ATTACHMENT A Tradebe Treatment and Recycling of Northborough, LLC FACILITY DESCRIPTION / LOCATION INFORMATION TABLE OF CONTENTS

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1 ATTACHMENT A Tradebe Treatment and Recycling of Northborough, LLC FACILITY DESCRIPTION / LOCATION INFORMATION SECTION TABLE OF CONTENTS PAGE 1.00 INTRODUCTION BUSINESS DESCRIPTION WASTES ACCEPTED FACILITY DESCRIPTION Existing Facility Proposed Changes To Existing Facility LOCATION INFORMATION Topography Legal Boundaries Geology of Site Area Hydrogeologic Characterization Public Water Supplies Private Water Supply Wells Floodplain Standard Seismic Data Meteorological Data Buffer Zone REQUIRED PERMITS PAST AND PENDING ENFORCEMENT ACTIONS...5 TABLES Table A-1 Directors/Officers... A-1 Table A-2 Permits...A-5 Table A-3 Past and Pending Enforcement Actions...A-5 APPENDICES Appendix A-1 Appendix A-2 Resumes For Key Management Personnel Meteorological Data

2 ATTACHMENT A Tradebe Treatment and Recycling of Northborough, LLC FACILITY DESCRIPTION / LOCATION INFORMATION 1.00 INTRODUCTION Tradebe Treatment and Recycling of Northborough, LLC (also referred to as the Facility and Licensee ) is a hazardous waste transfer facility located in the town of Northborough, County of Worcester, Massachusetts. The location of the facility is shown on the USGS Quadrangle Map provided in the RCRA Part A Permit Form found in Attachment J, RCRA Part A Application. All received materials managed under transport are subsequently shipped off-site. Tradebe Treatment and Recycling of Northborough, LLC ships only to those destination facilities authorized to receive hazardous waste by the U.S. Environmental Protection Agency ( US EPA ) and/or the state in which the destination facility is located. No treatment or disposal occurs onsite BUSINESS DESCRIPTION Tradebe Treatment and Recycling of Northborough, LLC currently provides hazardous waste management services to customers predominantly throughout the New England region. Tradebe Treatment and Recycling of Northborough, LLC has been providing industrial, municipal, and federal clients with services for the cleanup, transportation, and disposal of hazardous waste for over 25 years. With its central location in Northborough, Massachusetts, Tradebe Treatment and Recycling of Northborough, LLC offers clients 24-hour emergency response services, environmental remediation, and 5-day Truck-to-Truck transportation on-site services. Tradebe Treatment and Recycling of Northborough, LLC is owned and operated by Tradebe Treatment and Recycling Northeast, LLC, 234 Hobart Street, Meriden, CT A list of the directors/officers is provided in Table A-1, Directors/Officers of Tradebe Treatment and Recycling of Northborough, LLC. No officer, director or key staff member holds equity interest in TTRN. Appendix A-1, Resumes for Key Management Personnel, provides the resumes for key management personnel at Tradebe Treatment and Recycling of Northborough, LLC. TABLE A-1 Directors/Officers of Tradebe Treatment and Recycling of Northborough, LLC Robert O Brien, President Elkhart Pl Crown Point, In Victor Creixell, Manager Av. Barcelona 109 Sant Joan Despi, Barcelona Spain Page A-1

3 3.00 WASTES MANAGED All wastes managed at the Facility are classified by the generator using the US EPA and MADEP waste codes in accordance with 40 CFR Part 261 and 310 CMR This classification system provides a manageable procedure to process compatible wastes by different generators based on the ultimate treatment/disposal method. EPA and MADEP hazardous waste codes accepted at the Facility in accordance with the Facility s RCRA Part A Permit Form are included in this license renewal as Attachment J, RCRA Part A Application. Non-hazardous wastes are included in this list under the MA99 waste code 310 CMR FACILITY DESCRIPTION The following sections describe the existing waste management activities and proposed changes to the Facility under this license renewal Previous Tradebe Treatment and Recycling of Northborough, LLC, The Licensee, has held a Hazardous Waste Facility Part B License issued by the Massachusetts Department of Environmental Protection (MassDEP) since The facility s current Part B License was issued in May The Facility was originally designed to store and treat a limited number of EPA-regulated and MADEP-regulated hazardous wastes in storage tanks and containers. Hazardous wastes were accepted in bulk, (i.e., tanker trucks) and in containers. The storage tanks and ancillary equipment were RCRA closed and removed from the Facility in Containers were stored in covered and contained area adjacent to the storage tank farm Proposed Changes To Existing Facility Under this renewal application, Tradebe Treatment and Recycling of Northborough, LLC will be an authorized for the transfer of wastes from one transportation vehicle to another in the area where containers were previously authorized to be stored. TTR Northborough will relinquish the authorization to store waste in tanks onsite LOCATION INFORMATION Tradebe Treatment and Recycling of Northborough, LLC is located at 345 West Main Street, in Northborough, Massachusetts. The licensed hazardous waste facility encompasses approximately 2.75 acres. This facility is not on land designated as Indian Lands, nor is it adjacent to any sensitive receptors such as, schools, hospitals, nursing homes, and day care centers. The following sections provide details on the Facility location. Page A-2

