# Enclosure 1ENCLOSURE 1



## INFORMATION COLLECTION REQUEST FOR Off

-Site Waste and Recovery Operations
This information collection request is being conducted by the Environmental Protection Agency’s (EPA) Office of Air and Radiation (OAR) to assist the EPA Administrator in developing emission standards for Off

-Site Waste and Recovery Operations under Clean Air Act (CAA) section 112. The survey is being sent under the authority of Section 114 of the CAA.
BACKGROUND: Section 112 (d) of the Clean Air Act (CAA) calls for EPA to promulgate national technology

-based emission standards for hazardous air pollutants (NESHAP) for sources emitting one or more of the HAP listed in CAA section 112(b). For major sources, these technology

-based standards must reflect the maximum degree of emissions reductions of HAP achievable (after considering cost, energy requirements, and nonair quality health and environmental impacts). In addition, under CAA section 112(d)(6), EPA is required to review the technology

-based standards and revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every 8 years. Furthermore, we are required by section 112(f) (2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight years after the promulgation of maximum achievable control technology (MACT) standards under section 112(d). If we find the residual risk fails to protect public health with an ample margin of safety or to prevent (taking into consideration various factors) adverse environmental effects, we are required to promulgate
more stringent standards.
The Off

-Site Waste and Recovery Operations maximum achievable control technology (MACT) standards were promulgated on July 1, 1996 (see 61 FR 34140). We are collecting specific detailed information to support development of standards as part of our review as described above. Please note this survey is for off

site waste and recovery operations only. CAA section 114(a) states that the Administrator may require any person who owns or operates any emission source, who manufactures emission control equipment or process equipment, who the Administrator believes may have information necessary for the purposes set forth in section 114(a), or who is subject to any requirement of the CAA (other than certain provisions under Title II), to provide EPA with information for the following purposes:

1. Developing or assisting in the development of the following:
a. State implementation plans (§§ 110 and 111(d)); b. New Source Performance Standards (NSPS) (§ 111);
c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112); d. Solid waste combustion or other related solid waste regulations (§ 129); 2. Determining whether any person is in violation of any standards or requirements developed under the authorities cited above; or 3. Carrying out any provision under the CAA (except certain provisions under Title II). The Administrator may require that those persons identified above do the following so the Administrator may have the information necessary for the items listed in #1

-3:

 establish and maintain records;

 make reports; install, use, and maintain monitoring equipment, and use audit procedures, or methods;

 sample emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe);

 keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical;

 submit compliance certifications in accordance with section 114(a)(3); and

 provide such other information as the Administrator may reasonably require.
DIRECTIONS:

 All recipients must complete and return this survey by April 10, 2013

.

 Please identify clearly any response(s) that you consider to be confidential business information (CBI). Any responses not so identified will be included in a publicly available database. Refer to Enclosures 3, 4, 5, and 6 for more information on the treatment of CBI and a list of information you may be asked to submit later to substantiate a claim of confidentiality. DEFINITIONS: For the purposes of this ICR only, terms used have the meanings attributed to them in 40 CFR 63.681. CONFIDENTIAL BUSINESS INFORMATION (CBI): Please indicate if any CBI is included in this survey response: 

## Y 

## N
OFF

-SITE WASTE AND RECOVERY OPERATIONS We believe that you own a facility that has Off

-Site Waste and Recovery Operations. If you believe that this survey does not pertain to you, please indicate your reason below: 

##  The Off

-Site Waste and Recovery Operations are permanently shut down. Please also identify the date the Off

-Site Waste and Recovery Operations were shut down, what steps were taken to close the equipment or stop operations, and if you still have a permit

.

_________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________ 

##  No Off

-Site Waste and Recovery Operations at this facility. Please identify the operations at the facility.

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________ If your facility does not have Off

-Site Waste and Recovery Operations, please respond as soon as possible. We will review that information and respond as to whether you need to complete any other part of the survey.

# Enclosure 2U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

General Information
Name of Legal Owner: Clean Harbors, Inc. Legal Owner Address: 42 Longwater Drive, Norwell, MA 02061
Number of Legal Owner Employees: ~10,000 Facility Name: Clean Harbors Recycling Services of Chicago LLC Facility Address: 1445 W 42nd St, Chicago, IL 60609 Mailing Address (if different from facility address): N/A Facility Contact Name: Gary Malinowski Facility Contact Title: Sr. Manager, Health & Safety Facility Contact Phone Number: 219-391-6118 Facility Contact Email Address: malinowski.gary@cleanharbors.com Number of Company Employees at the Entire Facility: 32

Please enter any other comments regarding general ownership information here: N/A

Page 1 of 16

### U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Facility Information
Is the facility a major source for HAP? (see definition below) Major sources are any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year (TPY) or more of any hazardous air pollutant or 25 TPY or more of any combination of HAP. Are there one or more off-site waste management or recovery operations at the facility subject to the Off-Site Waste and Recovery Operations (OSWRO) MACT (40 CFR 63, subpart DD)?
Is the facility exempt from complying with the OSWRO MACT?

