Enclosure 1
ENCLOSURE 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 offsite 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 2
U.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 16
U.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 16
U.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 each OSWRO 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 16
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Tanks Emissions Information

N/A

Please list each OSWRO tank requiring Level 1 or Level 2 control: 

Tank ID Tank capacity Tank content MTVP1Tank 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 16
U.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

1

 Maximum True HAP Vapor Pressure 

2

 Average 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 16
U.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 16
U.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 16
U.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 times.

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 16
U.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? 

1

 If "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 16
Source 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 Documentation
Process Vent Emission Estimation Documentation

Originally submitted in August 29, 2006 CAAPP renewal application
Enclosure 2a
Enclosure 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 Type

4 

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

1

 For 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 1
Enclosure 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

7

 For 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 2
Enclosure 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

Page 3