Singer Furn_Class I Permit Modificaiton - Revised-OCR

CLASS I PERMIT MODJFICATI ON
SINGER FURNITURE COMPANY -PLANT NO. 33
LENOIR, NORTH CAROLINA
HAZARDOUS WASTE MANAGEMENT PERMIT NUMBER NCD000604322
Submitted to Secretary Johnathan Howes
North Carolina Department of Environment,
Health, and Natural Resources
Submitted by
Singer Furniture Company
Post Office Box 5337
3322 Hollins Road
Roanoke, Virginia 24012-0337
Prepared by
Environmental Quality Management, Inc.
Cedar Terrace Office Park, Suite 250
3325 Chapel Hill Boulevard
Durham, Nor'u'1 Carolina 27707
April 9, 1993
Revision 1
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I --.
TABLE OF CONTENTS
Section
Figures
1.
2.
3.
Introduction
1.1 Purpose and scope
1.2 Description of facility
Permit Modifications/ Changes
2. 1 Specific changes
Certifications
2.1.1 Standard conditions
2.1.2 General facility standards
2.1.3 Storage in containers
2.1.4 Treatment in tanks
2.1.5 Incinerator
3.1 Signatory requirements
Appendices
A 1 Relevant Portions of the Base Permit
A2 February 26, 1993 Modified Pages of the Permit
A3 Closure Plan and Financial Requirements
ii
Revision O
February 26, 1993
iii
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1
2
5
5
5
6
6
6
7
8
8
A1 -1
A2-1
A3-1
Number
1
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FIGURES
Topographic map and site layout
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February 26, 1993
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SECTION 1
INTRODUCTION
1.1 PURPOSE AND SCOPE
Revision O
February 26, 1993
Singer Furniture Company (Singer) has determined that clean closing the
hazardous waste container storage area, a nonhazardous waste storage tank, and the
incinerator located at its facility located at 904 Virginia Street, Plant 33, Lenoir, North
Carolina, is in the best interest of the company. The North Carolina Department of
Environment, Health, and Natural Resource Division of Solid Waste Management,
Hazardous Waste Section was notified of Singer's intent to implement the facility's
closure plan on October 17, 1992. On October 29, 1992 the Department notified Singer
that its final closure plan had been reviewed and approved. The Department's letter
also indicated that closure must begin within 180 days and that certifications from the
owner /operator and an independent professional engineer must be submitted to the
Department following completion of closur~.
Singer solicited proposals to implement the closure plan and as part of its due
diligence review discovered that implementation of the plan will: generate substantial
volumes of liquid wash waters; require inappropriate laboratory analyses; require
inappropriate procedures for decontamination; require additional State approvals tor the
closure waste analysis plan; require Singer to store the wash waters and debris until
laboratory results confirm that the clean closure standard has been achieved; require
changes in the closure schedule; and require revised closure cost estimates. The
purpose of this Class i permit amendment is to modify the permit in accordance with
North Carolina rules 15A NCAC 13A.0013 and corollary Federal rules (40 CFR 270.42)
identified as Permit Modification at the request of the permittee. Singer believes the
requested changes are equally protective of human health and the environment, saves
significant sums of money, and minimizes the volume of solid and/or hazardous waste
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February 26, 1993
that must be disposed. For these reasons Singer believes the permit amendment is
necessary. This document specifies the changes being made to the permit conditions
and supporting documents referenced by the permit. These changes do not
substantially alter the permit conditions or reduce the capacity of the facility to protect
human health or the environment. The Class I modifications identified herein require
prior director approval. Hence, Singer requests the director to approve this request
expeditiously. Appropriate public notifications will be made within 90 days of receiving
the directors approval. Singer has elected not to follow the Class 2 permit modification
procedures described in 270.42(b). Singer does not anticipate citizen opposition to
plans described herein. Singer will implement the plan as soon as practicable after
State approval is received.
1.2 DESCRIPTION Of f ACIUTY
Singer Furniture is located in Lenoir, North Carolina. The street address is:
Singer Furniture
Plant No. 33
904 Virginia Street, S.W.
Lenoir, North Carolina 28645
The mailing address is:
Singer Furniture
Post Office Box 1588
Lenoir, North Carolina 28645
Singer is a manufacturer of dining room, bedroom, wall units, electronics, and
occasional furniture. Hazardous wastes are generated from the finishing processes
used.
Nonliquid solid wastes in the form of filler scrapings, lacquer dust, and discarded
rags are generated in the manufacturing processes. Filler scrapings and lacquer dust
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
2
SECTION 2
PERMIT MODIFICATIONS/CHANGES
Revision o
February 26, 1993
This section specifies the changes being made to Singer's Hazardous Waste
Permit Number NCD000604322. Copies of those portions of the original permit and
supporting documents that are being changed are included in Appendix 1. Singer will
retain copies of the permit and any changes made to the permit.
2.1 SPECIFIC CHANGES
The specific changes being made to the permit and/or supporting documents
are discussed and justified in the sequential order of the permit. For tracking purposes
the revised permit pages are dated February 26, 1993, with an appropriate revision
number. The revision number identifies how many times a specific page has been
revised since the original Part B permit application was prepared. Appendix 2 includes
copies of the modified pages.
