Consolidated Edison of New York, Inc. Astoria Complex
Posted on July 13, 2015
Client: Consolidated Edison of New York, Inc.
Location: Astoria, NY
Project Type: Astoria Complex
- 6 NYCRR Part 373 Permit Modification Application
- Spill Prevention Control and Countermeasure Plans Update
- Closure Reports
- Secondary Containment System Inspection Services
The Consolidated Edison Company of New York, Inc. (Con Edison) Astoria Facility is located in Long Island City, New York along the eastern shore of the East River. The Astoria Facility historically was a major electricity generation site for Con Edison until the sale of the Astoria Generating Station and the Astoria Gas Turbine Site in recent years. The current primary function of the Astoria Facility is refurbishing transformers at the Astoria Transformer Shop (ATS) and conducting laboratory analyses at the Astoria Chemistry Laboratory. In addition, the facility stores the majority of the equipment and materials utilized by Con Edison to service the power grid.
The firm was retained by Con Edison to update the facility’s 6 NYCRR Part 373 Permit, update the facility’s four Spill Prevention, Control and Countermeasure (SPCC) Plans, prepare closure reports to document the closure of the Chem Lab Underground Storage Tank, the Transformer Shop West Oil Draining Station and Technical Service Area, PCB Waste Oil Tanker Trucks and PCB Waste Oil/Water Storage Tanker Truck, PCB/Lead Operational Hazardous Waste Roll-off Container and conduct engineering inspections of the PCB Canopy including preparation of an inspection report suitable for submission to the New York State Department of Environmental Conservation (NYSDEC).
6 NYCRR Part 373 Permit Modifications.
The firm was retained by Con Edison to update its existing 6 NYCRR Part 373 Permit for the Astoria Facility. The permit included all typical modules and associated attachments including facility description, waste characterization, waste analysis plan, quality assurance/quality control plan, contingency plan, personnel training, preparedness and prevention, closure plans, closure cost estimates and financial assurance documentation.
In addition, the modification included conceptual design of an 8,500-gallon tank proposed to be installed at the Astoria Wastewater Treatment Plant. The tank was permitted under the Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act (TSCA) for the on-site storage of PCB waste oil (> 50 ppm). Installation of this tank allowed Con Edison to close the PCB tankers located under the PCB Canopy which were used to store PCB waste oil. The permit modification also included conceptual design of a new secondary containment pad to be installed under the existing PCB Canopy.
Following review of the permit modification by the NYSDEC and the required public comment period, the firm prepared final plans and technical specifications for the tank and pad installation projects for Con Edison’s use in obtaining bids from potential contractors.
Spill Prevention, Control and Countermeasure Plans Update
The firm was retained by Con Edison to update Spill Prevention, Control and Countermeasure (SPCC) Plans for four facilities located at the Astoria complex. These facilities included the following:
• Astoria Gas Turbine Site
• Astoria Generating Station
• Astoria PCB Storage Facility
• Astoria Transformer Shop
The update of the SPCC Plans for the Astoria Gas Turbine Site and the Astoria Generating Station were conducted prior to the sale of these facilities. The update of the SPCC Plans for the Astoria PCB Storage Facility and Astoria Transformer Shop was part of the 3-year re-certification of the plans and involved separating the combined plan for the two areas into separate plans for each area.
As part of this assignment, the firm conducted a detailed engineering inspection of each facility to confirm and update the inventory and capacity of both aboveground and underground petroleum storage tanks located at each facility. The firm then reviewed information related to petroleum spill prevention and control for the facilities, including the portions of the facilities used for storage, loading/unloading and transfer of oil, secondary containment systems and storm water collection and conveyance. Specific activities that were conducted included: review of current SPCC Plans; site inspections to evaluate the adequacy of the secondary containment systems; the location of all petroleum tanks and evaluation of potential spill direction, rate and total quantity of oil which could be discharged from the facility as a result of each major type of failure.
Following the information review and facility inspection, the firm prepared an SPCC Plan for each of the facilities. Preparation of the SPCC Plans involved incorporating applicable provisions of 40 CFR Part 112. In addition, the firm reviewed and updated the hazardous waste contingency plan for each facility to ensure consistency with the SPCC Plan. Copies of the SPCC Plans and hazardous waste contingency plans were provided to Con Edison in both hard copy and electronic formats.
