Singer Furn_Closure Plan-Post Closure Plan-Financial Requirements-OCR

--·
are generated during the cleanup of spray booths where the material is applied to
furniture. Discarded rags were used to wipe off filler and dust from the product during
finishing operations. All three wastes are handled, stored, and treated as ignitable
wastes although they are not normally expected to be ignitable at the time of storage or
treatment. These three wastes are generated at two Singer sites in Lenoir as well as
plants in Roanoke, Virginia, and Washington, North Carolina. Nonliquid wastes from
offsite plants are transported by the U.S. Environmental Protection Agency (EPA)
registered transporters to Singer Plant No. 33 in Lenoir. The wastes are stored in
containers until they are incinerated.
Onsite generated liquid wastes from manufacturing operation include stains,
rinser paints, lacquers and other finishes used in furniture finishing. Other onsite
generated liquid wastes include spent nonhalogenated solvents used in the cleanup of
equipment and wash-off of finished furniture. All liquid wastes are characterized and
shipped by EPA listed transporters to an EPA listed treatment, storage, and disposal
(TSD) facility for recycling within 90 .. days of the original waste accumulation date.
In summary, Singer Plant No. 33 serves as a storage and treatment facility for
ignitable solid hazardous wastes generated by several Singer plants. Only nonliquid
hazardous wastes are stored for longer than 90 days, and these are incinerated in a
pyrolitic incinerator. Incinerator residue is nonhazardous and is disposed of in a local
landfill. This closure plan addresses the loading/unloading, storage, and incineration of
solid hazardous waste.
Fig1..1re 1-'1 is a facility topographic map and site plan. This figure shows plant
buildings, property boundaries, parking lots, internal roads, sewers, hazardous waste
facilities, and other pertinent details. Topography is shown at 5-foot contour intervals
for an area extending approximately 1000 feet in all directions from the perimeter of the
hazardous wastes management facilities.
Singer's property is bounded on the north by Lower Creek, on the east by
Virginia Street, on the west by City of Lenoir property, and on the south by privately
held property. All contiguous properties are zoned for industrial use. The hazardous
2/26/93 1-3 Revision 3
·" J
":.
1 !·•· ,.
•s w~rl!t Jaken from maps of lht11
N. !3.ollck, Reg:·S1.1iv#yor.
JES 10 C.<JNGRE.SS f l••A!•CIAl.
>~ :~~E~/~~~~i~R~O~~·~~t~. AS .~
.O IMGS, STQ~ClURES, P4RKl~G
; ON HtE f>frOP££lTY 1.0C.Al(~ AT
.PllW7 II 'I A(ollJ II 33 J
: EVIDENCE' OF EA5EMEt1TS• R•GriTS
H TO THE aEs l OF OUR AB IL11Y.
t A J EASEMEN'fS Af'ID RIGHTS Of
SOOK ~ND PAGt f'lU"*IER Of .
>AfHY WAl.l.S {CJ t'.NCRvAChMOHS
; OR .:.1.1.El'S 9\' AND OF SA 10 ~ '1MPRl>Vt.MU1T$, 011 I 0)
oS SY AIH tH•l tolffo. Sffll.JCl\NE
~ON ANY A~J~IW I NG Pk[MJSE&. AkU
~IOLAll ANY Sfl flAta OR or~e~ ~ES~ ANU E6H(~5 FROM !Hl
'lf~STH£E:r .<;.R. Jl461 :n i>1;fJ 1 ,, A •• •11T::. (;F wt.1
P .wr, r. ... D. :J. '!.
[.~Tf':}: t·· 16•9(;
~ ...... ) NC ~ • ;• ~:·. 1
.... : ...... ··. ..
] . ' . . .~., ·~~~/ '. ~ . : ..... :~;.. ~~,·':'»-;..}/.
I •:O •l . I;:· .~ .. ,~ ~~, : '· . ·. :-l~·-~:·~·i~t:f
.: f· : . ·: :~·; .·'{~~1Y:{!\~:1~: .' ·, .... ;·"':· "i;:\i ·j ,.,,,:·;,s., ... ~)~
J .• ; " •. '.< .• r~;;J1.
•• · • .,3 ... • .:·."fL:I . . •' .... ,a:, .. ~·._:\~~1~w
· · · · .':f.nkt
.... ~ .. ;·q~~' -:·:,·~ .!~~ :·t. . ;--_:y;~~~lt'· .. 1'f A I • ~:-;i;J'~! t?.-'· . :~s ·.1 • • . ; .. -,i)il •.