2.1 .1 Part 1 -Standard Conditions
Section F.4, Page 8
The closure plan has been rewritten and references to pages 1-1 through !-13 ,/
and Appendix E of the attachment are superceeded by the amended plan submitted
herein.
Section F.5. Page 8
A revised closure cost estimate has been prepared and included in the closure
plan. Reference to Page 1-8 is superceeded by the amended plan submitted herein.
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2.1.2 Part II -General Facility Standards
Section P -Closure, Paqes· 13 and 14
Revision o
February 26, i 993
The closure plan has been rewritten and references to Pages 1-1 through 1-6 are
superceeded by the amended plan submitted herein.
Section Q -Cost Estimate for Facility Closure. Page 14
The closure plan has been rewritten. Reference to Page 1-8 of the attachment is
superceeded.
Section R -Financial Assurance for Facility Closure, Page 14
The closure plan has been rewritten. Reference to Page 1-8 and 1-9 and is
superceeded.
Section S -Liability Requirements, Page 14
The closure plan has been rewritten. References to Pages 1-11 and 1-12 is
,.~ superceeded.
2.1.3 Part Ill -Storage in Containers. Page 17
The closure plan has been rewritten. Reference to Pages 1-2 through 1-13 is
superceeded.
2.1.4 Part IV -Treatment in Tanks. Pages 18 through 20
Singer did not and does not intend to construct or use the portable treatment
tank authorized by Part IV of the permit. Hence, the information on Pages 18 through
20 is deleted and any other references to the tank are superceeded by this
amendment.
6
2. 1.5 Part V -Incineration
Section D. Page 20
Revision O
February 26, 1993
The closure plan has been rewritten. The revised plan does not include steam
cleaning and rinsate collection for the incinerator.
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APPENDIX 1
RELEVANT PORTIONS OF BASE PERMIT
Ai-1
Revision O
February 26, 1993
Revision O
February 26, 1993
F. ro:;uM!Nrs TO m M!\rnr.AINED A'r FACILl1Y SITE
'!he Pellllittee shall maintain at the :facility, until closure is completed
and certified by an indepmdent registered professional engineer, the
following doo.mmits and &rena1>=nts, revisions and nr.xiificatioos to trese
docu.inents:
1.
2.
3.
4.
. 5.
6.
Waste analysis plan submitted in accordance with 40 CFR 264 .13 as
adopted m 10 N::AC lOF .0032 and pages C-10 through C-12 and
Appendix A of the attachimnt.
Personnel training documents and records stbmitted m accordance
with 40 CFR 264.16(d) as adopted in 10 OCAC lOF .0032 and pages H-1
thra.igh H-21 and Appendix B of the attachme:lt.
C.Ontingency plan submitted in accordance with 40 CFR 264 .S3(a) as
adopted :in 10 N::AC !OF .0032 and pages G-1 through G-45 and Appe1dix
C of the attachnent.
Closure plan submitted in accordance with 40 CFR 264 .112(a) as
adopted in 10 N::AC lOF .0032 and pages I -1 through I-13 and Appendix
E of the attachnent:.
C:Ost estimate fur f.acility closure submitted in acoordance with 40
CFR 264.142(d) as adopted in 10 N::AC lOF .0032 and Sectioo I-4 cu
page I-8 of the att.achmnt.
Q>erating record required by 40 CFR 264. 73 as adopted in 10 l'CAC
1.0F .0032, and pages C-11, F-4 throogh F-7, F-15 through F-20, G-37
through G-39, H-21, Appendix B of the att:achDent: and Condition
I.D.9. of this JEnni.t.
7. Inspection sc~eS developed in accordance with 40 CPR 264 . 15 (b)
as adopted in 10 N:AC lOF .0032 and pages F-4 thrcugh F-7, F-15
through F-20 and Appendix B of the attachmot.
All amendioo:lts, re11isioos and modifications to sny plan Ol" cost estimates
required by this pennit shall be submitted to the Secretary of tre
IEpartnient of Human Resoorces or his designee for apprOV"al and permit
m:xlifica tioo.
G. ANN.JAL REFOID'
'Ihe Peunittee shal 1 prepare and submit an annual report by March 1 of each
year in accordance with 10 N:AC lOF .0037. The report shall include, in
accordance with 40 CFR 264.75 as adopted in 10 N'.:AC lOF .0032, the fi:>llowing
information for facility activities during the previoo.s calendar year:
1. The EPA identifi.ca ti.on nurrber, nane, and address of the :facility;
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2.
3.
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Revision O
February 26, 1993
explosion, or t:elea.ae of haza.rdo.is waste or cCt'lStituents "II.bi.ch
t:hreat:eos or oould tht"eate.n twman heal th or the eavit'OCUJBlt as
required by 40 CFR 264 .56 as acbpted :in 10 N:AC lOF .0032. All or
part of the contingency plan shall be imple:aeoted :fur both major and
minor incide:its. -
Copies of Plan .. The Permittee shall comply with the requirements of
40 CFR 264.53 as adopted in 10 N:AC lOF .0032.
Amaoduents to Plan. 'Ihe Penni.ttee shall review and imzedi.ately
amend, H necessary, the crotiogency plan, in accordance with 40 CPR
264 .54 as adopted in 10 N'.:AC 1(}' .0032. Singer tWSt submit
notification and an Bllla.1ded contingfficy plan thirty (30) days prior
to PlBI1t #33 closure.
