Trioxy, Inc. Treatment Facility Audit Packet · Healthcare waste is managed through use of ozone treatment ... and infectious waste treatment facility is an allowable use within this

Trioxy, Inc.

Treatment Facility Audit Packet

Revision: December 12, 2018

ii TRIOXY AUDIT PACKET 12.2018

Table of Contents 1.0 Introduction ....................................................................................................................................... 1

2.0 Trioxy Background ........................................................................................................................... 1

3.0 Our Location ..................................................................................................................................... 1

4.0 Facility And Treatment Process Description .................................................................................... 2

5.0 Sustainable Solutions ........................................................................................................................ 4

6.0 Dangerous Drug Management .......................................................................................................... 5

7.0 Treatment Permit Summary .............................................................................................................. 5

8.0 Insurance Limits ................................................................................................................................ 6

9.0 Community Involvement .................................................................................................................. 8

10.0 Security ............................................................................................................................................. 8

Appendices Appendix A: Facility Maps and Photos Appendix B: Acceptable Waste Codes Appendix C: Waste Processing Permits Appendix D: Certificate of Insurance Appendix E: Waste Profile Form

1 TRIOXY AUDIT PACKET 12.2018

1.0 INTRODUCTION

Trioxy, Inc. is an innovative Missouri company that specializes in the treatment and beneficial reuse of waste, including healthcare waste, hazardous waste, and solid waste, by producing a sustainable quality fuel to replace coal use in cement kilns. Whether the healthcare waste is hazardous, infectious, or inadvertently mixed together as a dual waste, Trioxy is permitted to process the waste into a fuel that we call OxyFuelTM. Similarly, hazardous fuel bearing waste is also processed into OxyFuelTM while non-hazardous solid waste is recycled into a product Engineered Fuel. Trioxy’s primary focus is treating RCRA listed and characteristic hazardous waste. However, infectious waste and other solid healthcare wastes are also processed with the RCRA-regulated waste into OxyFuelTM, which burns cleaner than coal. Healthcare waste is managed through use of ozone treatment technology, by which all healthcare waste is fully sterilized prior to being converted into OxyFuelTM. Rather than being incinerated or landfilled, healthcare waste can now be beneficially reused as energy. Non-hazardous solid waste that is difficult to recycle is processed into Engineered Fuel that meets all of the legitimacy requirements under 40 CFR 241. Trioxy removes contaminants, blends, and shreds the non-hazardous waste into Engineered Fuel, containing fewer contaminants than the coal it replaces. 2.0 TRIOXY BACKGROUND

Trioxy is a Missouri “C” corporation. It was incorporated in December 2016. Trioxy is the owner and operator of the treatment facility and is responsible for maintaining compliance with permits as well as providing insurance and financial assurance as required under the regulations. 3.0 OUR LOCATION

Trioxy – Louisiana, MO Treatment Facility 3651 West Industrial Drive Louisiana, MO 63353 USEPA ID#: MOR000556985 Missouri ID#: 045848 SIC Code: 4953 NAICS Code: 562211 Trioxy is located at 3651 West Industrial Drive in Louisiana, Missouri. The facility is located on a 4-acre tract in an industrial park with industrial zoning classified as I-2. Operation of a hazardous, solid waste, and infectious waste treatment facility is an allowable use within this industrial zoning district. The 4-acre site is located at the corner of State Highway NN and West Industrial Drive. Industries are located both on the east and west sides of the 4-acre tract. An industrial lot, with a newly constructed building, is located on the northeast side of the tract. To the south of the site is a property owned by the City of Louisiana on which the Noix Creek traverses. To the south of this City property is a wooded, residential area.


4.0 FACILITY AND TREATMENT PROCESS DESCRIPTION

The purpose of the Trioxy facility is to operate a hazardous waste, solid waste, and infectious waste treatment facility to serve the needs of generators. The facility has been designed to manage both infectious waste and hazardous healthcare waste, including those wastes that have been comingled as dual waste. This facility provides best management practices for healthcare waste for conditionally exempt small quantity (very small quantity) hazardous waste generators; small and large quantity generators; and infectious waste generators. The treatment facility also operates as a fully permitted RCRA Part B Treatment facility managing all types of hazardous and non-hazardous waste. Waste that has fuel value is treated on-site while non-fuel bearing waste is stored and shipped to appropriately licensed and approved treatment facilities. The facility is designed to receive and treat the following volumes of materials on a daily basis. The capacity shown is based upon a 3-shift, 24 hours per day operation.