CONTll i NI NG 60. 969 llCRES ·. GRosS t 2, 655, 8.J s SF) ' . ; :);1::1
. . . .' . ' ·>: ']{''~ BEING~ ALL OF TR.AC.T XVI (PG~ 02!f) ~FIN!)_: . . . :·'-'t\:~
THE REMAINDER OF .TR.ACT XI I l (PG. : 02.1. > · · ··, :::'~\~ or ~OPERTY CONVEY$!). FR(J/1 . THE ·s !N.l;ER COHPANY . ·,-:":,•~.·ii'
(NEW JERSEY) TO SJNfi$R COHA4NY (-DEL-,V.JARE »·IN. . ·/.: ··.~.:~ !··
!)CED .BQOK 90.1 PAGES 001..0.03.! .13S:· RECDF?DE!l ·JN . THE . · .::-;;1~~
REGI STRY OF .DEEDS DF CALI»IE.C.L COUNTY~· NC.· . · "·r:·~'· . . ... , .. ' i: 1~·
DRAWING NO. F"-1()11 ... 11-s .~o.02 ! ·.·:::.;'}'.\
··--··-·-·---···--·------··-·----..--.---.--~-·... . ..._;__ •. :,.·-;1·. VJESTERN CAROL 1NA .$URVEYORS, -.P •. A~ . -,·.':\'
' l'.O • .ftO)( Hl7t . '." '.~'.:.:
·• ltLf, tro~J7H .. Ollit. lEMOr_R, i<.c. •tei~~ TEL(. l10~17$·8.:~j$l. " .. :;: '.;':"i' '-+i'TL.£--l'~lNSQRANCi'suRVE't' OF pfj-DPERTYiiEJ.ONGIMf TO.'.. :...,...,...~"'.''-~ ;. ~: >::;.
· SINGER FURNITURE .t'OHPANY · ,,. ! f\ .. ;::·;~t: I . . . """' " .. lc~;~~-;;;;:;·;;;-c~---·-·1=~;-··----T,=::L g·~-j : · · ~'.
. .t.62-·oJ. ~().! · I : -. : .. ;c£ fo-ii.-i :··· ·-.-·901 -.. ;:~~ooi ···· ·~·~~~---.--;;:~·---.. ---rrv 1 sr11-·-----re .... -.... .;. ,;_1-,
90<:f. ... ·-· . -··.. ---·-. ~·-:-l (. , ~.·.
I . • ~·--.· . --· •·•-Y91""--' • :·~
: ll'h>K _. l'~Gl . ··-llO<lK ··--· VA!Jt ·-r··-1-.. ~·~·-·';· -·. .'JS i~ r• [";~;;· 1'':~;; -· 1;~:~~~ ~;::~,~~::i0f:.j49f;; '~;.~-:~:;,:: ' ,~;
L__ ' · · · 'SJ': •9YJ'-fl ·-
l :.
~ .
1:
·r
~ ..
!•
... ·.~.
J .. _, ...... '..!,.:.f.-~~-~--··· •·•••••••• .. ~ ......... ·' ., ..... !.. ••.••• A .-., . .tt •• 't:l,. .. ,1..f..
ee
Carolina Solid and Hazardous Waste Management Branch. This waste is managed as
EPA Hazardous Waste Number DOOi .
The results of the additional tests on lacquer dust are as follows:
Clear Lacquer Dust~ Samgle Reference No. 101
Heating value
Toluene
Methyl Ethyl Ketone
Total Phthalates (as phthalic acid)
Total Sulfur
Total Chloride
Ash Content
8350 Btu/lb
< 200 ppm
< 400 ppm
14.9%
0.04%
0.27%
1.48%
Pigmented Lacquer Dust -Sample Reference No. 102
Heating value
Toluene
Methyl Ethyl Ketone
Total Phthalates (as phthalic acid)
Total Sulfur
Total Chloride
Ash Content
4828 Btu/lb
< 200 ppm
< 400 ppm
9.7%
0.04%
< 0.1%
1.48%
Singer mixes waste with moist sawdust so that 60 percent of the material fired in
the incinerator is waste, 40 percent is sawdust. The waste Singer incinerates is a
composite of many coatings used in each spray booth. Based on a review of purchase
records of phthalate-containing coatings and operating· records of the incinerator, the
maximum as-fired phthaiate content of the waste/sawdust mixture was less than 100
ppm. DEHNR agreed that the organic hazardous constituent concentration was
insignificant and the incinerator was exempt from certain trial burn and monitoring
requirements.
