudden and Accidental Occurrences) $30,000,000 Aggregate
Total coverage for Pollution incidences that
$30,000,000 Limit
occur during transportation related activities
For more detail concerning Clean Harbors’ coverage, please contact the Clean Harbors Risk
Management Department at (781) 849-1800.
Facility Closure Certificate
http://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=640&ft=1
Certificate of Liability Insurance
http://clark.cleanharbors.com/tt/sl.ashx?z=219847c5&dataid=98&ft=1
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7.0 Financial Information
Financial information on Clean Harbors and its subsidiaries are available from the Clean Harbors
website in the Investor Relations section.
http://www.cleanharbors.com/investor_relations/investment_materials.html
8.0 Appendix
If applicable, supporting facility documentation will follow.
2900 Rockefeller Avenue • Cleveland, OH 44115 • 216.429.2402 • www.cleanharbors.com 11