• Healthcare waste received = 48 tons per day

• Incoming liquid waste fuel materials = 120 tons per day

• Outgoing blended OxyFuel = 168 tons per day

• Engineered Fuel = 120 tons per day

All operations are performed inside an enclosed building and consist of three main components. The first is container receiving and storage for incoming waste materials. The second is an ozone treatment unit to sterilize infectious waste received at the facility. The ozone system also provides the shredding capabilities for Engineered Fuel. The third operation is a hazardous or non-hazardous waste fuel blending facility, which will produce a waste fuel for shipment to off-site facilities permitted to burn waste fuels. The remaining part of the facility holds the administrative offices, laboratory, locker room, break room, etc. The loading dock is an enclosed loading dock with two overhead doors to the interior of the building. Once inside the building, a receiving and weighing station is utilized to record incoming weights and provide appropriate barcode scanning and recordkeeping information through use of the facility’s waste tracking software. A container storage area has floor space for 80 pallets of waste. When stacked two pallets high, 160 cubic yards of waste on pallets or an equivalent of 32,314 gallons in drums can be stored. Hazardous waste may be stored for up to one year in this area, while putrescible waste is processed within 24 hours of receipt. All infectious waste with a biohazard label is considered putrescible. For noninfectious waste that is not hazardous, the waste is either removed on a weekly basis or placed into the hazardous waste storage area and managed as part of the total permitted hazardous waste storage volume. The ozone treatment system consists of an enclosed shredding unit followed by a treatment bin. The ozone is generated using a high-voltage, low-amperage electrical generating unit. Any ozone remaining in the unit following treatment will be converted back to oxygen with a catalyst filter prior to release to the facility emissions control system. Located at the discharge end of the ozone treatment bin is a tube conveyor that will direct all of the solid materials from the treatment bin to the fuel blending operation located in a separate fuel blending building.


The fuel blending operation is located in a newly constructed building that is designed to meet electrical and fire safety codes. Within this building, the enclosed tube conveyor will discharge into a blending pump system. This blending pump system consists of a blending unit specifically designed to incorporate the solids into the liquid fuel matrix. A liquid waste fuel (diluent) delivered to the site in tankers, drums, and totes will be pumped to this blending unit where the treated solids from the tube conveyor will be introduced. The blending unit will then wet the solids with liquids. The resulting liquid-solid blend is fed into the suction side of the blend pump. The blend pump is followed by an inline grinder unit. This inline grinder ensures that a consistent particle size of less than 8 mm is attained within the blended fuel material. Following the inline grinder, the fuel will be pumped into a blend tanker truck for shipment to the off-site permitted fuel facility. Recirculation capabilities are provided from this blend tanker back to the blending unit. Solids are added to this blend system until specifications are met for total solids content of the OxyFuel. At this point, the fuel will be sampled and tested in accordance with the Waste Analysis Plan prior to shipping the load off-site. Engineered Fuel is processed through the ozone shredding system equipment, but not sterilized. The enclosed tube conveyor directs the blended and shredded Engineered Fuel to the discharge location in the blend building where the recycled solid fuel is loaded into a roll-off box or end dump trailer for shipment as a product to the cement kiln to replace coal. The entire storage, ozone system, and blending operations are located within a total enclosure with all emissions from the building being directed to an activated carbon system. One hundred percent capture of emissions from the process will therefore be treated with activated carbon, reducing odors and volatile organic compound (VOC) emissions by > 95%. Maps and pictures of the facility are included in Appendix A.


5.0 SUSTAINABLE SOLUTIONS

Acceptable Waste Overview

• RCRA hazardous pharmaceutical, U-listed, P-listed wastes, and characteristic waste

• Chemotherapy waste

• Biomedical (infectious) waste including pathological waste, animal waste, cultures and stocks, etc.

• Inadvertently mixed hazardous and infectious waste (dual waste)

• Bulk and containerized hazardous liquid waste

• Containerized hazardous waste solids

• Bulk and containerized non-hazardous liquids

• Containerized non-hazardous solids

A full list of acceptable RCRA waste codes is included in Appendix B. Sustainability Concept

• Trioxy’s process creates an opportunity for healthcare waste (hazardous and/or infectious) and other hazardous and solid waste to be utilized for energy recovery at permitted cement kilns. Replacing coal with a cleaner fuel is considered to be a more environmentally preferred management strategy than landfilling or incineration.

• At Trioxy, all waste is treated in totally enclosed facilities with fugitive emission controls.

• The infectious waste is safely sterilized with ozone prior to producing OxyFuelTM.

• Non-hazardous solid waste is treated and recycled as a product Engineered Fuel.

• OxyFuelTM and Engineered Fuel burn cleaner than coal.

• The OxyFuelTM and Engineered Fuel reduce greenhouse gas emissions (CO2) at the cement kilns, as the majority of the waste is biogenic resulting in that portion being carbon neutral.

