PSC – Chemical Pollution Control, LLC of New York
Posted on July 10, 2015
Client: PSC – Chemical Pollution Control, LLC of New York
Location: Bay Shore, New York
Project Type: Facility Closure, Demolition and Reconstruction
- Hazardous Waste TSDF Facility Design
- Leadership in Energy and Environmental Design (LEED) Certification
- Resource Conservation and Recovery Act (RCRA) Permitting
- Compliance Assistance with Part 373/360 Permit
- RCRA Facility Investigation and Corrective Action
The PSC – Chemical Pollution Control, LLC of New York (CPC) Bay Shore, New York facility is a commercial hazardous waste treatment, storage and disposal facility (TSDF) that accepts and manages a variety of hazardous and nonhazardous wastes under a New York State Department of Environmental Conservation (NYSDEC) 6 NYCRR Part 373 Permit. The CPC facility, which currently includes a one-story masonry building with waste treatment, container and tank storage areas, occupies a parcel approximately 1 acre in size in an area consisting of developed industrial properties.
Dvirka and Bartilucci Consulting Engineers (D&B) was originally retained by CPC to develop conceptual plans for the enhancement of the existing facility to meet applicable NYSDEC hazardous waste regulations, as well as several other regulations and codes applicable to the facility, including Suffolk County Department of Health Services (SCDHS) Article 12 requirements, New York State Building and Fire Codes, and Town of Islip site development standards. At the time D&B was retained, CPC had modified its Part 373 Permit and proposed certain facility improvements in order to fulfill a Consent Order with the NYSDEC.
D&B initially reviewed the proposed facility improvements and conducted a detailed site inspection of the facility, including a structural evaluation of the existing facility building. Based upon this initial assessment, D&B determined that significant structural upgrades would be required in order to implement the proposed facility improvements previously agreed upon with the NYSDEC. In addition, D&B determined that the plan did not address several areas of the Town of Islip site development standards, including site drainage, parking and landscaping provisions. Based upon D&B’s recommendations, CPC decided to abandon the previously proposed facility improvements in favor of demolishing the existing facility and constructing a new, code-compliant facility meeting CPC’s operational needs.
CPC retained D&B to prepare design documents for the overall facility demolition and reconstruction project, as well as to assist with modifying its existing Part 373 Permit due to the conceptual change in the proposed facility upgrade.
Hazardous Waste TSDF Facility Design
Prior to initiating full-scale design of the new facility, D&B developed several conceptual site and facility layouts that were reviewed with CPC. These conceptual designs were based upon CPC’s operational needs, such as the facility’s waste storage volumes, waste handling procedures, the type of waste stored and administrative staff needs. In addition, the size and type of trucks loading/unloading waste at the facility, including intended truck routing, were considered in the development of the conceptual designs. Applicable NYSDEC hazardous waste and SCDHS Article 12 regulations, building codes, fire codes and Town of Islip site development standards were incorporated into the conceptual designs.
Once the proposed conceptual site design was agreed upon with CPC, D&B presented the proposed layout to representatives of the Town of Islip. The conceptual site design was revised based upon initial input from the Town of Islip and a final conceptual site design was selected by CPC which became the basis for full-scale design of the proposed facility.
The final facility design includes storage areas for 1,061 55-gallon drum equivalents of hazardous and nonhazardous waste. The building interior waste storage areas include a dedicated room for the storage of 160 55-gallon drum equivalents on storage racks, and a large warehouse type storage area for the remaining drums. Within the large warehouse storage area, fire-rated hazardous materials storage cabinets will be provided for oxidizers and water reactive materials. Treated photochemical liquids and nonhazardous liquids will be stored in three double-walled, 5,400-gallon aboveground storage tanks located outdoors. In addition, an area for the staging of two roll-off containers for the management of solid nonhazardous waste will be provided.