~r~cy Coordinator. The P.ermittee shall romply with the
requ ementS of 40 CFR 264.55 as adopted in 10 N'.'.AC lOF .0032,
concerning too ea:ergency coordinator.
N. Manifest System, The Permittee .stuU.l comply with the manifest
requhea:ent:s of 40 CFR 264. 71, 264. 72, and 264. 76 as adopted in 10 N:AC
lOF .0032.
O. Recordkeeping and Reporting.
1. . q,erating Record. 'Ihe Permittee shall mintain a written operating
record at the fiicility in acoordan~ with 40 CFR 264.73(a), (b)(l),
(2), (3), (4), (S), (6), (7) (off-site only), (8), and (9) as
adopted in 10 N'.:AC lOF .0032, and as described on pages C-11, F-4
through F-7, F-15 through F-20, G-37 thrrugh G-39, H-21, Appendix B
of the attachment and Cooditicn I.D. 9. of this permit.
2. Amue.l Report. 1he Permittee shall comply with the annual report
requi.remeots of 40 CFR 264.75 as aoopted in 10 liCAC lOF .0032 and
10 N:AC lOF .0037.
P. Closill'e.
1.
2.
3.
Performance Standard. '!he Permittee shall close the facility in
accoi'darire Wlf h the closure plan as descr:ibed en pages I -1 through
I-6 of tre attacl:m?nt and as l:'equired in 40 CFR 264.111 as adopted
:in 10 N:AC lOF . 0032 . The Permit tee mall also coo.duct soil
sampling a t tre drum storage area down to tre top of tl-e 't" horlzoo.
Ana'tdn:mt to Closure Plan. The Permittee shall am:nd the closure
plan in accordance with 40 CFR 264 . ll2 (b) as adopted in 10 N::AC lOF
.0032 Yhenever necessa:ry.
Notification of Closure. Tne Permittee shall notify the Secretary
of the llipart:ment of Hum9Il Rescurces or his designee at least
forty-five (45) days prior to the date he expects to begin closure.
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5.
6.
Revision O
February 26, 1993
Tim? Allowed For Closure. Within 90 d9.ys after receiving the final
volune of fuiiai'dous waste> the Permittee shall treat or reax:we from
site all hazardrus waste in acoordance with the schedule specified
:in tre closure plan. After receiving tre final volwe of hazardous
waste. the Permittee shall <n:nplete closure activities in accordance
with t~ sch:!dule specified in too closure plan on page I-5 and
Figui:e I-1 of the att.achmeot.
D~sal or Decontamination of F..qui~t. 'Ihe Pennittee shall
cciliPY wu:fi the reqUJ.rements of 40·~64.114 as acbpted in 10 N:.AC
lOF .0032. All equipne.nt shall be emptied prior to decoatatni.nat::ion.
After steam-cleaning, the rinsate shall be collected and analyzed.
Sfager !l\L!St submit all analysis results.
Certificatioo of Closure. !re Permittee ::hall certify that the
facl.lity haS been Closed in accordance with too specifications in
the closure plan as required by 40 CFR 264. 115 as acbpted in 10 l'C~
lOF .0032. 'Ihe Pet:mittee shall also submit a certification from an
independent professional engineer verifying that the facility was
closed per the specifications of the closure plan as described on
pages I-1 throogh I-6 of the attachment and Ccnditicns III.I., IV.E.
and V.D. .
Q. Cost Estimate for Facility Closure. 'Ihe Pennittee shall comply with the
re:iuiremen ts of 40 CFR 264 .142 as ad::>pted in 10 N::AC lOF . 0032, includ~
tre requiremeots to adjust and revise too cost estimates, ~en necessary.
The Permittee' s approxi.mate closure cost estimate l.s described on page I-8
of the attachnent.
R. Financial Assurance for Facility Closure. 'Ihe Pei:mittee shall dem:mstrate
ccndruooa comph.ance with 40 CFR 264.14\3 as adopted in 10 N::AC lOF .0032,
or \!here applicable with 40 CFR 264 .146 1 264 .149, 264 .150, and 264. 151 as
adopted in 10 N:'AC lOF .0032 by providing documeotatic:n of financial
assurance in at least tre azrount of the cost est:Unates re:iuired by permit
Coodition II.Q. and page I-8 of the attachment.
1.he financial n:echanism used shall be that instniment specified on page
I-9 and Appendix E of the attachment. 'Iba Permittee may propose using a
different aechanism by submitting a new financial instrument to tre
Secretary of the ))apartment of Human Resrurces or his deaignee for
approval. '!he PelJD.ittee must sthmi.t this do~tation no later thao
sixty (60) days prior to the effective date of the pro~sed change. The
existing financial aechanistn shal. 1 remain in furce unti.l tre change is
approved .
S. Liabili~ Re:iuireirents. '!he Pennittee shall comply with tm requireimnts
of 40 C 264 .147 as adopted in 10 ~C lOF . 0032 > including the
requirements to have and maintain liBbility coverage for sudden and
acci.deJtal oca.irrences in the 8lll0unt of at least $1 million per occu.."'t"ence
with an annual aggregate of at least $2 million, exclusive o f legal
de tense cos ts.
The financial. 1113Chanism used shall be that instrument specified on page
1-11, I-12 and Appendix E of the attachment. The Pennittee may propose
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2.