• OxyFuelTM and Engineered Fuel have less chlorine, sulfur, mercury, and other heavy metals than the coal it replaces.

• Pharmaceutical waste is kept out of sewers and landfills where healthcare waste can cause environmental issues.

• Difficult to recycle non-hazardous waste is beneficially reused to replace coal.


6.0 DANGEROUS DRUG MANAGEMENT

Trioxy is in the process of seeking approval as a disposal facility for controlled substances from the Drug Enforcement Administration (DEA). Licenses from the Missouri Bureau of Narcotics and Dangerous Drugs and Missouri Board of Pharmacy have been obtained to manage and treat pharmaceuticals through the treatment process. Trioxy submitted a document prepared by two independent PhD’s showing that the Trioxy treatment process renders controlled substances non-retrievable. A review is now underway at the DEA Headquarters in Washington D.C. 7.0 TREATMENT PERMIT SUMMARY

Trioxy holds multiple waste processing permits in the State of Missouri as listed below. Waste Processing Permits

• Missouri Department of Natural Resources Solid Waste Processing Facility Permit

o Operating Permit was issued on February 1, 2018

o No expiration on the Solid Waste Permit

• Missouri Department of Natural Resources Hazardous Waste Permit

o The RCRA Part B Permit was issued on May 11, 2018

o Expiration Date is May 10, 2028

Air Permit Documentation was submitted to Missouri Department of Natural Resources (MDNR) showing that the total emissions from the facility was de minimis and a permit is not required. NPDES Permit Documentation was provided to MDNR showing that all waste treatment operations are conducted inside the building and no exposure to stormwater occurs. No process waters are discharged. MDNR agreed that Trioxy is exempt from NPDES stormwater permitting requirements. Copies of these permits are included in Appendix C.


8.0 INSURANCE LIMITS

Following is a summary of the insurance limits for Trioxy, Inc. A Certificate of Liability Insurance is included in Appendix D. General Liability Insured: Trioxy, Inc. Insurer: Indian Harbor Insurance Co. Limits: General Liability $1,000,000 Damage to Rented Premises $100,000 Medical Expense $5,000 Personal & Advertising Injury $1,000,000 General Aggregate $2,000,000 Products $2,000,000 Automobile Liability Insured: Trioxy, Inc. Insurer: XL Insurance America, Inc. Limits: Combined Single Limit $1,000,000 Umbrella Liability Insured: Trioxy, Inc. Insurer: XL Specialty Insurance Limits: Each Occurrence $5,000,000 Aggregate $5,000,000 Workers Compensation & Employers’ Liability Insured: Trioxy, Inc. Insurer: Greenwich Insurance Company Limits: Each Accident $1,000,000 Disease – Each Employee $5,000,000 Disease – Policy Limit $1,000,000


Pollution Legal Liability Insured: Trioxy, Inc. Insurer: Indian Harbor Insurance Co. Limits: Each Occurrence $1,000,000 Motor Truck Cargo Insured: Trioxy, Inc. Insurer: XL Specialty Insurance Limits: Per Vehicle $100,000 Financial Assurance for Waste Treatment Operations RCRA: $280,000 letter of credit on file with Missouri Department of Natural Resources, backed

by a Trust Agreement Solid Waste: $120,000 letter of credit on file with Missouri Department of Natural Resources


9.0 COMMUNITY INVOLVEMENT

Trioxy is committed to being a good neighbor and positive addition to the Louisiana, Missouri community. Since its start, Trioxy has reached out to the community for input. Throughout the permitting, construction, and startup process, Trioxy has hosted a Community Advisory Group made up of a number of neighbors, city officials, hospital and school administrators, and influential members of the community to act as a conduit for communications to help address any questions and concerns that may arise within the local community. Trioxy intends to support the local community through economic development including the addition of several new jobs and supporting local businesses when possible. Trioxy will also look to support the local community by working with the police department and city officials to provide a safe, secure, cost-effective, and environmentally responsible means for the local community to dispose of unwanted pharmaceuticals. Trioxy has recently met with the local environmental planning committee (LEPC) to conduct a table top discussion of our operation and is planning a full-scale drill at our site next year. Trioxy has met with our nearest neighbors now that we have been in operation for a number of months to inquire about any possible issues with our operations. Both the residential and commercial facilities have been pleased with the operations indicating that no odors or noise has been observed. 10.0 SECURITY