What type(s) of off-site waste does the facility accept? (please include shipment method, physical form (i.e., solid, liquid, sludge), and a general description)

Approximately how many sources (facilities) does that waste come from?
What is the base year for which information is being provided? (please limit reporting years between 2006 and 2012, and provide the most current year)
For this base year, what was the amount of off-site waste received? (please specify units; e.g., gal/yr)
For this base year, what was the HAP content of the off-site waste received? (please specify units; e.g., tons)
How many hours per year are control devices bypassed to the atmosphere to perform routine maintenance?
Are any OSWRO operations scheduled to be discontinued?

Are any OSWRO operations scheduled to be added or expanded?

What is the permitting classification of your facility?

What are the operating permit IDs for the OSWRO operations at your facility?

Is your operating permit available online?

Please provide the coordinates (in decimal degrees) of your facility property boundary at each corner (node). Alternatively, please provide the minimum distance from any OSWRO emission point to the facility property boundary.

Please enter any other comments regarding the facility here: N/A N/A

2011

1,621,378 gallons/yr

914 tons/yr If yes, please explain:

58.25 hours in 2011

Corner 1: 41.818351, -87.66227 Corner 2: 41.817064, -87.66227 Corner 3: 41.817064, -87.662521 Corner 4: 41.815976, -87.662521 Corner 5: 41.815976, -87.661279 Corner 6: 41.816221, -87.660633 Corner 7: 41.816693, -87.660415 Corner 8: 41.817963, -87.660415 Corner 9: 41.817963, -87.661867 Corner 10: 41.818351, -87.661867 The Chicago Recycle Center functions as a storage, recycling and reclamation facility for a variety of used chemicals and solvents, solvent mixtures, solid and semi-solid materials, aqueous chemicals and other organic wastes. Materials are received at the facility in containers of various sizes or in bulk tanker vehicle shipments.

25-30

Link to Permit 95120093

If yes, please provide a link to or a copy of your most recent operating permit. If no, please provide a copy of your most recent operating permit. If yes, please provide date(s) that addition(s) and/or expansion(s) will begin production and explain changes: If yes, please provide dates of closure and explain changes: N/A

N/A

Page 2 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain. N/A

If no, please explain. N/A

If "Other", please explain: N/A

If "Other", please explain: See included "Fugitive (Leak) Emission Estimation Documentation" table

If neither apply, please explain: N/A

If yes, please describe the control technique(s): N/A Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: N/A

Pumps 77 Compressors N/A Agitators N/A Pressure relief devices 31 Sampling connection systems N/A Open-ended valves or lines 1731 Connectors 4174 Instrumentation systems N/A

3,678 Valves Please enter any other comments regarding equipment leaks here: What is the number of each type of component for the equipment in OSWRO HAP service (equipment that contacts off-site material having a total HAP concentration ≥ 10% by weight for 300 hours/year or more)? With which subpart do you comply for equipment leaks? Please provide documentation demonstrating the basis for the equipment leak emissions estimates. What type of documentation are you providing? Equipment Leaks
Have you verified and/or corrected the equipment leak emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your OSWRO equipment leaks in Enclosure 2A?

What emissions calculation approach was used to estimate the equipment leak emissions?

Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard?

Page 3 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain. N/A - The transfer systems are closed pipes, and no emissions are expected. Any emissions are accounted for in the process, tanks, and/or fugitive emissions.

If no, please explain. N/A - The transfer systems are closed pipes, and no emissions are expected. Any emissions are accounted for in the process, tanks, and/or fugitive emissions.

If "Other", please explain: N/A - The transfer systems are closed pipes, and no emissions are expected. Any emissions are accounted for in the process, tanks, and/or fugitive emissions.

If "Other", please explain: N/A - The transfer systems are closed pipes, and no emissions are expected. Any emissions are accounted for in the process, tanks, and/or fugitive emissions.

If yes, please describe the control technique(s): N/A Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: N/A

N/A Please enter any other comments regarding transfer systems here: Transfer Systems
Have you entered the OSWRO transfer system emissions in Enclosure 2A?

Have you completed all control information fields for your OSWRO transfer systems in Enclosure 2A?

What emissions calculation approach was used to estimate the transfer system emissions?

Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard? Please provide documentation demonstrating the basis for the transfer system emissions estimates.Are you providing emissions factors or source test data?U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain. N/A - The facility has no oil-water or organic-water separators.

If "Other", please explain: N/A - The facility has no oil-water or organic-water separators.

If "Other", please explain: N/A - The facility has no oil-water or organic-water separators.

If yes, please describe the control technique(s): N/A Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: N/A

N/A - The facility has no oil-water or organic-water separators. N/A - The facility has no oil-water or organic-water separators.

Please enter any other comments regarding organic or oilwater separators here: Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard? Please provide documentation demonstrating the basis for the oil-water and organic-water separators emissions estimates.Are you providing emissions factors or source test data? Oil-water and organic-water separators
Have you entered the OSWRO oil-water and organic-water separators emissions in Enclosure 2A?

Have you completed all control information fields for your OSWRO oil-water and organic-water separators in Enclosure 2A?