Closure of the Astoria Chem Lab Underground Storage Tank
The project consisted of the Resource Conservation and Recovery Act (RCRA) closure of a hazardous waste underground storage tank located at the Con Edison Astoria Chem Lab. The firm was responsible for providing engineering oversight of the closure activities and preparation of an engineering report to document that the closure was performed in accordance with the NYSDEC-approved closure plan. Following the decontamination activities, rinse water samples were collected from the tank in order to verify the effectiveness of the decontamination activities. In addition, soil samples were collected from beneath the underground piping associated with the tank to determine whether historic operation of the piping had impacted surrounding soil. Following the closure activities, a closure report, signed and stamped by a Professional Engineer licensed in the State of New York, was prepared and submitted to the NYSDEC.
Closure of the Astoria Transformer Shop West Oil Draining Station and Technical Services Area
The project consisted of the RCRA closure of two PCB hazardous waste storage areas located at the Con Edison Astoria Transformer Shop: the Technical Services Area and the West Oil Draining Station (WODS). The firm was responsible for engineering oversight of the decontamination activities and preparation of an engineering report to document that the closure activities were performed in accordance with the NYSDEC-approved closure plan. The project also included oversight of remediation activities undertaken on the soil underlying the Technical Services Area floor that was impacted by PCBs as a result of the historic operations once undertaken in this area. In addition, as a result of elevated PCB concentrations detected in wipe samples collected from the concrete apron surrounding the WODS, additional decontamination and PCB encapsulation activities were required and performed.
Following completion of the field activities, a closure report was prepared for the project which included a description of the closure activities. Subsequent to Con Edison review, the final closure report was signed and stamped by a Professional Engineer licensed in the State of New York and submitted to the NYSDEC.
Decontamination, Scarification and Recoating of Transformer Shop Floors and Walls
The firm was retained to document the field activities associated with the decontamination, scarification and recoating of polychlorinated biphenyl (PCB) contaminated areas located at the Consolidated Edison Company of New York (Con Edison) Astoria Transformer Shop, which is located within the Astoria Facility.
The ATS is Con Edison’s electric distribution equipment repair facility. Transformers, capacitors, rectifiers, switch gear, network protectors and other types of electrical equipment are evaluated, reconditioned, repaired and tested as required, and added to the on-hand inventory for eventual return to service. The ATS also stores bulk and drummed dielectric fluid (new and reconditioned) that is utilized during the repair and reconditioning process.
As a result of routine maintenance and repair of the ATS building, Con Edison initiated the scarification and recoating of the floors in certain areas of the shop during the fall of 2003. As part of the project, wipe and chip samples were collected from the floors to be scarified and recoated. The samples were analyzed for PCBs. During the sampling program, it was discovered that at least three areas, the Maintenance Room, Housing Area and Machine shop, were contaminated with PCBs. As a result, prior to scarification and recoating, Con Edison conducted specific decontamination procedures on the floors at these three areas. Decontamination was conducted in accordance with the double wash/rinse methods for decontaminating nonporous surfaces coated or covered with dust, dirt, grime, grease or another absorbent material outlined at United States Environmental Protection Agency (USEPA) 40 CFR Part 761.375. After decontamination and/or scarification, each area was coated with two coats of different colored epoxy material.
Upon completion of the field activities, the firm prepared a field report documenting the activities conducted by Con Edison.
Permanent Closure of PCB Waste Oil Tanker Trucks and PCB Waste Oil/Water Storage Tanker Truck
The firm was retained to provide engineering oversight and prepare a written report to document the field activities associated with the permanent closure of the PCB Waste Oil Tanker Trucks and PCB Waste Oil/Water Storage Tanker Truck located at the Astoria PCB Storage Facility.
The two permitted PCB Waste Oil Tanker Trucks and the PCB Waste Oil/Water Storage Tanker Truck were located in the PCB Canopy Area. These three tanker trucks were located within interconnected steel secondary containment pans with 12-inch high sides. The interconnected secondary containment pans have a total capacity of approximately 9,723 gallons. The PCB Canopy Area is generally designed to prevent precipitation from falling on the tanker trucks and accumulating within the secondary containment pans.
As required, pursuant to 6 NYCRR 373-2.7(c)(4), Con Edison notified the NYSDEC Region 2 office their intention to close the PCB Waste Oil/Water Storage Tanker Trucks and the PCB Waste Oil/Water Storage Tanker Truck and submitted a closure plan for NYSDEC review and approval.
At the request of the NYSDEC, the firm prepared on behalf of Con Edison, a letter permit modification request for submission to the NYSDEC. In addition, the firm prepared a revision to the 6 NYCRR Part 373 Permit modification application for the Astoria PCB Storage Facility. As part of the revisions, Con Edison stated its intention to close the PCB Waste Oil Tanker Trucks and the PCB Waste Oil/Water Storage Tanker Truck in accordance with the NYSDEC-approved closure plan. The NYSDEC approved the letter permit modification request. Additionally, the NYSDEC approved the revisions to the 6 NYCRR Part 373 Permit modification application for the Astoria PCB Storage Facility.