With the nature of the operations at Trioxy, security is an important component. The primary means of ensuring security at the facility is through controlled access to the site. The facility is closed to the general public and operations are performed within the building where all doors remain closed and locked. The truck receiving area is fenced and gated requiring trucks to utilize a call button for access to the site. Similarly, the front door to the facility remains locked when the front entrance is unattended with visitors utilizing a call button for access. Alarm systems are in place at the facility and surveillance cameras allow for on-site and remote monitoring of the facility 24 hours per day, 7 days per week. Various signs are posted throughout the facility to alert personnel and visitors to potential dangers and/or access requirements associated with the waste management processes. The facility maintains a written security plan on which key employees are trained. Security Features:

• Enclosed and Secure Building • Fences and Gates • Alarm System • 24-hour Video Surveillance • Site Lighting • Visitor Logbook

TRIOXY AUDIT PACKAGE 05.2018

Appendix A

Facility Maps and Photos

North

1000' RADIUS LAND USAGE MAP

ENVIROVAC WASTE TRANSPORT SYSTEMS, INC.

CITY OF LOUISIANA, PIKE COUNTY, MISSOURI

1

Trioxy

4 ACRE

BENCHMARK: UNDERGROUND UTILITIES NOTE:

North

DRIVEWAY (TYPE 1) PLAN

4

1

EXISTING SITE

DRIVEWAY PLAN1

1

DRIVEWAY CENTERLINE PROFILE2

1

DRIVEWAY (TYPE 1) TYPICAL SECTION

3

1

CONCRETE PAVEMENT SECTION5

1

SITE BOUNDARY MAP

ENVIROVAC WASTE TRANSPORT SYSTEMS, INC.

CITY OF LOUISIANA, PIKE COUNTY, MISSOURI

2

120'EXISTING BUILDING

100

'

CONFERENCEAND

TRAINING

BREAKROOM

LABMAINTENANCE

SUPPLY

ADMIN.

NEWCOVERED

DOCK

8 FT. OVERHEADDOOR

13'80'

NEW BUILDING ADDITION

12' O

VE

RH

EA

DD

OO

R

LIQUIDFUEL

TANKER #1TRACTOR

SLOPE

24' O

VE

RH

EA

DD

OO

R

ITROOM

TRACTOR

100

'

TREATMENTBIN

SHREDDING

FUTUREUNIT

BLENDBOX

TUBE CONVEYOR

ACT.CARBON

FAN

RECEIVINGWEIGHINGSTATION

ACT.CARBON

LIQUIDFUEL

TANKER #2

BLENDEDFUEL

TANKERTRACTOR

24'

26'

OPERATIONSMANAGER

MAINT.MANAGER

ADMIN./QUALITY

CONTROL

50'

50'

12'

OV

ER

HE

AD

DO

OR

3' MANDOOR

HOLDING AREA

REJECTED WASTE

16'

16'

SLOPE

8'-6"

2"

2"N.T.S.

NOTE: STEEL ANGLE SEALED AND BOLTED TO FLOOR

CONTAINMENT CURB:STEEL ANGLE

(SEE NOTE)

CONTAINMENT CURB:STEEL ANGLE(SEE NOTE)

22'-9

"

FORKLIFTRAMP

HOPPER

LIFT

OZONE

HVAC

NITROGENTANK PAD

36"MANDOOR

9' O

VE

RH

EA

DD

OO

R9

' OV

ER

HE

AD

DO

OR

12'

OV

ER

HE

AD

DO

OR

TR

EN

CH

36' M

AN

DO

OR

FILEROOM

RESTROOM

ELECTRICAND

FURNACE

LOCKERROOM

50'

-10"

NON-INFECTIOUSCONTAINER STORAGE - 160 CY

LANDINGAND STAIRS

SU

MP

27'

200'

70'-10"

