Posted on July 13, 2015
Client: Safety-Kleen Corporation
Project Type: Environmental Compliance and Permitting Services, NY
The firm was retained by Safety-Kleen Corp., an organization recognized throughout North America as a leader in waste oil recycling, to provide environmental permitting and overall multimedia compliance services in connection with its 25 million-gallon per year waste oil recycling and reprocessing facility located in Buffalo, New York. All environmental engineering activities were completed in support of Consent Order negotiations with the New York State Department of Environmental Conservation (NYSDEC) and in coordination with the requirements of an on-site Environmental Monitor. At the initial stages of the assignment, the firm prepared a completely revised Part 360 permit application package for the facility, addressing the recent revisions to NYSDEC’s revised Part 360 regulations for used fuel oil recycling and reprocessing facilities. This portion of the project included the following activities:
• Design, integration and implementation of comprehensive revisions to Safety-Kleen’s national standard operating procedures into a Quality Control Plan for the facility. The plan made provision for a decision matrix presenting a detailed protocol defining the specific waste streams to be accepted at the facility. The Quality Control Plan presented detailed specifications for the following:
– waste stream sample collection procedures based on the type and source of incoming waste oil to the facility
– the identification of specific sample collection frequencies based on similar source categories
– the review of specific laboratory analytical procedures to be utilized in analyzing waste oil based on its source of generation, thereby allowing for proper waste characterization
– the utilization of various regulatory thresholds to screen for and protect against the acceptance of hazardous waste at the facility
– the development of clear and definitive standard operating procedures addressing the specific circumstances under which waste would not be accepted and how such rejected waste loads were to be properly “manifested” to its point of origin
– The development of comprehensive internal auditing procedures for assuring regulatory compliance and appropriate Quality Assurance/Quality Control at the on-site laboratory.
• The development of a detailed inspection and record keeping system to assure and enhance the compliance of the facility with the following environmental regulations:
– 6 NYCRR Part 360 regulations regarding used oil
– 6 NYCRR Part 600 series regulations regarding aboveground petroleum bulk storage tank requirements
– 6 NYCRR Part 373 regulation regarding hazardous waste management, as appropriate
– 40 CFR Part 112 and Article 11 of the New York State Navigation Law pertaining to Spill Prevention Control and Countermeasures (SPCC) Plan requirements
– Spill and emergency reporting under various regulatory programs including SPCC Clean Water Act and Part 360 Contingency Plan requirements.
• The preparation of a facility-wide closure plan for both waste oil and hazardous waste storage
tanks including cleaning, decontamination, “vapor freeing” and final decommissioning.
• The preparation of a Contingency Plan providing for emergency response to spills, fires and explosions, including containment, cleanup, decontamination and repair procedures following response actions.
• As part of the initial environmental review, the firm provided technical assistance to Safety-Kleen in the evaluation of the performance of the on-site wastewater treatment system with regard to compliance with the mandated effluent limitations established by its State Pollution Discharge Elimination System (Buffalo Sewer Authority) permit.
In addition, a facility-wide environmental compliance review of bulk storage facilities, including aboveground tanks, secondary containment structures, loading/unloading racks and process equipment was conducted by the firm. Compliance with 6 NYCRR 360 and 612, 613 and 614 was evaluated in detail and corrective action was recommended as needed to bring the facility into compliance with state and federal regulations.
Safety-Kleen Corp. also retained the firm to update the facility Spill Prevention, Control and Countermeasure (SPCC) Plan and provide a Registered Professional Engineer’s certification as required by 40 CFR 112. In this capacity, D&B worked closely with Safety-Kleen operating and engineering personnel to identify noncompliant equipment, practices and procedures, and implement corrective actions. The scope of this work included a comprehensive evaluation of facility drainage structures, transfer operations, pumps and in-plant process equipment, tank and rail car unloading racks, and facility security measures.
As a result of the firm’s inspection activities, a list of facility improvements was developed along with cost estimates and an implementation schedule. Additionally, in response to corporate concern with regard to future air compliance, the firm has provided engineering assistance to Safety-Kleen in connection with a preliminary air emissions inventory at the facility.
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