Con Edison submitted a modification to the closure plan to allow the tanker trucks to be burned in a scrap metal recovery oven and smelted in place of decontamination. This modification was approved by the NYSDEC. Con Edison submitted an additional modification to the closure plan to allow the North Containment Pan (NCP) and Center Containment Pan (CCP) to be disposed of as PCB hazardous waste in place of decontamination. This modification was also approved by the NYSDEC.
Upon completion of the closure activities, the firm prepared a field report that provides a Professional Engineer’s certification that the areas have been closed in accordance with the specifications contained in the New York State Department of Environmental Conservation (NYSDEC) approved closure plan and 6 NYCRR Part 373-2.7.
Permanent Closure of PCB/Lead Operational Hazardous Waste Roll-off Container
The firm was retained to provide engineering oversight and prepare a report to document that the Less-Than-90-Day Building 150 PCB/Lead Operational Hazardous Waste Roll-off Container had been closed in accordance with the specifications contained in the approved closure plan as required by 6 NYCRR 373-3.7(f)(10).
The Less-Than-90-Day Building 150 PCB/Lead Operational Hazardous Waste Roll-off Container is located along the east side of the Material Storage Area, which is east of the Astoria Transformer Shop, to the west of Building 150. The 20 cubic yard roll-off container was utilized for the temporary storage of spent tarps and plastic used to wrap transformers in the field for transport to the Astoria Complex, as well as debris collected in the metal containment pans that the transformers are placed in during transport to the Astoria Complex. Con Edison has classified the roll-off container as a less-than-90- day hazardous waste storage unit and a less-than-30-day Toxic Substances Control Act (TSCA) storage unit, due to the potential for lead and PCB contamination to be present on the materials placed in the container. The roll-off container is covered with a large rubberized cover to prevent rainwater from entering the roll-off. The area located beneath the roll-off container, which measures approximately 10 feet by 20 feet, is surfaced with asphalt and appears to be intact with some minor cracks and deterioration. There were no visible signs of staining and/or discoloration or any other indicators of historic spills or contamination present in the area beneath or adjacent to the roll-off container. Con Edison began staging roll-off containers in this area approximately 2 years ago. All roll-off containers staged in this area have been provided by, and are the property of, the waste transporter.
As required pursuant to 6 NYCRR 373-3.7(c)(4), Con Edison notified the NYSDEC Region 2 office of their intention to close the Less-Than-90-Day Building 150 PCB/Lead Operational Hazardous Waste Roll-off Container and submitted the closure plan for NYSDEC review and approval.
On December 3, 2004, Con Edison submitted a modification to the closure plan to allow the area beneath the roll-of container to be encapsulated in place of further decontamination. This modification was approved by the NYSDEC.
Upon completion of the closure activities, the firm prepared a field report providing a Professional Engineer’s certification that the area had been closed in accordance with the specifications contained in the NYSDEC approved closure plan and 6 NYCRR Part 373-3.7.
PCB Canopy Secondary Containment System Inspection
The firm was retained by Con Edison to visually inspect the condition of the secondary containment system located at the Astoria PCB Storage Facility as required by the provisions included in the Con Edison 6 NYCRR Part 373 Hazardous Waste Permit. The areas inspected included the front and rear secondary containment areas within the PCB Storage Building and the three interconnected secondary containment pans located beneath the storage tankers located under the canopy
adjacent to the PCB Storage Building.
The inspection, conducted by a Professional Engineer licensed in the State of New York, included the following:
• Visual inspection of the overall condition of the storage tanker containment pans and the PCB Storage Building containment areas;
• Evaluation of the condition of the concrete/steel containment areas with respect to cracks, failed joint filler or sealant, differential settlement and any other defects which may affect the impermeability of the containment areas; and
• Identify recent repairs made to the containment areas and evaluate such repairs for adequacy. Con Edison provided
details regarding the methods and procedures regarding any repairs.
In addition to the secondary containment system inspection, the firm performed the following structural and safety
• Visual Inspection of the condition of the canopy overhanging the storage tankers for:
– loose or damaged sheet metal panels;
– security of bolts on structural framework or cross members; and
– corrosion, deterioration or apparent structural defects.
• Visual inspection of safety equipment.
A portable platform was utilized to facilitate inspection of the canopy.
Following completion of the inspections, the firm prepared an inspection report to document the inspection procedures and findings and provide recommendations for additional actions necessary as a result of deficiencies detected during the inspections. Following review of the inspection report by Con Edison and incorporation of the comments provided, a final inspection report was prepared and signed and stamped by a Professional Engineer licensed in the State of New York for submission to the NYSDEC.
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