NOTE: SCALE SHOWN REPRESENTS PLOTTED SCALE FOR 24" X 36" MEDIA.11" X 17" 2X SCALE SHOWN

Figure 1 - View Looking South at the Front of the Building from W Industrial Dr

Figure 2 - View of Blend Building

Figure 3 - Container Storage Area

Figure 4 - Receiving Area

Figure 5 - Ozone Treatment Unit

Figure 6 - Blend Building Layout

Figure 7 - Inline Grinder

Figure 8 - Laboratory


Appendix B

Acceptable Waste Codes

TRIOXYLOUISIANA, MISSOURI

HAZARDOUS WASTE ACCEPTABLE WASTE CODESRevised 11/21/18

D-CODES F-CODES K-CODES P-CODES U-CODES

D001 F001 K001 K051 K132 P001 U001 U047 U093 U140 U185 U239

D002 F002 K002 K052 K136 P008 U002 U048 U094 U141 U186 U240

D003 F003 K003 K060 K141 P012 U003 U049 U095 U142 U187 U243

D004 F004 K004 K061 K142 P042 U004 U050 U096 U143 U188 U244

D005 F005 K005 K062 K143 P046 U005 U051 U097 U144 U189 U246

D006 F006 K006 K069 K144 P075 U006 U052 U098 U145 U190 U247

D007 F007 K007 K071 K145 P081 U007 U053 U099 U146 U191 U248

D008 F008 K008 K073 K147 P088 U008 U055 U101 U147 U192 U249

D009 F009 K009 K083 K148 P092 U009 U056 U102 U148 U193 U271

D010 F010 K010 K084 K149 P108 U010 U057 U103 U149 U194 U278

D011 F011 K011 K085 K150 P188 U011 U058 U105 U150 U196 U279

D012 F012 K013 K086 K151 P204 U012 U059 U106 U151 U197 U280

D013 F019 K014 K087 K156 U014 U060 U107 U152 U200 U328

D014 F024 K015 K088 K157 U015 U061 U108 U153 U201 U353

D015 F025 K016 K093 K158 U016 U062 U109 U154 U202 U359

D016 F032 K017 K094 K159 U017 U063 U110 U155 U203 U364

D017 F034 K018 K095 K161 U018 U064 U111 U156 U204 U367

D018 F035 K019 K096 K169 U019 U066 U112 U157 U205 U372

D019 F037 K020 K097 K170 U020 U067 U113 U158 U206 U373

D020 F038 K021 K098 K171 U021 U068 U114 U159 U207 U387

D021 F039 K022 K100 K172 U022 U069 U115 U160 U208 U389

D022 K023 K101 K175 U023 U070 U116 U161 U209 U394

D023 K024 K102 K176 U024 U071 U117 U162 U210 U395

D024 K025 K103 K177 U025 U072 U118 U163 U211 U404

D025 K026 K104 U026 U073 U119 U164 U213 U409

D026 K027 K105 U027 U074 U120 U165 U214 U410

D027 K028 K106 U028 U075 U121 U166 U215 U411

D028 K029 K107 U029 U076 U122 U167 U216

D029 K030 K108 U030 U077 U123 U168 U217

D030 K031 K109 U031 U078 U124 U169 U218

D031 K033 K110 U032 U079 U125 U170 U219

D032 K034 K111 U033 U080 U126 U171 U220

D033 K035 K112 U034 U081 U127 U172 U221

D034 K036 K113 U035 U082 U128 U173 U222

D035 K037 K114 U036 U083 U129 U174 U223

D036 K039 K115 U037 U084 U130 U176 U225

D037 K040 K116 U038 U085 U131 U177 U226

D038 K041 K117 U039 U086 U132 U178 U227

D039 K042 K118 U041 U087 U133 U179 U228

D040 K043 K123 U042 U088 U134 U180 U234

D041 K046 K124 U043 U089 U135 U181 U235

D042 K048 K125 U044 U090 U136 U182 U236

D043 K049 K126 U045 U091 U137 U183 U237

DO96 K050 K131 U046 U092 U138 U184 U238

DO98

Codes added 11/21/18


Appendix C

Waste Processing Permits

May 11, 2018

CERTIFIED MAIL - 7017 0190 0000 6509 7930 RETURN RECEIPT REQUESTED

Mr. Brian Dyche Owner Trioxy Incorporated 3651 West Industrial Park Drive Louisiana, MO 63353

RE: Final Missouri Hazardous Waste Management Facility Part I Permit Trioxy Incorporated, Louisiana, Missouri EPA ID# MOR000556985

Dear Mr. Dyche:

dnr.mo.gov

The Missouri Department of Natural Resources (Department) hereby issues a final Missouri Hazardous Waste Management Facility Part I Permit for your facility, located at 3651 West Industrial Park Drive in Louisiana, Missouri. Our decision to issue the final permit was based on a thorough technical review of the facility's permit application, applicable federal and state laws and regulations, and all comments received during the public comment period. The Department listed all public comments and our responses in a Summary and Response to Comments. Our responses explain how we addressed each comment in making a final decision regarding the final Part I Permit.

On December 22, 2016, Trioxy Incorporated submitted a permit application to the Department and U.S. Environmental Protection Agency to obtain the required permits to operate a new commercial infectious and hazardous waste storage and treatment facility. The new facility is designed to manage both infectious waste and hazardous healthcare waste from hospitals, clinics, dentists, and veterinarians. Trioxy intends to blend liquid hazardous waste with treated healthcare waste to achieve the desired characteristics for use as an alternative fuel. The resulting hazardous waste-derived fuels will be shipped off-site to appropriately permitted hazardous waste facilities to be used as a substitute for fossil and other types of fuels. The Department's Solid Waste Management Program previously issued a permit to Trioxy for storing and treating the infectious waste. Construction of the infectious waste treatment component of the project began May 25, 2017. The infectious waste treatment operations began February 1, 2018, as permitted by the Department's Solid Waste Management Program.