Revision 0
February 26, 1993
The Permittee shall not place hauu:dous waste .in an unwashed
container that previously he~d an incom~tilile waste or material.
3. '1be Permittee shall not store a container of ha.zardrus waste that is
incompatible with any waste or roat:erial stored nearby in o~r
coot:ainers, piles, open tanks or surface im:pOUldmaltB wless the
rontainer is separated from the o~ materials by a dike, betm,
wall, or other device.
H. R~ of Containers. The Permittee shall receive the shiixoent of
d waste mteriBl as described en page D-3 of the a.tt:achmeat;
however, a min:!.nun of 10% of the drtma shall be fingerprinted as described
on page D-3 of the attachment. Any unacceptable wastes discovered during
this inspection shall be i.mnedia.tely returned to the generator.
I. Closure. The Perm:i.ttee shall follow the closure plan as described en
pages I-2 through I-13 of the a.ttacl:mlt and sh.all comply with 40 CFR
264.178 as adopted in 10 N:!AC lOF .0032. At a m:initnun, soil sampling at
tine of closure shall include samples tllken down to the top of the 't"
horizon. Singer arust sU:>mit a certification fran an independent
professional engine.e.r verifying that closure was completed to ~
specificati.cos of this Ccaditica of the permit.
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PAR!.' IV -TREA.TMENI' lN T.AN<S
Revision 0
February 26, 1993
The Singer facility shall use one pOrtable t~atnent tank fur mixing waste to
be loaded into the incinerator. This tank mall be located inside the
':incinerator building on the imparmeable, diked concrete floor.
!he t:ank shall be an ariproxi.mately 4' x 6 1 x 4' deep, V-shar-ed rootal hopper
attached to a 2' wide 'live-bottom" rubber belt comeyor. 'Ihe tank shall be
used to mix [()()l (lacquer dust)' roo1 (filler scrapings)) 0001 (discarded
rags), and damp sawdust. After mixing is completed, tre waste shall lealle the
tank, via the conveyor belt, to be leaded into the incinerator.
Since tl:e tank shall never rontain free liquids and is situated in a building
with. an :impermeable floor, this facility is e:xanpted from the i:equirements of
40 CFR 264 .193 as adopted in 10 !iCAC lOF .0032.
A. Des~ of 'l'anks. Th; Pennittee mall maintain al1 t.anks in accordance
wit pages D"6 and D-7 of the attachirent and the approved information to
be stbmitted after the effective date of the permit. '!his infonm.tioo
includes preliminary design drawings of tl:e tank and conve)Or belt,
as-built blooprints of the tank and conveyor belt, an assessJ.ne!.1.t of the
tank 1 s integrity, a cert:i.fi.cation from an independent profussiooal
engineer that the tank and belt assembly 'lo.'ere ccnstructed per the approved
plans and doet..mentation that th?. managen:ent of the tank system has been
added to the employee train~ program.
B. RfErting Requirenents. Within thirty (30) days after the effective date
o ffiiS pernu.t, Smger must slbmit preliminary design drawings of the tanl<
and other relevant information concerning tl'e tank and its installation.
Within ninety (90) days after approval of the tank system design, singer
Ol.1.lSt complete construction and installation of the tank and conveyor belt
assen:bly. Progress reports oo the tank cmatructicn must be stbmitted
every ronth during this 90-<lay period. Within thirty (30) days prior to
placing hazardoos waste in the treatment tank, singer mu.st stbmit as-built
blueprints of the tank and conveyor belt asseubly with an independent
profuasional engineer oottificaticn that the t.nit was built to neet or
exceed tl'e minim.Jm design specifications as described on pages D-6 and D-7
of the attachmEnt and as shown on the apprmred design drawings stbmitted
in accordaoce with Condition IV .A. Within thirty (30) days prior to
placing hazardoos waste in the tank, Singer must slbmit dorumentatioo that
t~ employees' training program includes de use and roanagen:ent of tre
tank.
C . General Qp:rating Requirerent.s .
1.
2.
'lhe Pennittee shall oomply with 40 CFR 264. 192 (a) as adopted in 10
l'CAC lOF .0032. A written assessment of the tank's structural
integrity must be submitted thirty (.30) days prior to placing
hazardous waste in the tank.
'Ihe Pemittee sh.all oompl y with 40 CFR 264 . 192 (b) as adopted in 10
N:'AC lOF .0032. An inde-pe:ident, qualified, registered professional
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3.
4.
5.
6.
Revision 0
February 26, 1993
engineer must inspect and certify the integrity of the tank and
Slbmit this certifi.ca ti.on thirty (30) days prlor to placing
hazarda.is waste in the tank.
'Ihe Pellllittee sh.all compl y with 40 CFR 264 .192 (e) as adopted in 10
tn\C lOF .0032. '!he conve~r belt assembly 11DJBt be supported and
protected against physical damage and excessive stress.
1he Permit tee shall canply with 40 CFR 264. 192 (g) as adopted in 10
f'CAC lOF .0032. 'Ihe Permittee shall cbtain and keep on file at th:!
facili.ty the wri.tten statemmts by those perscns required to certify
tm design and installati.on of tm tank system.
'!he Permitt ee shall a:mply with 40 CFR 264.194 as adopted in 10 tCAC
lOF .0032 and as described on pages D-6 and ~7 of the attachnent.
