RCRA SERVICES

Client: Fertilizer Manufacturer -- Closure Plan Preparation and Implementation

Objective:

Provide hazardous waste facility engineering support services for fertilizer manufacturing facilities, including RCRA Part B permit applications numerous closure plans.

This long-term contract includes a variety of hazardous waste facility engineering support services for fertilizer manufacturing facilities. To date, the main areas of support have been the preparation of RCRA Part B Permit Applications for the facilities, and the preparation and implementation of numerous closure plans.

Five closure plans have been prepared for different hazardous waste management units. One closure has been completely implemented and certified. Two closures are nearing completion and are awaiting final approval from the state. One plan currently is being reviewed by State regulators. The fifth closure plan is for an active facility. This plan is on file with the State for future implementation.

Two Closure Plans were prepared for the Money Point facility -- one each for an outdoor waste pile facility and an indoor tank mixing facility. Both plans were approved by the State. Site sampling, analyses, and statistical evaluation services were provided. The assessment resulted in the excavation of the building housing the tank and concrete slab which were used for the waste piles. Significant volumes of contaminated soil were also excavated. Closure activities are complete at both facilities, and have been approved by State and EPA officials.

At the South Norfolk facility, closure plans were prepared for an indoor waste pile area, an outdoor temporary waste unloading area, and a waste storage/processing area. The plan for the indoor waste pile area is currently being reviewed by state regulators. The closure plan for the outdoor waste unloading area was approved, implemented, and certified. The final plan addresses the waste storage and processing areas currently in use. This plan, prepared as a component of the facility Part B Permit Application, has been reviewed by and is on file with the State.

Client: Tool Steel Manufacturer -- RCRA Closure and Post-Closure, Surface Impoundment at Metal Finishing Plant, South Boston, Virginia

SCS' initial assignment was the preparation of a clean closure plan for a RCRA surface impoundment. The impoundment received lime stabilized spent pickle liquor sludge generated by an industrial waste treatment system for the plant's metal plating lines. The spent pickle liquor sludge was a RCRA hazardous waste which had been delisted by EPA.

Upon further investigation it was determined that the surface impoundment also received the supernatant from the waste treatment process. Negotiations with State regulatory personnel concluded that the State considered the surface impoundment a RCRA hazardous waste management unit because the supernatant had not been delisted under RCRA. Thus, clean closure could not be achieved (unless the lagoon was emptied), and a RCRA post-closure permit was required.

SCS prepared the closure plan, which included site re-grading and the design of a RCRA multi-layer cover system. Cover system components include a clay layer to minimize precipitation infiltration, a vegetation support layer to control erosion, and run-on control features. SCS assisted in identifying, evaluating, and selecting a contractor to install the cover system. SCS provided construction oversight and closure certification.

Following closure, SCS prepared the Post-Closure Permit Application, which included a groundwater assessment program and a routine inspection and maintenance program for the cover and vegetative layer. SCS assisted in implementation of the groundwater assessment program, including statistical analysis of the quarterly groundwater monitoring data and preparation of groundwater assessment reports for submittal to the Virginia Department of Waste Management.

Client: Southeastern Public Service Authority (SPSA), Chesapeake, Virginia - Small Quantity Generator Hazardous Waste Management Feasibility Study

SCS surveyed and analyzed 22 small quantity hazardous waste generators and recommended appropriate actions to improve management of hazardous wastes for six cities and two counties in Southeastern Virginia.

SCS was retained by SPSA to conduct a survey of the small quantity hazardous waste generator (SQG) population in its area and determine the amounts and types of hazardous wastes generated, as well as the current disposal methods practiced. The study area covered the Cities of Chesapeake, Franklin, Norfolk, Portsmouth, Suffolk and Virginia Beach and the Counties of Isle of Wight and Southampton. Twenty-two industrial groups were identified based on the types of waste expected to be produced and on the types of good and services provided.

SCS chose a two-tier approach to the survey. First, the number of SQGs and the types and amounts of waste generated were estimated using the California Technical Manual "No Survey" method. Second, a limited survey was conducted, using a stratified random-sampling method, to determine if the SPSA service area SQG data differed significantly from the national data; the survey also provided information on SQG waste management practices in SPSA's service area.

The results of the survey indicated that approximately 86.8% of the wastes were solvents and paint wastes. The survey indicated that the majority of SQGs were disposing of their wastes properly; only seven percent of the respondents reported using an inappropriate disposal method (e.g., sending wastes to a sanitary landfill or transfer station).