-t.� •+i Recycled paper

Mr. Brian Dyche Page 2

The Department invited the public to review and offer written comments on a draft Part I Permit for the Trioxy facility during a 45-day public comment period, which began February 14, 2018, and ended April 2, 2018. We did not receive any requests for a public hearing. After reviewing all comments received during the public comment period, the Department responded to those comments, made minor changes to the draft permit, and issued a final Part I Permit. The final Part I Permit allows Trioxy to construct and operate the commercial hazardous waste storage and treatment facility. The final Part I Permit contains contingent conditions that may be exercised in the event there is a release to the environment that requires corrective action.

EPA decided not to issue a Hazardous and Solid Waste Amendments Part II Permit since EPA has no specific regulatory conditions for the facility, beyond those contained in the final Part I Permit, and Missouri is fully authorized for all permitting and contingent corrective action activities at the facility.

The fmal Part I Permit includes a Schedule of Compliance. Trioxy must comply with all items listed in the schedule. The as-built diagrams for the facility's equipment/operations were submitted to the Department on March 14, 2018. The Department confirmed the as-built configurations during an on-site facility inspection on March 26, 2018. During the public comment period for the draft Part I Permit, Trioxy submitted the required closure cost estimate and fmancial assurance documents specified in the final Part I Permit schedule of compliance. The Department reviewed and accepted those documents on April 4, 2018. Trioxy also submitted its third party liability insurance documents on April 27, 2018. The Department reviewed and accepted these documents on April 27, 2018.

The final Part I Permit is effective immediately. Hazardous waste operations under the fmal Part I Permit may also begin immediately as the Department hereby grants authorization to operate based on the facility inspection and its review and acceptance of the referenced documents. Please be aware that any parties adversely affected or aggrieved by the Department's decision to issue the fmal Part I Permit, or specific conditions of the fmal Part I Permit, may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by June 11, 2018 , as more fully described on page 5 of the fmal Part I Permit.

The Department conducted public participation activities for the fmal Part I Permit, as described in Code of State Regulations 10 CSR 25-8 .124(1 )(A) 15. The Department mailed a notification letter to everyone on the facility mailing list and everyone who submitted comments. We also mailed the Department's summary and response to public comments to everyone who submitted comments. In addition, we anticipate sending a news release to our Pike County and surrounding area media broadcast e-mail lists.

The Department posted the final Part I Permit and summary and response to comments received during the public comment period on the Department's website at dnr.mo.gov/env/hwp/permits/notices. Some supporting documents are not available on the

Mr. Brian Dyche Page 3

Department's website due to their file size. We sent a copy of the final Part I Permit, summary and response to comments, this letter, the letter to the facility mailing list, and letter to those who submitted comments to the Louisiana Public Library for public viewing. The final Part I Permit, summary and response to comments, and various letters are included with this letter. Also included with this letter is an invoice for the permit fee, as required by Schedule of Compliance Item I.D. Once sent to the above media broadcast e-mail lists, the news release will be available on the Department's website at dnr.mo.gov/news/news-and-media.

The final Part I Permit may include conditions you are not familiar with. We would be pleased to meet with you to discuss any questions you may have related to the permit conditions. An appointment can be set up by contacting Ms. Maria Bonney, P .E., of my staff at the Missouri Department of Natural Resources, 7545 South Lindbergh Boulevard, Suite 210, St. Louis, MO 63125-4839, by telephone at (314) 416-6205 or l-800.:.361-4827, or by e-mail at [email protected]. Any follow-up in response to your meeting request, whether by telephone, in-person meeting, or on-site visit, is considered Compliance Assistance and will focus on explaining the permit conditions to you. Thank you.

ENVI�NTAL QUALITY

Director

EG:mbt

Enclosures

c: Mayor Marvin Brown, City of Louisiana Presiding Commissioner Chris Gamm, Pike County Robert Aston Jr., R.G., P.E., Missouri State Coordinator, U.S. EPA Region 7 Ms. Carol S. Comer, Director, Missouri Department ofNatural Resources Ms. Holly Mabry, Director, Louisiana Public Library Greg Haug, P.E., Senior Project Manager, Trioxy Incorporated Northeast Regional Office, Missouri Departinent·ofNatural Resources (via Electronic

Exchange)

STATE OF MISSOURI

DEPARTMENT OF NATURAL RESOURCES

MISSOURI HAZARDOUS WASTE MANAGEMENT FACILITY

PART I PERMIT

PERMIT NUMBER: MOR000556985

PERMITTEE

Owner and Operator: Trioxy, Incorporated 3651 West Industrial Park Drive Louisiana, MO 63353