'!he Pertnitte~ must caapletely empty the tank befure washing the tank
rut as described on page D-7 of the attachn;ot.
D. Ias~cti.oos. '!he Permittee shall canply with inspectioo requirements set furt m 40 CFR 264.195 (b)(l) and (3), and (d) as aoopted in 10 N:AC lOF
.0032 and as descr:ibed on pages F-5, F-17 and Appendix B of the attachment.
E. Closure. 'I.he Pennittee shall follow the closure plan e.s described on
pages 1-2 through I-5 of the attachment and $:\all canply wit:h 40 CFR.
264 .197 as adopted in 10 f'CA~ lOF .0032 . '!he tank shall be empty befure
dee<ntamination, Both the tank and the comreyor belt assenbly shall be
st eam-cleaned and t:re ti..nsate oollected fur analysis. Singer Dl.ISt submit
the results of the analyses with a oertifi.ca.ticn fr0tn an independent
professional qineer verifying the closure plan was fbllowed per this
Coodition of the permit .
F. $pecial R~uire!ll'mt:S fur Ignitable or Reactive Wastes.
1. '!he Permittee shall caaply with 40 CFR 264.198(a) as adopted in 10
N::AC lOF • 0032 .
2. 'lhe Peilllit t:ee shall compl y with the requireimnts of 40 CFR
264.198(b) as adopted in 10 N:AC lOF .0032 .
G. Special Rf;quirenents for Incompatible Wastes.
1.
2.
'lhe Permittee shall not place ino:xnpatible wastes in the saxm tank.
'Ihe Pennittee shall not place hazsrdoos waste in an unwashed tank
"°ich previously held an inccmpatihle waste or material.
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PAR!' V -UCIIBRATION
Revision 0
February 26, 1993
'Ihis f.acility qualifies .fur the autO!llatic eJemption allowed under 40 CFR
264 .340 (b) as a.cbpted in N:'.AC lOF . 0032 and may~ incinerate the wastes 0001
(lacquer crust), IXXH (filler scrapings), and 0001 (discarded rags), \ohich are
listed solely because of ignit:ability. This eJ<a11ptioo is doa..miented in th;
facility's adninistrntive record and on page D-10 and Appendix A of tre
attachment. I
A. The Pellllittee shall operate and maintain the incinerator as described on
pages D-10 throo.gh D-18 of the attachment.
B. 'Ihe Petmittee shall inspect the incinerator and supporting structures and
equipm:nt as per 40 CFR 264 .347 (b) and Ccnditioo II.G. of this perm.it.
C. '!he Pet11l:i.ttee shall adhere to the waste analysis plsn as per 40 CFR
264.341 and Ccoditicn II.D. of this permit.
O. 'Ihe Pennittee stulll adhere to the closure plan conditions as per 40 CFR.
264 .351 and Cooditicn II .P. of this petmit. Tne incinerator and coocrete
pad must be stE!Blll-cleaned and the rinsate collected fur analysis after
deCXXlt:amination. Singer must stbolit the results of the analyses with a
certification from an independent professional engineer verifying tha
closure plan was canpleted per this Cooditioo of the permit.
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SECTION I
CLOSURE PLAN, POST~CLOSURE PLAN, AND
FINANCIAL REQUIREMENTS
Revision o
February 26, 1993
This Section describes Singer's conformance to the requirements of 40
CFR §122.25(a)(13), ~264.112 through 115 , §264,178, §264 .197. and
§264.258. This plan identifies all the .steps that will be necessary to
co~letely close the facility at the end of its intended operating life.
A post-closure plan is not required because this is not a disposal
facility and all wastes will be removed at closure,
Singer will maintain an onsite copy of the approved closure plan and
~11 revision~ to the plan until the certification of closure completeness
has been submitted and accepted by the North Carolina Solid and Hazardous
Waste Management Branch . Singer will notify the Branch Head at least 180
days prior to the date final closure activities are expected to begin.
The closure date for of the entire facility will be the year 2003. Upon
completion of closure, Singer will submit to the Branch Head a
certification by both Singer and by a independent registered professional
engineer that the facility has been closed according to the
specifications in the approved closure plan.
7/29/83 I-1 Rev. No . ()
A1-10
1-1 Closure Plan (40 CFR 122.25(a)(l3)]
I-la Closure Performance Standard [40 CFR 264 .111]
Revision O
February 26, 1993
This closure pl an was desi gned to ensure that t~e faci1ity
wil l not require further maintenance and controls, threats to human
health and the environment will be minimized or eliminated, and
escape of hazardous waste, hazardous waste constituents,
contaminated rainfa11. or waste decomposition products to the
ground or surface waters or to the atmosphere will be avoided. If
there is evidence of any spills or leaks, saJTq>1es wi1 1 be taken and
analyzed to determine the extent of contamination in the soil and
if necessary, i n grou ndwater. Any contami nated soi l wi ll be
excavated, removed, and disposed of at a proper disposal faci1ity.
Any contaminated groundwater will be remedied. The following
sections discuss in detail efforts to be made at Singer to satisfy
the cl osure performance standard.
I~lb Final Closure Activities
Secti ons I -ld(2) and I-ld(l) of the closure plan present
procedures for final closure of the Container Storage Area and
incinerator area. If any modificati ons to existi ng facility
equipment, structures, instruments or procedures related to the
management of these two areas of the facility occur, Singer will
revise the closure plan accord1ngly .