2/26/93 1-7 Revision 1
ee
SECTION J-2
DESCRIPTION OF UNITS
1-2.1 CONTAINER STORAGE AREA
The Container Storage Area is located outdoors on the north side of Plant No.
33 building, as shown on Figure 1-1. The maximum inventory of drums in storage at
any given time during the operating life of the facility was approximately 500. Drummed
hazardous wastes include lacquer dust, filler scrapings, and discarded rags. These are
nonliquid solid wastes. The container storage area is managed and permitted only to
store wastes that do not contain free liquids.
The only other waste stored in this general area is water wash stain, a
nonhazardous liquid waste. It is stored in a 6000 gallon storage tank adjacent to the
incinerator building. This waste and its storage tank are not a part of the permit or this
closure plan.
The Container Storage Area consists of a designated area just west of the
Lumber Shed on the north side of Plant No. 33. This area is approximately 40 by 35
feet. The area Is located so as to maintain a buffer of at least 50 feet from the plant
property line. A fence forms the northern border. Recessed landscape timbers form
the eastern and western borders.
Drums were stored on wooden pallets to prevent contact with any standing
precipitation. The pallets were placed in rows so as to maintain at least a 3-foot aisle
between rows for inspection purposes. No more than four· drums were stored on a
pallet. Steel 55-gallon drums were used at the facility to store solid hazardous waste.
The drums were constructed of low carbon steel that meets U.S. Department of
Transportation (DOT) Specification No. 17H.
2/26/93 1-8 Revision 6
Natural gas is used in the incineration system as the auxiliary fuel and can be fed
at two points. The main combustion chamber and the thermal reactor are each
equipped with a natural gas burner rated at 800,000 Btu/h, capable of being turned
down to 50,000 Btu/h. The thermal reactor burner is normally set at 45,000 Btu/h.
Combustion air is supplied to the main combustion chamber through openings
along the base of the chamber. The prJme mover Is a high pressure, direct-drive,
blower, rated to deliver at 640 SCFM at 4" W.C. and driven by a 1 H.P. motor. This air
flow rate maintains combustion in the main chamber in a pyrolytic state. Complete
combustion of the bases generated in the main chamber is achieved in the thermal
reactor. Additional combustion air enters the thermal reactor by natural draft through
shroud-covered air inlets. The residence time in this 8 cubic feet reaction chamber is
0.28 seconds, operating at 1500° F.
Fifty-five gallon drums containing solid hazardous waste were transported from
the Container Storage Area to the incinerator by a forklift with a drum clamp
attachment. The contents were historically emptied onto the recessed concrete slab in
front of the cold incinerator, from which the solid material is manually loaded into the
incinerator with a shovel prior to firing. Most recently waste, were emptied from drums
into a steel container. The container was used to homogenize the waste and mix the
waste with sawdust prior to loading into the incinerator. The as burned mixture was 40
percent sawdust 60 percent waste.
Nonhazardous water-wash stain is fed by a transfer pump from the 6,000 gallon
storage tank to the 120 gallon incinerator feed tank. A high level controller
automatically shuts off the transfer pump when the feed tank is full. A back-up
controller shuts off the transfer pump if the primary controller should fail.
Liquid is fed from the 120 gallon feed tank by a gear pump. The nonhazardous
liquid waste is injected into the incinerator through a nozzle, using compressed air at 25
to 40 psig to atomize the liquid. The nozzle orifice is 5/16 inch in diameter, large
enough to prevent pluggage by solid particles in the liquid. Liquid passing through the
orifice is atomized by four air jets directed at the orifice discharge. The feed rate is
automatically controlled according to the temperature of the flue gas leaving the thermal
2/26/93 1-10 Revision 1
f\.) ..........
I\) 0) .......... <O (.i)
. I\)
~
:0
([)
$.
(/) 5·
:J
0
Schedule Name
Responsible
As·of Date
Singer Closure Schedule Plnnt 33 lenoi r llorth Ceroll na
~anda Jenkins SFC Roanoke, Va 703 366·0361
24 • Feb·93 9:00a Sch•?dule File : SINGER
Task Name Resources Status
Submit Class I Mod c p
Receive State Appr c s
Review bids and aw c ps Conduct Inspection c ps
Container Storage ps
Soil Sampling p
tab Anal y9es ps
Oeta Evaluation s
Incinerator end An c ps OecOfillli s; on In c p
Ranove refrecto c ps
Oemoli sh Bui ldi c ps
Oecontllfllinete F c ps
Sample Refrac/D c ps Lab Analyses c ps
Data Evaluation c s
PE Certificetion c ps
Sut:mit Certiffcati c s
__.Detail Task ~n Stnmary Task ,,_. (Progress) ==;;; (Progress)
93
Mar
B 15 22 29
• . . . . . . . .
ooo .. Baseline
conflict
Apr s
....__ (Sleek) :::s--(Slack) ..... Resource delay
1 Milestone Progress shows Percent Achieved on Actual
··················Scale: 8 hours per char~cter
TIME LINE Gantt Chart Report, Strip,
12
. . . . .