FACILITY LOCATION

Trioxy, Incorporated 3651 West Industrial Park Drive

Louisiana, Missouri 63353 Pike County

North Latitude - 39°25'28" West Longitude - 91 °04'30"

FACILITY DESCRIPTION

Trioxy, Incorporated (Trioxy) is a commercial hazardous waste treatment and storage facility. Trioxy accepts alcohols, healthcare wastes, solvents, characteristic hazardous wastes, as well as various F-, K-, P-, and U-listed hazardous wastes. Trioxy conducts disinfection and grinding of infectious health care wastes that may be mixed with hazardous wastes. The disinfected/treated/ sized wastes are then blended with liquid hazardous waste in tanker trucks. The blended wastes are prepared for use as an alternative fuel at other appropriately permitted hazardous waste facilities. The infectious aspect of the healthcare waste is permitted through a Solid Waste

Trioxy, Incorporated Missouri Hazardous Waste Management Facility Permit -Part I MOR000556985

Page2

Program construction permit, issued May 25, 2017. The general facility location is shown in Figure 1. The facility property boundaries are shown in Figure 2.

PERMITTED ACTIVITIES

This Permit allows Trioxy to operate a hazardous waste treatment and storage facility and requires the conditions contained in this Permit to be complied with throughout the operation and future closure of the facility. This Permit also contains contingent corrective action conditions to address any newly-identified releases to the environment from newly-identified Solid Waste Management Units and Areas of Concern, as necessary and appropriate.

EFFECTIVEDATES OFPERMIT: May 11, 2018 to May _10, 2028

May 11, 2018

Date Edward . lbraith, Director DIVISION OF ENVIRONMENTAL QUALITY


Appendix D

Certificate of Insurance

ANY PROPRIETOR/PARTNER/EXECUTIVEOFFICER/MEMBER EXCLUDED?

INSR ADDL SUBRLTR INSD WVD

PRODUCER CONTACTNAME:

FAXPHONE(A/C, No):(A/C, No, Ext):

E-MAILADDRESS:

INSURER A :

INSURED INSURER B :

INSURER C :

INSURER D :

INSURER E :

INSURER F :

POLICY NUMBER POLICY EFF POLICY EXPTYPE OF INSURANCE LIMITS(MM/DD/YYYY) (MM/DD/YYYY)

AUTOMOBILE LIABILITY

UMBRELLA LIAB

EXCESS LIAB

WORKERS COMPENSATIONAND EMPLOYERS' LIABILITY

DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

AUTHORIZED REPRESENTATIVE

EACH OCCURRENCE $DAMAGE TO RENTEDCLAIMS-MADE OCCUR $PREMISES (Ea occurrence)

MED EXP (Any one person) $

PERSONAL & ADV INJURY $

GEN'L AGGREGATE LIMIT APPLIES PER: GENERAL AGGREGATE $PRO-POLICY LOC PRODUCTS - COMP/OP AGGJECT

OTHER: $COMBINED SINGLE LIMIT

$(Ea accident)

ANY AUTO BODILY INJURY (Per person) $OWNED SCHEDULED

BODILY INJURY (Per accident) $AUTOS ONLY AUTOSHIRED NON-OWNED PROPERTY DAMAGE

$AUTOS ONLY AUTOS ONLY (Per accident)

$

OCCUR EACH OCCURRENCECLAIMS-MADE AGGREGATE $

DED RETENTION $PER OTH-STATUTE ER

E.L. EACH ACCIDENT

E.L. DISEASE - EA EMPLOYEE $If yes, describe under

E.L. DISEASE - POLICY LIMITDESCRIPTION OF OPERATIONS below

INSURER(S) AFFORDING COVERAGE NAIC #

COMMERCIAL GENERAL LIABILITY

Y / NN / A

(Mandatory in NH)

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORETHE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED INACCORDANCE WITH THE POLICY PROVISIONS.

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIODINDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THISCERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS,EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THISCERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIESBELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZEDREPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement onthis certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

CERTIFICATE HOLDER CANCELLATION

© 1988-2015 ACORD CORPORATION. All rights reserved.ACORD 25 (2016/03)

CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)

$

$

$

$

$

The ACORD name and logo are registered marks of ACORD

KFENTRESS

01/10/2018

ENVIWAS-02

CUEC004505303

BAEC002784409

DWEC002784709

AGEC002784509

A PEC002786109

1,000,0001,000,000

1,000,000

10,0005,000,0005,000,000

2,000,000

1,000,0002,000,000

5,000100,000

1,000,000

1,000,000

X

X

X

X

X

X

X X

XX

C UM00040113MA17A

12/31/2017 12/31/2018

12/31/2017 12/31/2018

12/31/2017 12/31/2018

12/31/2017 12/31/2018

12/31/2017 12/31/2018

12/31/2017 12/31/2018

RBN & Associates, Inc.303 E Wacker Dr.Suite 1130Chicago, IL 60601

(312) 856-9425(312) 856-9400

Trioxy, Inc3651 W Industrial Dr.Louisiana, MO 63353

Trioxy, Inc3651 W Industrial Dr.Louisiana, MO 63353

Indian Harbor Insurance Co.XL Insurance America, Inc.XL Specialty InsuranceGreenwich Insurance Company 22322

