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Environmental
Compliance Audit
For a municipal vehicle maintenance facility located in
southwestern Connecticut, HRP Associates, Inc. completed an
environmental compliance audit under EPA New England's
Department of Public Works (DPW) Audit Incentive Program. The
environmental compliance audit consisted of reviewing all
operations and related documents for compliance with applicable
environmental regulations. Upon completion of the compliance
audit, HRP prepared the required self-disclosure questionnaire,
which listed all identified regulatory deficiencies, and
submitted this questionnaire to the EPA within 21 days of the
audit. A final report which documented all HRP's findings,
conclusions, and recommendations was submitted to the DPW
facility.
HRP also assisted the DPW in correcting specific regulatory
deficiencies and reported this information to the EPA.
Closure of Hazardous Waste Container
Storage Areas
Under this project, HRP prepared and implemented a closure plan
for a chemical manufacturer's three, greater than 90 day,
hazardous waste storage container storage areas. The closure
procedure carried out under this CT DEP approved closure plan
was as follows:
-
Identification
of final hazardous waste constituents for each storage area
– analysis of concrete floor samples for 40 CFR 261 Appendix
IX hazardous constituents;
-
Development of
clean closure standards for identified hazardous waste
constituents;
-
Investigations
of secondary containment systems for potential pathways to
surrounding environment;
-
Sampling and
analysis of subsurface soil from suspected pathways (e.g.
cracks in concrete floor) for identified hazardous waste
constituents;
-
Sampling and
analysis of secondary containment system surfaces for
identified hazardous waste constituents;
-
Excavation and
disposal of subsurface soils and concrete secondary
containment systems which exceeded clean closure standards;
and
-
Backfilling of
excavated areas with clean fill and pouring of concrete
floors.
A clean closure
certification for the three storage areas was submitted to the
CT DEP.
Part B Hazardous Waste Permit Application
HRP Associates, Inc. prepared a Part B Hazardous Waste Permit
Application for the greater than 90 day container hazardous
waste storage building located at a U.S. Naval Subbase. The Part
B Permit Application included detailed information on the
following hazardous waste management procedures/activities:
-
Waste Analysis
-
Inspection
-
Training
-
Emergency
Response
-
Security
-
Container
Loading/Unloading
-
Traffic
Patterns
-
Preparedness &
Prevention
-
Recordkeeping
-
Closure
-
Containment
System Design
-
Incompatible
Wastes
The site-specific
figures and plans provided in the permit application included:
site plan, layout of storage building, topographic map, wind
rose, flood plain, land use, traffic patterns, security,
evacuation routes, recordkeeping logs, and waste profile
databases.
In order to keep all hazardous waste management
practices/activities under one document, the permit application
also included detailed information on hazardous waste management
procedures for satellite sites, <90 day accumulation area, and
non-permitted recycling activities.
During the preparation of the permit application, HRP met with
key U.S. Naval Subbase staff almost weekly to review completed
sections of the permit application. These meetings allowed the
U.S. Naval Subbase to review the application in manageable
pieces, provide HRP with timely comments, and submit the
completed Part B Permit Application on-time and within the
budget.
For more
information, please contact
Richard McFee,
P.E. or Tad
Goetcheus, P.E. at 1-800-246-9021
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