What emissions calculation approach was used to estimate the oil-water and organic-water separators emissions?U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

If "Other", please explain:

Please list eachOSWRO container requiring Level 1 or Level 2 control:

Container ID Container capacity Container emissions control level implemented Tight Head Drum (D.O.T. spec.) 55 gallons Level 1 Open Head Drum (D.O.T. spec.) 55 gallons Level 1
I.B.C. Totes (D.O.T. spec.) 250 gallons Level 2
I.B.C. Totes (D.O.T. spec.) 350 gallons Level 2 Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: N/A Emissions from containers are assumed to be negligible because the facility receives very few containers and emissions from unloading containers is accounted for in the receiving tank emission rates. If "Other", please explain:

Please enter any other comments regarding containers here: N/A (add information for more containers as necessary) Containers
Have you entered the OSWRO containers emissions in Enclosure 2A?

Have you completed all control information fields for your OSWRO containers in Enclosure 2A?

What emissions calculation approach was used to estimate the containers emissions?

Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard? Please provide documentation demonstrating the basis for the containers emissions estimates.Are you providing emissions factors or source test data? N/A

N/A

Emissions from containers are assumed to be negligible because the facility receives very few containers and emissions from unloading containers is accounted for in the receiving tank emission rates.

N/A If yes, please describe the control technique(s):U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain. N/A - The facility has no surface impoundments.

If no, please explain. N/A - The facility has no surface impoundments.

If "Other", please explain: N/A - The facility has no surface impoundments.

If "Other", please explain: N/A - The facility has no surface impoundments.

N/A - The facility has no surface impoundments.

N/A - The facility has no surface impoundments.

N/A - The facility has no surface impoundments. Please enter any other comments regarding surface impoundments here: If yes, please describe the control technique(s):
Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: Surface Impoundments
Have you entered the OSWRO surface impoundments emissions in Enclosure 2A?

Have you completed all control information fields for your OSWRO surface impoundments in Enclosure 2A?

What emissions calculation approach was used to estimate the surface impoundments emissions?

Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard? Please provide documentation demonstrating the basis for the surface impoundments emissions estimates.Are you providing emissions factors or source test data?U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

N/A Please enter any other comments regarding process vents here: If "Other", please explain:

If yes, please describe the control technique(s):
Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP:
N/A Please provide documentation demonstrating the basis for the process vent emissions estimates. Are you providing emissions factors or source test data?

See included "Process Vent Emission Estimation Documentation" diagram
Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard?
N/A N/A

If "Other", please explain: Process Vent Emissions Information
Have you verified and/or corrected the process vent emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your OSWRO process vent streams in Enclosure 2A?

What emissions calculation approach was used to estimate the process vent emissions? N/A

N/A

Page 8 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Tanks Emissions Information

N/A

Please list eachOSWRO tank requiring Level 1 or Level 2 control:

Tank ID Tank capacity Tank content MTVP 1 Tank content AVP2 Tank height Tank diameter Tank average annual throughput* Tank emissions