The secondary containment system designed by D&B for the container storage areas includes a combination of concrete curbs and sloping floors to provide a containment system meeting NYSDEC hazardous waste regulations, SCDHS Article 12 regulations and the New York State Fire Code, while at the same time allowing safe and efficient forklift traffic within the building. The design includes a loading dock and canopy provided with secondary containment. The loading dock will allow facility operators to load/unload waste materials directly into the building using hydraulic dock levelers, which will be a significant improvement compared to current waste handling practices which require operators to first unload pallets onto the ground before relocating the waste to the appropriate storage area.
It should be noted that the size of the site posed a significant constraint on the project. D&B’s design includes the above described waste storage areas, as well as a two-story office area with locker rooms, a shop area, quality assurance/quality control laboratory, conference room, break room and general office areas. Including provisions for these areas within the building while allocating space for truck routing, parking, drainage facilities and landscaping required efficient site design and significant coordination with CPC and Town of Islip personnel. Variances from the Town of Islip were required for parking and landscaping relaxations. D&B was responsible for preparing applications to modify existing Deed Covenants and Restrictions for the property and presenting the application to the Town of Islip Planning Board and Town Board in order to obtain the required variances. In addition, D&B was responsible for preparing applications to the Town of Islip for Site Plan Approval and for Building Department approval.
Since public sanitary sewers are not available in the area, D&B included a septic system for managing on-site sanitary wastewater in the design documents and D&B submitted an application to the SCDHS for approval of the proposed design. Due to relatively high water table conditions, D&B was required to prepare an Engineering Report documenting that the proposed system would function properly given the nature of soil and location of the water table at the site. In addition, due to the site’s close proximity to the Sonia Road Landfill, SCDHS required D&B to prepare a Methane Mitigation Report as part of the septic system application to document that methane gas in the subsurface environment is being properly managed by the landfill and would not pose any issues related to the septic system installation and operation.
At the present time, the required variances for the project have been obtained and the modified Deed Covenants and Restrictions approved by the Town of Islip, Site Plan Approval has been obtained, and septic system and Building Department review is currently in progress.
Leadership in Energy and Environmental Design (LEED) Certification
CPC, in consultation with D&B, decided to pursue a LEED certification for the facility reconstruction project. To support CPC’s decision making process which ultimately led to CPC’s decision to pursue a LEED certification, D&B conducted a detailed review of the proposed design and LEED rating system to identify aspects of the design that could incorporate green construction. This included the preparation of a detailed summary of the various green alternatives, the credits available under the LEED rating system, and the associated design and construction costs for implementing each alternative.
Based upon the results of this analysis, several green construction alternatives were incorporated into the design, including improvements to the building envelope for energy savings, the use of light emitting diode (LED) light fixtures to reduce electricity usage, the use of low-flow plumbing fixtures, recycling of construction and demolition debris, and the use of native drought-resistant plants that do not require routine watering, among others.
The project has been registered with the United States Green Building Council (USGBC) and D&B anticipates submitting applications for LEED credits prior to and during the construction project with the goal of obtaining a LEED Silver rating.
Resource Conservation and Recovery Act (RCRA) Permitting
When the design of the facility was approximately 50% complete, D&B met with representatives of the NYSDEC to present the proposed project and gain NYSDEC’s support for the revised conceptual plans. Based upon the outcome of this initial meeting, D&B prepared Interim Operating Procedures (IOPs) to outline how the facility would operate prior to and during construction of the new facility. The IOPs included a revised RCRA Closure Plan describing how CPC will close its existing facility in accordance with NYSDEC’s hazardous waste regulations.
In addition, D&B prepared an application to modify CPC’s existing Part 373 Permit to incorporate the revised conceptual plan. A key component of the permit modification process was to establish procedures to allow CPC to operate at the facility until construction, during construction and after construction. As a result, D&B worked closely with CPC and NYSDEC to gain approval of the IOPs and setup the modified permit to include provisions for operating the facility under its existing Part 373 Permit until construction, with certain exceptions and modifications, the IOPs during construction and the modified Part 373 Permit after construction is complete and approved by the NYSDEC. Due to the nonhazardous waste operations conducted at the facility, the permit modification included information suitable for review by the NYSDEC to support the issuance of a Part 360 Permit for the facility in addition to the hazardous waste permit.