At a maximu r~, SOO drums wil l be on hand during normal
operation for the life of the facility. Section l-lc of the
closure plan describes the maxi~Jm inventory of wastes at the
3/28/84 I -2 Rev. No. l
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Revision 0
February 2s. 1993
time of closure. Singer will dispose of its wastes in the incinerator
or remove them from the site via an EPA approved transporter to an EPA
approved TSD facility.
I-le Maximum Waste Inventory
At time of closure, a physical inventory of hazardous waste a-
waiting incineration will be taken. The time to conduct the waste in-
ventory should be minimal since the characteristics of wastes generated
by the facility are solely dependent upon the products used in finishing
operations, which do not vary significantly over time.
The maximum drum storage capacity is 500.
I-ld Inventory Re.moval and Disposal or Decontamination of £quipment
The following step6 will be taken to remove, dispose of , and/or
decontaminate facility equipment ;
03/09/88
l . All solid hazardous waste 'I-Till be loaded into the incinerator
at normal loading sites. Nonhazardous water-wash stain will
be pumped through the incineration system as during normal
operations. This will treat all of the hazardous waste gen-
erated and leave residual ash in the bottoro of the incinerator.
2. The incinerator will be shut down.
3. Aftitr cooling, all ash will .be cleaned o'ut of the incinerator.
4. The ash will be disposed of as a nontoxic, nonhazardous waste
at a local sanitary landfill. Not e that the ash has been
analyzed by an independent testing laboratory and found to
be nontoxic (See Section C).
5. The incinerator will be decommissioned by removing its air
compressor, shutting off its g~s supply, and disconnecting
its power supply. Representative samples of the incinerator
I -3
A1-12
R.ev. No. 2
·'9
6.
7.
Revision 0
February 26, i 993
refractory will be taken for analysis as outlined in
No. 9 below. All other incinerator parts will be de-
contaminated by steam cleaning with collection of water
run-off for proper disposal, following a sample analysis
as in No. 9 below.
If for sorne reason the incinerator is not operable irnd
cannot be readily made operable, the wast:es will be shipped
to an off-site TSO facility, in lieu of Steps 1-4 above.
The .t.nterior walls and ceiling of the Incinerator Build-
ing, and the floor (pad) on which the incinerator sets,
liquid feed tank, and proposed Hopper/Conveyor Feed Tank,
will be decontaminated by double washing with a steam
cleaning unit. The rinse water will be collected for
analysis and proper disposal as in No. 9 beloo.
8. The proposed Hopper/Conveyor Feed Tank Wil l likewise be
decontaminated with a double wash by a steam cleaner, the
rinseate collected for analysis and proper disposal per
No. 9 below.
9. Sample Collection & Disposal
a. All sampling ~ill be done by a recognized envir.on-
mental engineering firni, with analyses ac a Branch
Certified Lab. A closure waste analysis plan will
be submitted to the Br.anch for approval prior to
completion. Following completion, a copy of the
analyses results will be forwarded to the Branch
for confirmation of decontamination. Sample col.lee-
tion procedures will essentially follow Section C
and Appendix A with regard to sample hand ling a1\cl
shipping.
':)r,i• ,.,,
A1 -13
OJ/09/88
Revision O
February 26, 1993
b. All samples will be analy4ed for the identical para-
meters found in Table C tI. Contaminate levels will
be compared to background levels from soil at least
1000' in distance upgradient and upwind from the in-
cinerator building, from unused steam cleaning water,
and from unused wipe sample cloth.
c . At leas e eight (8) soil samples will be taken around
the Incinerator Building and in the Container Storage
Area. Bore holes will be advanced with a hollow-stem
auger with a push-through end plug. The sampl ing de-
vice will be a specifically modified Diedrich 3-inch
OD split barrell sampler with special aluminum liners,
which become the sample container. (Hence, soil
samples are not exposed to atmosphere.)
d. Using a Coliwesa Sa~pler (Appendix A, Figure L) as pre-
scribed in Appendix A, Part B "Sample Collection -
Liquids, '1 obtain a representaive sample from each 55
gal. drum of rinseate material collecced from steam
cleaning.
e. Collect at least four (4) representative samples of
t he i ncinerator refractory material simply by break~
ing chunks inco a plasc1c sample bag.
f. At least twelve (12) representative "wipe" samples
of che interior Incinerator Building and pad shall
also be taken. A wipe sample kit consists of latex
plastic gloves, 2" diameter inert cloth wipe pads,
and plastic lock-seal bags.
Rev. No. 2
A1-14
Revision O
February 26, 1993
10. Following results of sampling, disposal of the rinseate
water from steam cleani ng can be accomplished as required
by contaminate findings , in accordance ~1th all EPA regula-
tions. Remedial action , if required by soil or building
contamination findings, can be designated by the extent
and level of contamination.
If consistituenc concentrations are det ected at levels requiring
further evaluation, as established through the Branch or other appropri-
ate soil clean-up action levels, remedial clean-up action or more exten-
eive investigation followed by remediation may be necessary.
If more soil investigation is needed, it will be done according to
the sa.rne methods described in 9(c) above to the extent necessary co deline-
nate the lateral and vertical extent of organic ·chemicals in the soil and
design a remedial alternative. Remedial alternatives for soil clean-up
generally consists of one or a combination of 1) removal and disposal 2}
in-situ soil-gas venting and treatment 3) bioremediation 4) excavation,
on-site treatment, and replacement.