control equipment 1 11,648 gal 0.002 0.001 16 ft 11.5 ft 226.64 gal None 2 11,648 gal 0 0 16 ft 11.5 ft 1,320.96 gal None 3 11,648 gal 0 0 16 ft 11.5 ft 1,320.96 gal None 4 11,648 gal 0.002 0.001 16 ft 11.5 ft 226.64 gal None 5 7,134 gal 0 0 16 ft 9 ft 1,811.44 gal None 6 7,768 gal 0 0 13 ft 10.5 ft 1,972.43 gal None 11 3,342 gal 0.002 0.001 16 ft 6.16 ft 65.03 gal None 12 3,342 gal 0 0 16 ft 6.16 ft 848.59 gal None 13 3,342 gal 8.7358 4.5035 16 ft 6.16 ft 317.19 gal None 14 3,342 gal 0.002 0.001 16 ft 6.16 ft 65.03 gal None 15 3,342 gal 0 0 16 ft 6.16 ft 218.23 gal None 16 3,342 gal 0 0 16 ft 6.16 ft 218.23 gal None 18 3,342 gal 0 0 16 ft 6.16 ft 218.23 gal None 19 3,342 gal 8.7358 4.5035 16 ft 6.16 ft 317.19 gal None 20 1,174 gal 0 0 8.5 ft 5 ft 298.10 gal None 21 470 gal 0.002 0.001 5 ft 4 ft 0.00 gal None 22 2,887 gal 0.002 0.001 14 ft 6.15 ft 56.17 gal None 23 3,225 gal 0 0 14 ft 6.5 ft 818.88 gal None 31 20,068 gal 0 0 32.5 ft 10.5 ft 2,275.85 gal None 32 20,068 gal 0 0 32.5 ft 10.5 ft 1,310.43 gal None 33 20,068 gal 0 0 32.5 ft 10.5 ft 1,310.43 gal None 36 20,068 gal 0 0 32.5 ft 10.5 ft 2,029.26 gal None 38 20,068 gal 0 0 32.5 ft 10.5 ft 2,275.85 gal None 39 20,068 gal 0.002 0.001 32.5 ft 10.5 ft 390.48 gal None 42 20,068 gal 0 0 32.5 ft 10.5 ft 1,310.43 gal None 43 20,068 gal 0 0 32.5 ft 10.5 ft 3,055.76 gal None 44 20,068 gal 0 0 32.5 ft 10.5 ft 1,310.43 gal None 45 20,068 gal 0.003 0.0019 32.5 ft 10.5 ft 564.08 gal None 50 20,068 gal 0 0 32.5 ft 10.5 ft 1,310.43 gal None 51 20,068 gal 0.003 0.0019 32.5 ft 10.5 ft 564.08 gal None 102 12,078 gal 0 0 18 ft 11 ft 3,233.36 gal None 103 12,425 gal 0 0 16 ft 11.5 ft 10,409.66 gal None 104 7,610 gal 0 0 16 ft 9 ft 6,375.65 gal None 171 3,006 gal 0.002 0.001 8 ft 8 ft 58.49 gal None 172 6,459 gal 0.002 0.001 11.2 ft 10 ft 125.68 gal None 173 6,459 gal 0.002 0.001 11.2 ft 10 ft 125.68 gal None 174 3,523 gal 8.7358 4.5035 6.7 ft 10 ft 334.37 gal None 175 3,006 gal 0 0 8 ft 8 ft 196.29 gal None 176 6,459 gal 8.7358 4.5035 11.2 ft 10 ft 613.03 gal None 177 6,459 gal 8.7358 4.5035 11.2 ft 10 ft 613.03 gal None 178 5,778 gal 0 0 14 ft 8.7 ft 377.30 gal None 179 5,778 gal 0.002 0.001 14 ft 8.7 ft 112.43 gal None 180 5,778 gal 0.002 0.001 14 ft 8.7 ft 112.43 gal None 194 5,778 gal 0.002 0.001 14 ft 8.7 ft 112.43 gal None 195 5,778 gal 0.002 0.001 14 ft 8.7 ft 112.43 gal None 30A 10,358 gal 0 0 16.25 ft 10.5 ft 676.37 gal None 30B 10,358 gal 0 0 16.25 ft 10.5 ft 676.37 gal None 34A 10,358 gal 0 0 16.25 ft 10.5 ft 2,772.90 gal None 34B 10,358 gal 0 0 16.25 ft 10.5 ft 2,772.90 gal None 35A 10,358 gal 0.002 0.001 16.25 ft 10.5 ft 201.54 gal None 35B 10,358 gal 0.0768 0.0315 16.25 ft 10.5 ft 7,073.79 gal None 37A 10,358 gal 0 0 16.25 ft 10.5 ft 1,047.39 gal None 37B 10,358 gal 0 0 16.25 ft 10.5 ft 621.67 gal None 40A 10,358 gal 0.0768 0.0315 16.25 ft 10.5 ft 7,073.79 gal None 40B 10,358 gal 0 0 16.25 ft 10.5 ft 2,571.43 gal None 41A 10,358 gal 0.002 0.001 16.25 ft 10.5 ft 201.54 gal None 41B 10,358 gal 0 0 16.25 ft 10.5 ft 1,416.67 gal None 46A 10,358 gal 0 0 16.25 ft 10.5 ft 2,005.38 gal None N/A If yes, please describe the control technique(s): N/A

Please provide documentation demonstrating the basis for the tanks emissions estimates.Are you providing emissions factors, source test data or other data?

Link to EPA TANKS Information
Are you implementing work practices or other HAP control techniques beyond those required by the MACT standard? N/A If "Other", please explain:

If "Other", please explain:

Please provide the additional capital and annual costs of this practice above that required by the OSWRO NESHAP: Have you entered the tanks emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your OSWRO storage vessels in Enclosure 2A?

What emissions calculation approach was used to estimate the tank emissions? If no, please explain.

If no, please explain. N/A

Page 9 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Tanks Emissions Information 46B 10,358 gal 0 0 16.25 ft 10.5 ft 2,005.38 gal None 47A 10,358 gal 0 0 16.25 ft 10.5 ft 621.67 gal None 47B 10,358 gal 0 0 16.25 ft 10.5 ft 2,630.07 gal None 48A 10,358 gal 0 0 16.25 ft 10.5 ft 2,630.07 gal None 48B 10,358 gal 0 0 16.25 ft 10.5 ft 2,630.07 gal None 49A 10,358 gal 0 0 16.25 ft 10.5 ft 1,047.39 gal None 49B 10,358 gal 0 0 16.25 ft 10.5 ft 390.58 gal None 52A 10,358 gal 0 0 16.25 ft 10.5 ft 2,005.38 gal None 52B 10,358 gal 0 0 16.25 ft 10.5 ft 2,005.38 gal None 53A 10,358 gal 0 0 16.25 ft 10.5 ft 1,047.39 gal None 53B 10,358 gal 0 0 16.25 ft 10.5 ft 1,047.39 gal None

1Maximum True HAP Vapor Pressure
2Average HAP Vapor Pressure For each tank with an internal floating roof, please list the slotted ladder information:

