Chemical Waste Disposal Corporation
Posted on July 13, 2015
Client: Chemical Waste Disposal Corporation
Location: Astoria, Queens, NY
Project Type: Part 373 Hazardous Waste Management Permit
Chemical Waste Disposal (CWD) Corporation is a commercial hazardous waste storage facility located in Astoria, New York. CWD Corporation transports containerized and lab-pack waste from offsite generators including schools, laboratories, medical facilities, pharmaceutical manufacturers and industrial companies to its facility for short-term storage prior to subsequent shipment to authorized recycling, treatment and disposal facilities. The firm was initially retained by CWD Corporation in May of 1990 to provide complete environmental engineering services with regard to its Part 373 Permit Application as a commercial hazardous waste storage facility. Since that time, the firm has had the opportunity to provide CWD Corporation with environmental engineering services that have supported the preparation and issuance of a Part 373 Permit by the New York State Department of Environmental Conservation (NYSDEC) in September of 1994.
Of critical importance during the development of the Part 373 permit application was the scheduling, development and implementation of related engineering activities that included the preparation of detailed design plans and specifications to address required improvements at the facility. The design of the upgraded facility included provision for secondary containment, a storm water management system and physical separation of incompatible waste to preclude pending denial of the permit by the NYSDEC.
The design of the upgraded components of the facility and associated corrective action program integrated the preparation of a detailed closure plan addressing the potential for prior releases from former solid waste management units (SWMUs) as well as regulated units such as the container storage area. The firm successfully negotiated these elements with the U.S. Environmental Protection Agency (USEPA) and NYSDEC to allow the incorporation of the provisions of the EPA RCRA 3008(h) Consent Order into the Permit Document as well as a schedule of activities to address interim and long-term corrective action remedial programs culminating in the construction of the upgraded storage facility. The firm also fostered the concept of joint permitting to include the federal HSWA requirements of the program into the permit for which the NYSDEC had not yet been authorized by the EPA.
The following presents an overview of the specific environmental engineering and regulatory assignments undertaken by the firm in support of Chemical Waste Disposal Corporation operations.
Information Regarding Potential Hazardous Waste and Hazardous Waste
Constituent Releases from Solid Waste Management Units (SWMU Report)
This project required the completion of the 6 NYCRR Part 373 Questionnaire that is commonly referred to as a Solid Waste Management Unit (SWMU) Report. In this report, the firm provided a detailed description of the current and past process operations conducted at the facility and identified the specific types of hazardous materials managed at the facility. The identification of past and present process operations was completed with the aid of historical aerial photographs and available design and “as built” drawings.
Part 373 Permit Application
Since the submittal of its original Part 373 permit application in 1986, CWD Corporation responded to several Notices of Incomplete Application (NOIA) from the NYSDEC regarding deficiencies in its permit application. Due to technical deficiencies in the permit application that focused mainly on noncompliance with secondary containment and storm water management issues, the NYSDEC made a tentative determination to deny the facility’s permit application which would have resulted in the closure of the facility. In order to rectify this situation, CWD Corporation retained the firm to rewrite the existing Part 373 permit application and address the technical deficiencies that were itemized in the most recent NOIA from the NYSDEC.
The revised permit application included the following:
- Enhanced record keeping system for the numerous waste types accepted and managed at the facility.
- Detailed acceptance protocols for all waste received at the facility, including provisions for an on-site laboratory for “fingerprinting” appropriate waste.
- Revised Waste Analysis Plan and Quality Assurance/Quality Control (QA/QC) Plan.
- Updated Contingency Plan and Preparedness and Prevention Plan.
- Provision for a comprehensive, computerized waste tracking system for improved QA/QC and operational efficiency.
- A detailed and comprehensive Closure Plan and closure cost estimate. It is worthy to note that the facility closure plan integrated the technical requirements of the corrective action program requirements for on-site soil as a means of achieving compliance with the requirements for assessing the vertical and horizontal extent of any contaminants for regulated units.
- Detailed facility inspection reporting system
- A comprehensive, updated lab-pack operations protocol addressing the acceptance of over 300 waste codes.
Part 373 Permit Feasibility Study
As part of this project, the firm prepared a predesign feasibility study report to address alternatives available for structural modifications to the CWD Corporation facility in order to bring the facility in compliance with the Part 373 regulatory requirements. In general, the report evaluated the present worth, cost and technical feasibility of two principal storage alternatives along with options for managing storm water and chemical releases.
Preparation of Variance Document
This project involved the preparation of a variance from the requirement that ignitable and reactive waste be stored at least fifty feet from the facility property line. In order to reduce to the maximum extent possible the threat to human health and the environment from a release of flammable and ignitable waste, the firm designed an alternate storage configuration that incorporated pre-engineered safety storage buildings for the storage of ignitable and reactive waste at the facility. This evaluation and storage configuration addressed requirements of the National Fire Protection Association along with the requirements of the New York City Fire Department.
Technical Review and Coordination of Permit Modules
As part of this project, the firm provided technical and administrative support to CWD Corporation regarding the public notice and hearing process for the facility’s Part 373 Permit Document. The firm negotiated the terms and conditions of the permit and prepared written comments addressing modifications to the facility’s operating procedures and changes in the design of the storage unit. The firm also fostered the concept of joint permitting to include the federal HSWA requirements into the permit document for which the NYSDEC had not yet been authorized.