37885

X

N

X

X

Each Occurenceper vehicle

1,000,000100,000

Pollution Legal LiabMotor Truck Cargo


Appendix E

Waste Profile Form

Page 1 of 3

A. CUSTOMER INFORMATION

Generator Category:

B. SHIPPING INFORMATION

Yes No Is this a USEPA Hazardous Waste?

Is this a DOT Hazardous Material?

C. GENERAL MATERIAL & REGULATORY INFORMATION

Yes No Yes No Yes No

Container Type:

Container Size:

Shipping Frequency:

Anticipated Volume:

Infectious Waste (may contain infectious waste mixed with hazardous healthcare waste)

Water Flammables Pyrophoric Oxidizers

Acids Pesticides/Herbicides Fungicides Air Reactives

Reactive Sulfides

Does this waste contain any of the following?

Non-Hazardous Solid Waste

Reactive Cyanides Caustics Other Incompatibles

Name of Waste Stream:

DOT Shipping Name:

USEPA Waste Codes:

Waste Codes Continued:

Process Generating the Material:

Comments:

Billing Contact:

Fax:

Phone: Email:

Generator Name: Facility Address:

City: State:

Billing Company: Billing Address:

City: State:

US EPA ID #:State Generating ID #:

3651 West Industrial Drive, Louisiana, MO 63353Telephone: 573-560-3442

Waste Profile Sheet

Technical Contact: Phone: Email:

Zip: Zip:

Fax:

Page 2 of 3

D. (1) MATERIAL COMPOSITION

D. (2) MATERIAL COMPOSITION (ELEMENTAL)

Elemental Constituents:

Check if this material contains No Detectable Elements / Metals, unless listed below.

Data Listed Based On: Total Analysis or TCLP Method or Generator Knowledge

E. MATERIAL PHYSICAL CHARACTERISTICS @ 70° F

Color: Flash Point:

Specific Gravity:

Viscosity (cps): If < 73°F, list: °F Low Med. High

Density:

lbs / gal lbs / cu. ft. Boiling Point (if < 130°F):

pH: Multi-layered? Yes No Pumpable w/ centrifugal pump? Yes No

Exact Soluble in water? Yes No Liquids > 20% H2O or Non-aqueous

BTU/lb: PCB's Detected? Yes No If yes, ppm

FluorineThallium

Antimony

# of Phases:

Liquid %:

Sludge %:

Solid %:

Powder %:

SeleniumSilverZinc

CadmiumChlorine

Chromium

ppmConstituentArsenicBarium

Bromine

ppmConstituentppmConstituentLead

MercuryNickel Beryllium

Constituent Range (%)Constituents

Chemical/Physical Constituents: List all detectable components by chemical name,

Low High Typical

including physical materials (e.g., sorbent, debris, etc.). (Range ≥ 100%)

Ash %:

Page 3 of 3

F. GENERATOR CERTIFICATION

By checking the box, the generator certifies that the following wastes are not included:

Asbestos containing materialsLead acid batteriesDemolition and construction wasteMunicipal waste, yard wastePCB'sLarge anatomical partsFetusesInfectious agents at Biosafety Level 3 or 4ExplosivesRadioactive materialsIncompatible wastes placed in the same container (i.e., small containers of flammable liquids and corrosives in same box)

Containers of flammable liquids or corrosive liquids placed in the shipping container with biohazardous waste

G. CUSTOMER PROFILE CERTIFICATION

How has the generator determined the waste is or is not a RCRA hazardous waste?

Generator Knowledge SDS (Attach) Analytical (Attach)

Comments:

I hereby certify that I am an authorized agent of the generator, and warrant on behalf of the generator that the information supplied on this form and any attachments or supplements hereto is complete and accurate, and that all known or suspected hazards of the waste described herein have been disclosed.

Authorized Representative Name (Printed): Company:

Title:

Authorized Representative Signature: Date:

Received: Approved:

Profile #: Approval Date:

Recert Date:

Notes:

Trioxy Use Only

Documents

Trioxy, Inc. Treatment Facility Audit Packet · Healthcare waste is managed through use of ozone treatment ... and infectious waste treatment facility is an allowable use within this