Tank ID Number of ladders

with slotted legs Gasketed deck cover

over slotted ladder(s)? Ladder sleeve over slotted ladder(s)? Pole wipers in place for

slotted ladder legs? N/A N/A N/A N/A N/A

For each tank with a fixed roof, please list the tank fitting information:

Tank ID Number of access

hatches Number of gauge

hatches Number of conservation vents Number of

valves/instruments Number of

emergency pressure relief vents 1 2 1 1 11 1 2 2 1 1 11 1 3 2 1 1 11 1 4 2 1 1 11 1 5 2 1 1 8 1 6 2 1 1 8 1 11 2 1 1 9 1 12 2 1 1 9 1 13 2 1 1 9 1 14 2 1 1 9 1 15 2 1 1 9 1 16 2 1 1 9 1 18 2 1 1 9 1 19 2 1 1 9 1 20 1 1 1 7 1 21 1 1 0 7 1 22 2 1 1 9 1 23 2 1 1 9 1 31 1 1 1 12 1 32 1 1 1 12 1 33 1 1 1 12 1 36 1 1 1 12 1 38 1 1 1 12 1 39 1 1 1 12 1 42 1 1 1 12 1 43 1 1 1 12 1 44 1 1 1 12 1 45 1 1 1 12 1 50 1 1 1 12 1 51 1 1 1 12 1 102 2 1 1 5 1 103 2 1 1 11 1 104 2 1 1 11 1 171 1 1 0 5 1 172 1 1 0 5 1 173 1 1 0 5 1 174 1 1 0 5 1 175 1 1 0 5 1 176 1 1 0 5 1 177 1 1 0 5 1 178 2 1 1 3 1 179 2 1 1 3 1 180 2 1 1 3 1 194 2 1 1 5 1 195 2 1 1 5 1 30A 2 1 1 15 1 30B 2 1 1 10 1 34A 2 1 1 15 1 34B 2 1 1 10 1 35A 2 1 1 15 1 35B 2 1 1 10 1 37A 2 1 1 15 1 37B 2 1 1 10 1 40A 2 1 1 15 1 40B 2 1 1 10 1 41A 2 1 1 15 1 41B 2 1 1 10 1 46A 2 1 1 15 1 46B 2 1 1 10 1 47A 2 1 1 15 1 47B 2 1 1 10 1 48A 2 1 1 15 1 48B 2 1 1 10 1 49A 2 1 1 15 1 49B 2 1 1 10 1 (add information for more tanks as necessary)

(add information for more tanks as necessary)

Page 10 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Tanks Emissions Information 52A 2 1 1 15 1 52B 2 1 1 10 1 53A 2 1 1 15 1 53B 2 1 1 10 1

For each tank with a floating roof (internal or external), please list the tank information:

Tank ID Annual number of

days roof rests on landing legs Length of landing legs N/A N/A N/A

Please enter any other comments regarding tanks here: Average annual throughput is based on 2011 throughput data (add information for more tanks as necessary)

(add information for more tanks as necessary)

Page 11 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Off-Site Material Treatment

If you treat off-site waste using biological degradation, please answer the following questions: What method of off-site waste HAP reduction is used?

N/A

How do you characterize the components of the waste products you receive that are treated with biological degradation? N/A

Please enter any other comments regarding off-site waste treatment here: N/A Do you perform any testing or other practices to determine whether fouling agents may be in the waste received? N/A If "Other" or more than one of the above applies, please explain.

Page 12 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Startup and Shutdown Events

If no for any of the above, please explain: Per the interpretation of startup and shutdown outlined in Section 1.0 and specific regulatory language in 40 CFR 63.6(e)(3)(A-C), containers, tanks, pumps and piping/transfer systems are excluded from the SSM plan. These sources are in continuous service, and thus do not go through startup and shutdown as defined in 40 CFR 63.2. Containers contain waste when they are received at the facility through their ultimate treatment, and tanks, pumps and associated piping are also in continuous use. Unlike control devices or process equipment, they are not technically “operated.” Equipment leaks are themselves malfunctions of transfer equipment (pumps and piping systems). As such they are excluded from “startup” and “shutdown” and are only addressed under “malfunctions.” The tank farm vent systems are operated continuously as required by the facility’s RCRA TSDF (Part B) operating permit. The systems, as a whole, are never shut down and are never started up as defined in 40 CFR 63.2.

Please provide the following information about all startup and shutdown events: Liquid to Liquid Extractors (E1700 and E1800) Thin Film Evaporator (2100) Fractional Distillation Columns (C1100, 1200, 1300, 1400, 1500, and FC70) Flare The flare is operated continuously under normal operating conditions. The process emission units regularly go through startup and shutdown every few days.