4 5.10 Topography In addition to the United States Geological Survey ( USGS ) topographic map showing the Facility location and provided as part of the [RCRA Part A Permit Form found in Attachment J, RCRA Part A Permit Application, Tradebe Treatment and Recycling of Northborough, LLC has prepared a topographic map and various site plans to illustrate information required by 310 CMR (4)(a). Figure 4 in Attachment L, Blueprints and Plans shows topography within the Facility boundaries. In addition, Figures B3A and B3B show aerial plans and soil classifications, respectively. All Facility site plans are provided in Attachment L, Blueprints and Plans Legal Boundaries Tradebe Treatment and Recycling of Northborough, LLC is bounded as shown in Figure 4, Attachment L, Blueprints and Plans Geology of Site Area Tradebe Treatment and Recycling of Northborough, LLC facility sits atop a thick layer of overburden sorts. According to boring logs for wells drilled at the site, the overburden is at least 60 feet deep. The Soil Survey of Worcester County, Massachusetts, classifies the underlying soils as part of the Merrimac and Freetown soil units. The Merrimac soil unit is described, in general, as a fine sandy loam originally deposited by glacial melt waters in outwash plains. The Freetown soil unit is described as muck that can be found in low-lying areas and old glacial lakes. A Surficial Geologic Map of the site and surrounding area is provided in Figure 3, Attachment L, Blueprints and Plans. Bedrock in the area has been mapped as the Washoba Formation. This formation consists of metamorphic schist, gneiss, amphibolite, and marbles Hydrogeologic Characterization The groundwater table at Tradebe Treatment and Recycling of Northborough, LLC property ranges in depth from approximately 3 to 22 feet below ground surface. The groundwater gradient is from south to north. Groundwater likely discharges into the low-lying wetlands area to the north and ultimately to Cold Harbor Brook which flows northeast to the Assabet River Public Water Supplies Based on a review of recent public records, there are no municipal wells located within 1,000 feet of the site. The town of Northborough is serviced by municipal water supplied from three existing water wells, located on Crawford Street, Brigham Street and Howard Street. These wells are approximately three quarters of a mile north-northwest, 1.37 miles east-southeast, and Page A-3

5 one and one-half miles north-northwest from the site, respectively. A fourth well exists on Lyman Street and is labeled Town Well D. The Lyman Street well was terminated in December 1988 due to trichloroethane contamination, and has not yet been brought back on-line Private Water Supply Wells The Topography Plan, Figure 4, Attachment L, Blueprints and Plans, identifies residences and wells in the vicinity of the facility. It confirms that municipal water is not available to some regions contained within the 1,000-foot radius. All of Davis Street, Old Colonial Road, Wiles Farm Road, and Route 20 (Southwest Cutoff) private wells are upgradient of the Tradebe Treatment and Recycling of Northborough, LLC facility. The direction of groundwater motion in the West Main Street wells is parallel to the Facility Floodplain Standard Tradebe Treatment and Recycling of Northborough, LLC facility is not located within a 100-year or 500-year high water level floodplain, based on levels established by the Federal Flood Insurance Program. Therefore, the Facility does not need to be designed, constructed, operated, or maintained to prevent washout of any hazardous waste in the event of a flood event. The closest boundary of the 100-year floodplain areas to the site, as designated by the National Flood Insurance Program, is indicated in Figure 4, Attachment L, Blueprints and Plans Seismic Data Tradebe Treatment and Recycling of Northborough, LLC facility is not located within 200 feet of a fault which has had displacement in Holocene time. Additionally, Tradebe Treatment and Recycling of Northborough, LLC facility is not located in a political jurisdiction listed in 40 CFR 264 Appendix VI. Facilities which are located in political jurisdictions other than those listed in 40 CFR 264 Appendix VI are not required to demonstrate compliance with 40 CFR ; thus Tradebe Treatment and Recycling of Northborough, LLC facility is determined to be in compliance with 40 CFR (a), Seismic Considerations Meteorological Data Meteorological data is provided in Appendix A-2. Page A-4