If soil sampling analyses indicate groundwater may have been affected
by organic chemicals in the soil, a t least three monitoring wells will be
installed and developed according to established procedures, which will be
delineated if needed. Three wells are needed to define the groundwater
flow direction and gradient.
lf it were to become apparent that groundwater remediation is re-
quired, a clean-vp program would be proposed to the Branch and implemented
according Co an approved plan.
I -ld(l) Closure of Containers
The empty drum containers will be sold either to a drum
reclaimer or back to the supplier of the drum.
03/09/88 I-4b Rev . Xo. 2
A1-15
I-ld (2) Closure of Tanks
See Section I-ld, Icems 1 through 10.
I-ld (3) Closure of Waste Pile
Not Applicabl e
1-ld (4) Cl osure of Surface Impoundments
Not Applicable
I-ld(S) Closure of Incinerators
See Section l -ld, Items l through 10
I-le Schedule ror Closure
Revision O
February 26, 1993
Within ninety (90) days after receiving the final volume of
hazardous waste, final closure will be initiated. Closure will be
completed within 180 days after receiving the final volume of hazardous
waste. All financial calculations are based on a c l osure date in the
year 2003. Final closure will be supervised by qualified operators
within the company and certified by a professional engineer. A closure
schedule is shown in Figure l-!.
1-lf Extensions for Closure Time
Singer does not expect to require an extension for closure time.
03/09/88 1-5 Rev. No. 2
A 1-16
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1-2 Post-closure Plans [40 CFR l22 .25(a)(13))
Revision O
February 26, 1993
Post-closure care will not be neederl for this facility because it
is not a disposal facility.
7/29/83 I-6 ~ev. No. 0
A1-18
Revision O
February 26, 1993
1-3 Not ice in Peed and Notice to Local land Authority (40 CFR i22.?.5(a ) m
Notation is not necessary in the deed informing potential
purchasers of restrictions associated with a disposal facility because
Singer i~ not a hazardous waste disposal facility.
7/29/83 1-7 Rev. No. 0
A1-19
Revision O
February 26, 1993
I -4 CLOSURE COST £ST1!1ATE (40 CFR 1:?:?.25(.1) (15) ,rnd 2i.~.1.;~)
The closure cost information presented is submitted according to the re-
quirements of 40 CPR 122.25(a) (15) and 264.142 6 143.
An estimated $142,000 will be necessary to close the Singer furniture
Company (SFC) waste storage and treatment facilities (WSTF). The estimate
is conservatj.vely based on off-site disposal of all of the m<!X:i.mUtll in storage.
The closure costs 111.ll be structui:ed as follows:
ITEM QUANTITY UNIT $'s LABOR $'s TOTAL $' s
lnventory Disposal 500 Drums 250 N/A 125,000
Clean-Up so Man-hours N/A 10 Han-hours 600
Clean-up Equipment 25 Hours 50/Hrs. XIA 1,250
P. E. Certification Lurop Sum 500 N/A 500
Soil/Incinerator Samp-
ling, Decontamination
6 Disposal N/A N/A N/A 10,000
Contingency N/A N/A N/A 4,650
142,000
This closure cost estimate will be kept on file at the SFC xSTf during its
operat!ng life. This co~plies with 40 CFR l42(d). It will be revised whenever
a change in the closure ?lan affects the cost of cl osure. The closure cost e$ti-
mate will be adjusted a~~ually from the date of original develop::IBnt co reflect
ch8nges brought about by inflation. The Department of Commerce 's Annual Implicit
Price Deflator for Gross National Pro4uct (*) will be used to ;:ia~e this adjustment.
04/22/91 r-s Rev. No. S
A1-20
Revision o
February 26, 1993
1-5 Financial Assurance Mechanism for Closure (40 CFR Sections
122.25(a) (1), 264.143, and 264 .1502
I-Sa Closure Trust Fund
Not Applicable
I-Sb Surety Bond
Not Applicable
I-Sc Closure Letter of Credit
Not Applicable
I-Sd Closure Insurance
Not Applicable
I-Se Financial Test and Corporate Guarantee for Closure
Singer has obtained the use of the financial test method to
demonstrate financial responsibility for closure as specified
in 40 CFR 264.143(f).
I-Sf Combinations
Not Applicable
03/09/88 I-9 Rev . No. l
A1-21
Revision 0
February 26, 1993
I-6 Post-Closure Cost EstiMate [40 CFR Sections 122.25(a)(lfi) and
264.144)
Since all wastes will be destroyerl hy lncineration on-site or sent
to an off-site TSO facility, there will be no post-closure activities or
costs.
7/29/P.3 l -10 Rev. No. 0
A1-22
Revision O
February 26, 1993
1-7 Financial Assurance Mechanism for Post-Closure [40 CFR Sections
122.25{s)(16) and 264.14~1
Since all wastes will be incinerated on-site or sent to an offsite i
TSO facility, there will oe no post-closure activities or costs.