D&B reviewed the draft Part 373/360 Permit issued by the NYSDEC for Public Comment and provided the NYSDEC with comments on the draft Permit on behalf of CPC. The final Permit became effective in June 2010.
Ongoing Compliance Assistance with Part 373/360 Permit
D&B has provided CPC with ongoing compliance assistance associated with its Part 373/360 Permit since being retained by CPC, which included the following activities:
• D&B updated CPC’s existing Groundwater Monitoring Plan (GWMP), which requires semiannual sampling of the existing nine groundwater monitoring wells, to incorporate NYSDEC comments. In addition, D&B conducted the April 2011 groundwater sampling event and prepared a report documenting the results of the sampling event.
• CPC’s Part 373/360 Permit requires CPC to conduct an annual inspection of its secondary containment areas. As a result, a New York State licensed Professional Engineer from D&B conducted a detailed inspection the secondary containment areas and prepared a report documenting the results of the inspection and providing recommendations for upgrading the containment areas to ensure their integrity.
• CPC’s Part 373/360 Permit also requires CPC to conduct biennial integrity assessments of the hazardous waste storage tanks operated at the facility. D&B conducted the 2010 biennial integrity assessments at the facility and prepared a report documenting the results of the inspection and providing recommendations for upgrading the tanks, as necessary.
• CPC replaced three aboveground hazardous waste tanks at the facility. D&B inspected the tanks in order to fulfill the requirements of 6 NYCRR Part 373-2.10(c)(2), which requires any new hazardous waste tank system to be inspected by an independent, qualified Professional Engineer licensed to practice in the State of New York prior to placing the tanks in service.
RCRA Facility Investigation and Corrective Action
The June 2010 modified Part 373/360 Permit required CPC to prepare a Current Conditions Report and complete a RCRA Facility Investigation (RFI) at the facility as a result of historical operations conducted at the site. In addition to the Corrective Action requirements contained in CPC’s modified Part 373/360 Permit, the site is a listed Class II Inactive Hazardous Waste Disposal Site. CPC retained D&B to prepare an RFI Work Plan, which included a Current Conditions Report, for approval by the NYSDEC. The RFI Work Plan outlined a proposed soil and groundwater sampling program at the site.
Once the RFI Work Plan was approved by the NYSDEC, D&B implemented the work plan, which included advancing 42 soil probes to the water table and collecting soil samples for laboratory analysis, developing and sampling nine existing onsite and off-site groundwater monitoring wells, excavating four test pits in an area of suspected underground storage tanks (USTs) and collecting soil samples from the test pits for laboratory analysis. D&B oversaw removal of two approximately 4,000-gallon USTs discovered during the test pit activities in accordance with NYSDEC and SCDHS requirements during implementation of the RFI.
D&B summarized the results of the RFI into an RFI Report and Focused Corrective Measures Study (CMS) which was submitted to the NYSDEC for review and approval. The results of the field program identified concentrations of contaminants of concern in both site soil and groundwater. The contamination primarily consisted of chlorinated volatile organic compounds (VOCs) in site soil and groundwater beneath the existing outdoor drum handling and storage areas, although pesticides, semivolatile organic compounds (SVOCs) and metals were also detected. The Focused CMS prepared by D&B recommended soil excavation and disposal followed by in-situ chemical oxidation to address the contamination identified during the RFI.
D&B is currently in the process of preparing a Focused Corrective Measures Work Plan (CMWP) for review by the NYSDEC to outline implementation of the corrective measures selected during preparation of the Focused CMS.
Since the site will be undergoing RCRA Closure and Corrective Action in accordance with its modified Part 373/360 Permit, the site is a Class II Inactive Hazardous Waste Disposal Site and since significant soil excavation will be conducted in order to construct the new facility, D&B coordinated closely with NYSDEC to satisfy the goals of these various programs through implementation of the RFI and corrective measures. The overall goal of the RCRA Closure program and corrective measures designed by D&B is to close the existing facility in accordance with the approved RCRA Closure Plan, satisfy the facility’s corrective action requirements and delist the site from NYSDEC’s Registry of Inactive Hazardous Waste Disposal Sites.
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