The flare only experiences startup and shutdown after a malfunction or when taken down for planned maintenance. These occurrances are infrequent. The process emission units are shutdown and started up frequently per business needs. One chemical waste stream is run for a customer, then a clean-out, then another stream run, or a secondary run on the same customers material to further purify it. The process units are compliant with the MACT requirements during startup and shutdown.Start-up and shutdown events for the operating equipment differ for each waste stream or fraction of the semifinished product. Some runs are at atmospheric pressure, some vacuum, and some under pressure. They also run at different temperatures. Emissions to the atmosphere from process equipment are directed to the flare, unless the flare is down, then emissions are to the atmosphere via the flare bypass for malfunction and maintenance. For process emission units, events occur daily or every few days. Startup and shutdown events for the flare are infrequent, with 17 occurring in 2011 for planned plant shutdowns or flare maintenance. Equipment Leaks
Transfer Systems
Organic and Oil-Water Separators

Containers

Surface Impoundments

Process Vents Organic and Oil-Water Separators

Tanks Process Vents

1. What emissions source types experience startup and shutdown events?

2. How often do startup or shutdown events occur? The United States Court of Appeals for the District of Columbia Circuit vacated portions of two provisions in the EPA’s CAA section 112 regulations governing the emissions of HAP during periods of startup, shutdown and malfunction (SSM). Sierra Club v. EPA, 551 F.3d 1019 (D.C. Cir. 2008). Specifically, the Court vacated the SSM exemption contained in 40 CFR 63.6(f)(1) and 40 CFR 63.6(h)(1), that are part of a regulation, commonly referred to as the “General Provisions Rule,” that the EPA promulgated under section 112 of the CAA. When incorporated into CAA section 112(d) regulations for specific source categories, these two, now vacated, provisions exempted sources from the requirement to comply with the otherwise applicable CAA section 112(d) emission standard during periods of SSM. To be consistent with the Court’s decision, facilities must comply with the applicable standards at all time s
.

For each emission source type, do the annual emissions estimate in the Enclosure 2A "Emissions (TPY)" field include the annual emissions from startup and shutdown events that you added in the "STARTUP EMISSIONS (TPY)" and "SHUTDOWN EMISSIONS (TPY)" fields? Please enter a separate response for each emissions point type below:

For each emission source type, can you comply with the emissions limitation and/or work practices in the regulation that apply during normal operation during startup and shutdown events? Please enter a separate response for each emissions point type below: Surface Impoundments

1.d. How are emissions released to the atmosphere (e.g., through a pressure relief device)? 1.c. How does the startup or shutdown event compare to normal operations (e.g., differences in flowrate, temp., pressure, alternate fuels used, alternate control devices used, etc.)? 1.a. Under normal operating conditions, do these emissions sources operate continuously?

1.b. What triggers the equipment to experience a startup or shutdown event (e.g. hot startup, startup after an emergency shutdown, re-start, control device startup)? Tanks

Equipment Leaks
Transfer Systems

Containers

Page 13 of 16U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Startup and Shutdown Events For 2011, the average duration of each flare shutdown was 14.3 hours. Duration of startup and shutdown for process emission units is not tracked since these events are routine and process emission units comply with the MACT emission limits during the events. For the flare, shutdown is complete when the flare goes into alarm because of a flame out, or power outage, or the process vent blowers to the flare fail or shut down.

None. An emissions chart calculated from the type of material run is used. These emission factors are then added to the flare SSM log if any equipment is being run when the flare goes down During any startup or shutdown, the flare is operated in a manner consistent with good air pollution control practices, as stated in 40 CFR 63.6(e)(3)(A). Operation of flare in a manner consistent with good air pollution control practices, as stated in 40 CFR 63.6(e)(3)(A).

N/A - The process emission units are compliance with the MACT requirements during startup and shutdown of the equipment.

N/A

N/A

N/A

Please enter any other comments regarding startup or shutdown here: N/A 6. How do you determine the HAP emissions during the event?
7. How are control devices and work practices used to minimize emissions during the startup or shutdown event? 8. What compliance determination method(s) do you use during startup and shutdown events (e.g., monitor with CEMS)?

9.a. Please describe how HAP emissions would be minimized.

9.b. How much would it cost to minimize HAP emissions in this manner? 9.c. How much would HAP emissions be reduced compared to an uncontrolled event? (If "emission factor" is used as basis for emissions estimate, please provide the emission factor and sources of the emission factor. 1) 4. What marks the end of the startup or shutdown event?

9. During startup and shutdown events, if you cannot comply with the emissions limitation and/or work practices in the regulation that apply during normal operation, what is the minimum emissions level that could be achieved?

1If "source test" is used as basis for emissions estimate, please provide a copy of the source test. 5. What safety issues are connected with a startup or shutdown event? 3. What is the average and range of event duration?