Preparation of Plans and Specifications
This project involved the preparation of detailed design drawings and specifications for construction of hazardous waste storage areas at the CWD Corporation facility. The plans and specifications made provision for the upgrade of the existing exterior storage area at the facility by incorporating specific engineering design elements to comply with NYSDEC regulations. The basic design concept consisted of the construction of a roof to completely cover the exterior storage area of the facility and prevent the entry of storm water, as well as the installation of safety storage sheds and secondary containment sumps to provide the required containment capacity and separation of incompatible waste. The design plans and specifications were incorporated into the Part 373 Permit document with the construction schedule based on the completion of the onsite Corrective action program.
Negotiation of RCRA 3008(h) Corrective Action Order
As part of this project, the firm provided technical assistance in the review, evaluation and preparation of a technical response to USEPA Section 3008(h) Corrective Action Order. In general, the Corrective Action Order required the preparation and implementation of a RCRA Facility Investigation work plan and Interim Corrective Measures work plan. Based on the results of the investigation and engineering evaluations undertaken in accordance with these plan elements, the order makes provision for the initiation and completion of a corrective measures study and corrective measures implementation program.
Preparation of RCRA Facility Investigation Work Plan
This project involved the preparation of a RCRA Facility Investigation Work Plan in accordance with the Corrective Action Order that was negotiated with the EPA as part of the previous project. The purpose of the RFI Work Plan was to determine the nature and extent of any contamination at the facility and to evaluate the need for any interim or long-term corrective measures. In addition, several specific interim corrective measures were identified for consideration at the facility to help alleviate any threat or potential threat to human health or the environment. In order to achieve these goals, a three-phased investigation was designed as part of the RFI Work Plan. The first phase was designed to fully evaluate the suitability and integrity of existing groundwater monitoring points, and collect and analyze available data regarding nearby subsurface structures as potential sources and/or migration pathways for contamination. Chemical analysis was included to identify specific constituents of concern. The second phase of the investigation involved the installation of clustered groundwater monitoring wells to map potentiometric surfaces, measure hydraulic conductivity, calculate groundwater flow velocities, and determine groundwater quality in the subsurface. In addition, the second phase of the investigation included an onsite and off-site soil boring program undertaken to develop a three dimensional contaminant profile of unsaturated soils utilizing an unbiased sampling grid in conjunction with biased sampling points. As part of the third phase of the investigation, supplemental groundwater monitoring wells and piezometers will be installed to enhance data obtained relative to plume definition. The firm responded to technical comments from both the EPA and NYSDEC regarding the RFI Work Plan with the final document approved in October of 1994.
Implementation of Phase I RCRA Facility Investigation
This project involved the implementation of Phase I of the RCRA Facility Investigation at the CWD Corporation facility that was described in detail in the approved RFI Work Plan. The specific tasks conducted included:
The results of the Phase I RFI were documented in a report that included recommendations for modifications to the Phase II RFI. The Phase I report was approved by the EPA and NYSDEC in February of 1995.
- Assessment of existing groundwater monitoring wells.
- Redevelopment of existing groundwater monitoring wells.
- Obtaining groundwater level measurement/tidal influence.
- Collecting groundwater samples for analysis for corrosivity, total dissolved solids, and Appendix IX parameters.
- Conducting a radiological survey.
- Defining of the 19th Avenue sewer line, utility trench and nearby building foundations.
Implementation of Phase II RCRA Facility Investigation
This project involved the implementation of Phase II of the RCRA Facility Investigation at the CWD Corporation facility in accordance with the approved RFI Work Plan and Phase I RFI report. The specific tasks conducted included:
- Abandonment of existing monitoring wells that are damaged.
- Completing an on-site and off-site soil boring program that involved the advancement of 35 soil borings and the collection of soil samples for chemical analysis.
- Installation of 12 groundwater monitoring wells and collection of groundwater samples for chemical analysis.
- Obtaining groundwater level measurements and developing a potentiometric surface map.
- Conducting in situ hydraulic conductivity testing.
In preparation for the Phase II Field Investigation, the firm also prepared bid documents to procure the required drilling and analytical laboratory subcontractors.
The results of the Phase II RFI were documented in a report that included recommendations for modifications to the Phase III RFI, as well as the implementation of corrective measures.
Preparation of Closure Plan and Closure Cost Estimate
As with any Part 373 Permit Application, the firm was required to prepare a comprehensive closure plan and closure cost estimate for the CWD Corporation. As was mentioned above, a critical element of the Part 373 Permit Application was the design of a new facility storage pad with integral secondary containment and storm water management systems. Prior to initiation of the construction of the new storage unit, proper closure of the existing unit is required along with an assessment of the vertical and horizontal extent of any contaminated subsurface soils. As part of permit and 3008(h) Order negotiations, the firm designed a subsurface investigation program that met the multiple objectives of NYSDEC and EPA with regard to the closure of the old storage unit, the assessment of the vertical and horizontal extent of any soil contamination as part of the corrective action program, as well as the definition of soil required to be excavated and/or remediated in place beneath the storage unit either due to chemical contamination or its unsuitability as fill. The investigation program is also designed to provide for full chemical characterization to allow for the calculation of detailed disposal costs if soil is removed off-site or the soils are found to be suitable from a geotechnical standpoint and in situ remediation is warranted. Lastly, this program allowed the client to defer a significant amount of the cost associated with closure from the closure cost estimate to the corrective action program, significantly reducing the financial assurance requirements.
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