. . . .
Mey
19 26 3
Ill -. .
. . . . . . .
. . .
Figure 1-5.1. Closure schedule.
Jun Jul
10 17 24 1 7 14 21 28 6 12
. . . . .
• aa .. •K88SGCOES5BB&aaa:JIR•E~.~ -
•!l!!9!1'W8&1!1"!!:seasemJ!!!1lllEl!IDB••••••-11•••••aJ1 ----•
. . -. . .
19
.
-
26
•
e
e
4t
ee
TABLE 1-6-1. CLOSURE COST ESTIMATE
1. General Items
Mobilization/Demobilization
Site Inspection/Certifications/Reports
2. Container Storage Area
Sampling 16 hat $45/h
Analyze 20 samples Level I QA/QC
3. Incinerator
Decommissioning 20 h at $45 /h
Removal of refractory 24 h at $45 /h
Demolition of building 50 hat $45/h
Decontaminate floor 6 hat $45/h
Sampling 6 hat $45/h
Analyze 9 samples Level I QA/QC
Heavy equipment at 3 days at $900/day
4. Disposal of Debris
40 ycf at $45 /ycf
Dumpster rental 3 mo at $200/mo
[Total
4/9/93 1-26
I
. " ...
April 1993
Implicit Price Deflater for GNP 121.2
3,000
13,800
800
6,666
900
1,100
2,500
250
. 300
3,000
2,700
1,800
600
37,416 I
Revision 1
• ••
Mr. Johnathan Howes 2
The Class i modifications require prior Director approval. Singer requests the Director
to approve this request expeditiouslly. Appropriate public notification will be made
within 90 days of rece'iving the Director's approval. Singer is anxious to complete the
closure activities. Should you have any questions, please contact me at (703) 366-
0361.
Sincerely,
SINGER FURNITURE COMPANY
~~&I~
Wanda S. Jenkins
Environmental Engineer, CHMM
WSJ/tlp
cc: Facility Operating Record With Enclosures
4/9/93 1-35.2 Revision O
t
iINGERA
FURNITURE COMPANY ,, ..
April 20, 1992
State of North Carolina
Department of Environment , Health, & Natural Resources
Division of Solid Waste Management, Hazardous waste Section
P. o. Box 27687
Raleigh, NC 27611-7687
Attention: Jenny s. Weaver, Section Paralegal
Dear Ms. Weaver:
I am the Ch ief Financial Officer of Singer Furniture company,
3322 Hollins Road NE, Roanoke, Virginia, 24012. This letter is
in support of the use of the financial test to demonstrate
financial responsibility for liability coverage and closure
and/or post-closure care as specified in Subpart H of 40 CFR Part
264, adopted by reference in North Carolina as 15A NCAC 13A
.0009(1).
The firm identified above is the owner or operator of the
following facilities for which liability coverage for sudden
accidental occurrences is being demonstrated through the
financial test specified in Subpart H of 40 CFR Part 264, adopted
in North Carolina as 1 SA NCAC 1 3A • 0009 ( 1). ...
FACILITY
Singer Furniture Company
904 Virginia St. SW
P. 0. Bo~ 1588
Lenoir, NC 28645
EPA IDENTIFICATION NO.
NCD 000604322
The firm identified above guarantees, through the corporate
guarantee specified in Subpart H of 40 CFR Part 264, adopted in
North Carolina as 15A NCAC .0009(1), liability coverage for
accidental occurrences at the following facilities owned or
operated by the following subsidiaries of the firm: None •
1. The firm identified above owns or operates the following
facilities in the State of North Carolina for which
financial assurance for closure or post-closure care is
demonstrated through the financial test specified in
Subpart H of 40 CFR Part 264, adopted in North Carolina
Continued
SlNGER FURNITURE COMPANY
3322 HOLLINS ROAD• BOX 5337 •ROANOKE, VA 24012·0337 • [phone] •FAX: [phone]
•seiGU•t"tn.:lnt\)t11f/nu~rC~t..~t1.mn~1~~~'~'c~