Page 14 of 16Source Service Chemical Emission Factor (lb/hr/component) Emission Factor Units Control Efficiency Pumps Light Liquid TOC 0.0439 pound per hour per component 93% Valves Light Liquid TOC 0.0089 pound per hour per component 97% Open-end Lines N/A TOC 0.0038 pound per hour per component 97% Connectors/Flanges Light Liquid TOC 0.0005 pound per hour per component 0% Relief Valves N/A TOC 0.2293 pound per hour per component 97%

**VOM Emissions (ton) = Number of Components x The Appropriate Emission Factor x (1 - Appropriate Control Efficiency) x Hours Of Service/2000. *Source: EPA Document, EPA-453/R-93-026, June 1993, Page 2-10 for uncontrolled fugitive equipment in SOCMI light liquid service, and control efficiencies for Texas Natural Resources Conservation Commission Leak Detection and Repair Programs, 28MID, Technical Guidance Package for Chemical Sources, Equipment Leak Fugitives, March 1995. Fugitive (Leak) Emission Estimation DocumentationProcess Vent Emission Estimation Documentation Originally submitted in August 29, 2006 CAAPP renewal application

# Enclosure 2aEnclosure 2a

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name Emission Unit ID Process ID Emissio n Release Point ID SCC Code1 Emissions Start Date Emissions

End Date Pollutant

CAS Number2 Pollutant Name

(include organic and non-organic pollutants) Actual

Emissio ns (TPY) MACTAllowable Emissions (TPY) 3 Routine

Emission s Max Hourly (lbs/hr) Startup

Emissio ns (TPY) Startup

Emissio ns (lbs/hr) Shutdo

wn Emissio ns (TPY) Shutdow

n Emissio ns (lbs/hr) MACT Source Category Emission Release Point Type4 Stack

Height (ft) Exit Gas

Temperatu re (°F) Stack

Diameter (ft) Exit Gas

Velocity (ft/sec) Exit Gas

Flow Rate (ft3/sec) Fugitive

Length (EW) (ft) Fugitive

Width (NS) (ft) EXAMPLE ENTRY: American Welding Paducah Plant 25 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2 Off-Site Waste and Recovery Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA Clean Harbors Recycling Services of Chicago LLC Unit 1 E1700 0010 50310007 1/1/2011 12/31/2011 N/A N/A 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 E1800 0062 50310007 1/1/2011 12/31/2011 N/A N/A 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 C1100 0059 50310007 1/1/2011 12/31/2011 75092 Methylene chloride 1.1E-03 3.5E-01 3.2E-02 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A 108952 Phenol 2.4E-08 5.7E-07 5.2E-08 N/A N/A N/A N/A 68122 Dimethyl formamide 2.0E-09 2.3E-07 2.1E-08 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 C1200 0058 50310007 1/1/2011 12/31/2011 67561 Methanol 8.9E-06 5.1E-03 4.7E-04 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A 75092 Methylene chloride 9.6E-04 9.7E-02 8.8E-03 N/A N/A N/A N/A 127184 Perchloroethylene 5.2E-07 3.0E-04 2.7E-05 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 C1300 0008 50310007 1/1/2011 12/31/2011 67561 Methanol 2.1E-05 1.9E-03 1.7E-04 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A 75092 Methylene chloride 1.5E-03 2.0E-01 1.9E-02 N/A N/A N/A N/A 75058 Acetonitrile 5.6E-05 1.9E-03 1.8E-04 N/A N/A N/A N/A 108952 Phenol 2.7E-08 6.7E-06 6.2E-07 N/A N/A N/A N/A 68122 Dimethyl formamide 2.3E-09 1.4E-07 1.3E-08 N/A N/A N/A N/A 110543 Hexanes (Isomers) 1.8E-06 4.0E-03 3.7E-04 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 C1400 0009 50310007 1/1/2011 12/31/2011 67561 Methanol 5.3E-05 1.1E-03 1.0E-04 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A 75092 Methylene chloride 1.2E-04 8.0E-02 7.3E-03 N/A N/A N/A N/A 107211 Ethylene glycol 6.7E-11 1.8E-08 1.6E-09 N/A N/A N/A N/A 108883 Toluene 2.2E-07 4.3E-04 3.9E-05 N/A N/A N/A N/A 110543 Hexanes (Isomers) 2.3E-06 1.6E-03 1.4E-04 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 C1500 0060 50310007 1/1/2011 12/31/2011 N/A N/A 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 FC70 0011 50310007 1/1/2011 12/31/2011 N/A N/A 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 1 L2100 0002 50310007 1/1/2011 12/31/2011 67561 Methanol 4.4E-05 1.1E-03 1.0E-04 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Vertical 26.1 303 3 4.91 0.9635 N/A N/A 75092 Methylene chloride 3.7E-04 1.6E-02 1.5E-03 N/A N/A N/A N/A 127184 Perchloroethylene 2.4E-06 4.9E-05 4.5E-06 N/A N/A N/A N/A 108883 Toluene 7.5E-08 1.0E-04 9.6E-06 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 2 TF-1 0070 50310003 1/1/2011 12/31/2011 67561 Methanol 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations N/A N/A N/A N/A N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 2 TF-2 0076 50310003 1/1/2011 12/31/2011 67561 Methylene chloride 8.8E-01 8.8E-01 2.0E-01 N/A N/A N/A N/A Off-Site Waste and Recovery Operations N/A N/A N/A N/A N/A N/A N/A N/A 108883 Toluene 8.0E-06 8.0E-06 1.8E-06 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 2 TF-3 0003 50310003 1/1/2011 12/31/2011 N/A N/A 0.0E+00 N/A N/A N/A N/A N/A N/A Off-Site Waste and Recovery Operations N/A N/A N/A N/A N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 2 TF-4 0003 50310003 1/1/2011 12/31/2011 67561 Methylene chloride 2.8E-01 2.8E-01 6.5E-02 N/A N/A N/A N/A Off-Site Waste and Recovery Operations N/A N/A N/A N/A N/A N/A N/A N/A 108883 Toluene 6.9E-06 6.9E-06 1.6E-06 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC Unit 2 TF-5 0003 50310003 1/1/2011 12/31/2011 67561 Cumene 3.7E-04 3.7E-04 8.5E-05 N/A N/A N/A N/A Off-Site Waste and Recovery Operations N/A N/A N/A N/A N/A N/A N/A N/A 100414 Ethylbenzene 2.6E-04 2.6E-04 6.0E-05 N/A N/A N/A N/A 67561 Methanol 1.5E-03 1.5E-03 3.5E-04 N/A N/A N/A N/A 108101 Methyl isobutyl ketone 1.9E-04 1.9E-04 4.4E-05 N/A N/A N/A N/A 67561 Methylene chloride 1.6E-04 1.6E-04 3.6E-05 N/A N/A N/A N/A 108883 Toluene 3.8E-03 3.8E-03 8.7E-04 N/A N/A N/A N/A 108383 Xylene (-m) 7.2E-04 7.2E-04 1.6E-04 N/A N/A N/A N/A