In order to project future SQG waste generation rates, SCS calculated the projected economic growth and the population growth. The results suggested that SPSA can anticipate 67% more hazardous waste will be generated in the year 2010. To assist SPSA in determining methods which would help meet the future needs of the SQG population, SCS analyzed several alternatives, including no additional action. Recommendations included: an educational outreach program; upgrade of security against receipt of hazardous wastes at the landfill(s), transfer station(s) and on haul trucks; recycling; and requirement that SQGs which use SPSA services provide proof of a reasonable amount of liability insurance. The final recommendation was that SPSA should not implement a plan to provide a hazardous waste collection/transfer facility as this could cause SPSA to become a hazardous waste generator itself.

Client: Tool Steel Manufacturing Facility - RCRA Facility Investigation, Corrective Action Plan, and Lagoon Closure, Bedford, Pennsylvania

Problem:

Manufacturing facility under EPA Administrative Order to alleviate potential releases of hazardous waste constituents.

Solution:

Performance of lagoon closure and negotiation of scope of work for performance of the RCRA Facility Investigation.

SCS has provided services to this facility, which manufactures tungsten carbide tools, since 1987. SCS designed and provided oversight for RCRA closure of two lagoons containing pentachlorophenol (PCP) compounds, conducted a waste minimization study, and conducted a RCRA Facility Investigation (RFI). The RFI focused on environmental conditions on and near the Bedford site, with particular attention to possible historical releases of PCP, trichloroethane, and polychlorinated biphenyls.

The RCRA status of the facility is controversial. Samples of sludges from two lagoons formerly used for wastewater treatment were found to contain PCP, and thus the lagoons were regarded as regulated units by the Pennsylvania Department of Environmental Regulation (PaDER). However, the plant never used PCP, according to available records. Instead, it appears that a sodium pentachlorophenate compound contained in paints used at the plant may be the source of the PCP found in the lagoons. Despite the fact that no listed hazardous wastes were known to be treated in the lagoons, PaDER ordered them closed as RCRA units. SCS prepared construction plans and provided construction oversight, eventually certifying closure in accordance with the plans.

The U.S. Environmental Protection Agency (USEPA) Region III issued an Administrative Order for Kennametal to provide information under Section 3013 of RCRA.  The order included a statement of work for an RFI. SCS summarized current conditions, reviewed preliminary corrective action technologies, and prepared a work plan (including sampling and analysis, quality assurance, data management, and community relations plans) for the RFI.

As part of the on-going field investigations for the RFI, SCS has conducted multiple rounds of groundwater, surface water, and sediment monitoring and analysis. In addition, SCS currently is preparing an ecological risk assessment and a human health risk assessment. In support of the ecological assessment, SCS completed a wetland assessment, characterization of dominant site vegetative communities, and semi-quantitative analysis of the upstream and downstream benthic macroinvertebrate communities. Other tasks included a soil-gas survey, stormwater permitting, and quarterly groundwater monitoring.

SCS provided technical support for extensive negotiations with both PaDER and EPA Region III concerning both the lagoon closure and the scope of work for the RFI.

Client: Paint Manufacturer, Portsmouth, Virginia

Problem:

Buried paint waste; groundwater and soil contaminated with a variety of solvents at a paint manufacturing facility.

Solution:

Excavation of buried paint waste and contaminated soil. Bioremediation of shallow soils. Groundwater pump-and-treat using air stripping.

SCS was retained by the bankruptcy court (through the Trustee) to provide multimedia, turnkey remediation services at a former paint reclamation and manufacturing facility. SCS services included the design, permitting, installation, and operation of soil and groundwater remediation systems. The groundwater pump-and-treat system consists of a 25-foot recovery well and a shallow tray air stripper. Treated water is discharged to an adjacent stream under an NPDES permit. An air emissions permit was also obtained for the air stripper. SCS is providing operations and maintenance services for approximately two years, including sampling and analysis of the raw water feed and treatment system effluent on a monthly basis, and preparation of the monthly discharge monitoring reports for the NPDES permit.

Surface soils were treated using a combination of bioremediation and aeration. This relatively simple remediation system consists of the application of two tons each of nutrients (fertilizer) and lime at six month intervals. Nutrients and water are then disked into the surface soil. Prior to initiating the soil remediation activities, four soil samples were collected to document baseline conditions of the area to be treated. Post-treatment soil analyses indicated that the bioremediation and aeration approach was effective in significantly reducing the concentration of volatile organic compounds in surface soils.

The final task involved the removal of buried paint materials and contaminated soils. Approximately 100 cubic yards of buried paint, paint waste, and contaminated soil were excavated. Hundreds of intact, damaged, and corroded paint containers were also removed. The removed materials and soil were segregated, characterized and transported off-site for treatment at a RCRA permitted hazardous waste facility. Contaminated perched water was also removed from the excavation for off-site treatment. A final report is being prepared to document the remediation activities and effectiveness.