6 5.80 Buffer Zones The Facility is not licensed to receive or store reactive waste in tanks and therefore reactive waste will not be addressed REQUIRED PERMITS Tradebe Treatment and Recycling of Northborough, LLC has a number of permits and/or approvals required for the operation of the Facility and associated activities. These permits and their status are provided in Table A-2, Tradebe Treatment and Recycling of Northborough Permits. TABLE A-2 Tradebe Treatment and Recycling of Northborough, LLC Permits Permit/Approval Description Permit Number Comments MA Department of Fire Services MGL148, Expires 4/27/2017 Section 10A MA Department of Public Safety - Division of Not applicable Expires 4/27/2017 Fire Prevention Registration for storage of flammables MSGP for Stormwater MAR Expires 06/04/ PAST AND PENDING ENFORCEMENT ACTIONS A listing of the previous five years of past and pending enforcement actions for the Licensee, Tradebe Treatment and Recycling of Northborough, LLC, EPA ID MAD , are provided in Table A-3 below. TABLE A-3 Past and Pending Enforcement Actions at Tradebe Treatment and Recycling of Northborough, LLC Date Type Description Fine Reference Number 2/14/2018 Notice of Noncompliance License Renewal Application Deficiencies $0 NON-BO Note: Unless indicated otherwise, the agency involved in the enforcement actions is MADEP Page A-5

7 APPENDIX A-1 RESUMES FOR KEY MANAGEMENT PERSONNEL

8 Brian Viera Business Phone: (888) West Main Street, Northborough, MA PROFESSIONAL PROFILE MA Facilities Manager Tradebe Treatment and Recycling Northeast, LLC Responsible for the overall operation of the Northborough MA Facility and the Stoughton MA facility. Actively involved in the day to day operation of both facilities Actively involved in the procurement of staff, materials and equipment needed to perform services that TES offers to customers. Oversees environmental health & safety program offered to staff. Works directly with customer representatives, state, federal and local regulatory agency representatives, and local emergency response personnel. Coordinates regulatory training programs for staff. AS FACILITIES MANAGER FOR TRADEBE NORTHBOROUGH/STOUGHTON MY RESPONSIBILITIES INCLUDE BUT ARE NOT LIMITED TO THE FOLLOWING Ensure compliance with all applicable Local, State,and federal regulations (MA-DEP EPA OSHA MWRA US Coast Guard Local Fire Dept. Local Board of Health) Oversee employees training & certifications Ensure employees are familiar with permit requirements and strictly adhere to those requirements etc. Routinely review with employees, safety measures, emergency response procedures, licensing requirements etc. Implement any changes to the permit requirements. Address any regulatory issues. Storm water Pollution Prevention Plan. Storm water inspections. Sewer use discharge permit. Part B Permit. Coast Guard Exercises. Contingency Plan. Security Plan

9 WORK HISTORY Facilities Manager Tradebe Environmental Services 2011-present Northborough, Stoughton Massachusetts Facility Manager Tradebe Environmental Services 2007-present Stoughton MA Operations manager UIS RI Transportation UIS RI LICENSE MA Wastewater Treatment Plant Operators License-Grade 4-I Full Active MA Hoisting Engineer License:HE RI CDL Class A TRAINING OSHA 40-hour HAZWOPER and annual 8-hour refreshers. Confined Space Entry and Rescue. First Aid/CPR Personal Protective Equipment Massachusetts Wastewater Operator Training Massachusetts Hoisting Training

10 Calvin Lajoie Business Phone: (888) West Main Street, Northborough, MA PROFESSIONAL PROFILE Field Service Manager of Tradebe Environmental Services Coordinates completion of environmental projects at customer sites. Oversees environmental health & safety program offered to staff. Manages emergency spill response services. Works directly with customer representatives, state, federal and Actively involved in the procurement of staff, materials and equipment needed to perform services that TES offers to local regulatory agency representatives, and local emergency response personnel. customers. Coordinates regulatory training programs for staff. PROFESSIONAL ACCOMPLISHMENTS Prior to working at Tradebe Environmental Services: WORK HISTORY Co-owned and operated an environmental services company. Vice President & Operations Manager of an environmental services company. Field Service Manager Co-owner/Operator and President Vice President of Operations Operations Manager and Field Operations Supervisor EDUCATION Tradebe Environmental Services, 2003-present Northborough, Massachusetts S&G Inc., Ellington, Connecticut Tri-S Inc., Ellington, Connecticut Tri-S Inc., Ellington, Connecticut Bachelor of Science Charter Oak, Farmington, CT 1988 Associates University of Connecticut, Storrs, CT 1974 TRAINING OSHA 40-hour HAZWOPER and annual 8-hour refreshers. Confined Space Entry and Rescue. First Aid/CPR Personal Protective Equipment

11 APPENDIX A-2 METEOROLOGICAL DATA