Clean Harbors Recycling Services of Chicago LLC N/A Fugitives 0061 50310001 1/1/2011 12/31/2011 75058 Acetonitrile 1.9E-02 1.9E-02 4.3E-03 N/A N/A N/A N/A Off-Site Waste and Recovery Operations Fugitive N/A N/A N/A N/A N/A 600 540 68122 Dimethyl formamide 1.4E-06 1.4E-06 3.3E-07 N/A N/A N/A N/A 107211 Ethylene glycol 2.4E-08 2.4E-08 5.5E-09 N/A N/A N/A N/A 67561 Methanol 4.1E-02 4.1E-02 9.4E-03 N/A N/A N/A N/A 67561 Methylene chloride 1.2E+00 1.2E+00 2.7E-01 N/A N/A N/A N/A 127184 Perchloroethylene 9.2E-04 9.2E-04 2.1E-04 N/A N/A N/A N/A 108952 Phenol 1.0E-05 1.0E-05 2.4E-06 N/A N/A N/A N/A 108883 Toluene 2.7E-05 2.7E-05 6.2E-06 N/A N/A N/A N/A Clean Harbors Recycling Services of Chicago LLC N/A Containers N/A 50310002 1/1/2011 12/31/2011 75058 Total HAPs Negligible Negligible Negligible N/A N/A N/A N/A Off-Site Waste and Recovery Operations Container N/A N/A N/A N/A N/A N/A N/A

1For SCC Code, please input one of the following codes: SCC SCC Description 50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers 50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks 50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators 50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments 50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems 50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards (annual average if the parameter varies) Vertical Emissions Release Point Parameters Fugitive Emissions Release Point Parameters

Page 1Enclosure 2a

4 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic:

6 Location of stack or southwest corner of a fugitive emissions release point

7For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon Adsorption list specific type in Control Measure Comments column

Combustor list specific type in Control Measure Comments column Electrostatic Precipitator Fabric Filter/Baghouse Flare Pressurized Tank Fixed Roof Tank Fixed Roof Tank Vented to Control Device External Floating Roof Tank Fixed Roof Tank with Internal Floating Roof Vapor Balancing Floating Membrane Cover Cover Vented to Control Device High-Efficiency Particulate Air Filter (HEPA) Leak Detection and Repair Program Condenser

Scrubber list specific type in Control Measure Comments column

Multiple Controls in Series list specific types in Control Measure Comments column

Other Control Device describe in Control Measure Comments column

Pollution Prevention Technique describe in Control Measure Comments column

Process Modification describe in Control Measure Comments column

Page 2Enclosure 2a

Fugitive Angle (degrees) 5 Longitude (decimal degrees)6 Latitude

(decimal degrees)6 Is

Control Measur e In Place? Control Measure 7 Control Measur e Efficien cy Comments

NA -72.078903 41.44273758 yes flare 98% reduction efficency based on manufacturer guarantees

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661257 41.817233 Yes Flare 98%

N/A -87.661687° 41.816690° Yes Fixed Roof Tank N/A

N/A -87.662200° 41.816408° Yes Fixed Roof Tank N/A

N/A -87.662427° 41.816275° Yes Fixed Roof Tank N/A

N/A -87.661273° 41.816172° Yes Fixed Roof Tank N/A

N/A -87.660685° 41.816525° Yes Fixed Roof Tank N/A

0 -87.662521 41.816102 Yes Leak Detection and Repair Program Varies Refer to control efficiencies included in "Fugitive (Leak) Emission Estimation Documentation" table of submittal

N/A N/A N/A Yes Pollution Prevention Technique N/A Containers are kept closed.

, Fugitive Emissions Release Point Parameters

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