I-8 Liability Insurance [40 CFR Sections 122.25(a)(l7) and 264.147]
I-Sa Sudden Insurance [40 CFR Sections 264.147(a), 264.lSl(i),
and 264.15l(j)
Singer meets the financial test criteria of 40 CFR
264.147(f)(f), therefore, sudden insurance is not required.
l-8b Nonsudden Insurance [40 CFR 264.147(b), 246.15l(i), and
264.15l(j)]
Singer is not a disposal facility, therefore no liability
insurance is required for a non-sudden accidental occurrence.
I-8c Financial Test [40 CFR 264.147(f) and 264.15l(j))
Singer meets the financial test criteria of 40 CFR 264.147
( f )( i ) . The fo 11 owing i terns appear 1n Append1 x E in accordance
with §264 .147(f )(3):
1. A letter signed by Singer's chief financial office that is
worded as specified in §264.151(9).
2. A copy of the independent certified public accountant 's report
on examination of Singer's financial statement for the latest
completed fiscal year,
3. A special report from Singer's independent certified public
accountant to Sioyer stating that:
3/28/84 I-ll Rev. No. l
Ai -23
·<9
Revision 0
February 26, 1993
a. He has compared the data which the letter from the chief
ffnancial officer specifies as having been derived fro~ the
independently audited, year-end financial statements for
the latest fiscal year with the amounts in such financial
statements; and
b. In connect ion with that procedure, no riatters came to his
attention which have caused hi~ to believe that the
specified dates should be adjusted.
I-8d Variance Procedures [40 CFR Section 2n4.147(c)]
Singer does not request a reduction of liahility amounts.
I-Se Adjustment Procedures [40 CFR Section 264.147(d )J
Updated Financial Test Information will be sub~itted
annually in accordance with &264 .147(f)(5).
7/29/83 1-12 Rev . No. 0
A1 -24
Revision O
February 26, 1993
1-9 State Assurnetion of Responsibility [40 CFR 264.150]
S1nger does not request state assumption of legal or financial
responsibiliti es .
7/29/83 I-13 Rev . No. 0
A1 -25
APPENDIX 2
Revision 1
April 9, 1993
.. \ ...
APRIL 9, 1993 MODIFIED PAGES OF PERMIT
(ONLY PAGES WITH REVISIONS HAVE BEEN INCLUDED. REVISIONS ARE NOTED
WITH BOLD LETTERS.)
A2·i
Revision 0
February 26, 1993
F. oo::;UM!NI'S TO 1£ WJNrAINE0 AT FACILTIY SITE
The Permittee shall maintain at the facility, until closure is completed
and certified by an independent registered professional engineer, the
fullowing doo.mients and amenciDents, revisions and nxxlifi.cations to these
docw:oents;
1.
2.
3.
4.
5.
Waste aoalysis pl.so submitted in accordance with 40 CFR 264.13 as
adopt.ed in 10 t-CAC lOF .0032 and pages C-10 throogh C-12 and
Appendix A of the attachirent.
Personnel training doCl.ltlleots and records stbmitted in accordance
with 40 CFR 264. lG(d) as e.dopted in l.0 ID\C lOF .0032 and pages H-1
throogh H-21 and Appeodix B of the att.achmmt.
Contingency plan submitted in accordance with 40 CFR 264.53(a) as
adopted in 10 1'CAC lOF .0032 Md pages G-1 through G-45 and Appendix
C of tho! attach:oent.
Closure plan submitted in accordance with 40 CFR 264.112(a) as adopted
in 10 NCAC 10F .0032 and pages 1-1 through 1-28 and Appendix E of the
attachment.
Cost estimate for facility closure submitted in accordance with 40 CFR
264.142(d) as adopted in 10 NCAC 10F .0032 and Section 1-6 on page 1-
26 of the attachment.
6. ~rating record required by 40 CFR 264 . 73 as adopted in 10 N::AC
lOF .0032, and pages C-11, F-4 thrwghF-7, F-15 thra.ighF-20, G-37
through G-39, H-21, Appendix B of the attachialt and Condition
I. D. 9. of this {:E!nnit.
7. Inspection scredules developed in accordance with 40 CFR. 264. JS (b)
as e.dopted in 10 MC lOF .0032 and pages F-4 t:hra.igh F-7, F-15
through F-20 and Appendix B of the attactmmt.
All amendments, revisions and modifications to any plan or cost estimates
required by this permit shall be submitted to the Secretary of the Department of
Environment, Health, and Natural Resources or his designee for approval and
permit modification.
G. ANN.JAL RE.FOR!'
'Ihe Pemittee shall prepare and submit an annual rep:>rt by MBLch 1 of each
year in .accordance with 10 N::AC lOF .0037. '!'he report shall include, in
accordance wi.th 40 CFR 264 . 75 as adopted in 10 N::AC lOF . 0032 , the £0 l low:ing
infunnation fur facility activities during the previrus calend.gr year:
l. 'Ihe EPA identification nuo:ber, n.e.roa, and address of the facility;
8
Al-3
A2·3
·~
2.
3.
4.
Revision 1
April 9, 1993
explosion, or release of hazardcuS waste or ca:istit:uents ....trl.ch · .,.
threat:a:ts or oould thrnateo human health or the envi.rootle:l.t as · ·
-r:equire:l by 40 CFR 264 .56 as acbpted in 10 N::A.C lOF .0032. All or
part of the contingency plan sh$ll be impleaent.ed for both major and
minor incide1ts. -
Copies of Plan. The Pennittee shall comply with tre requirements of
40 CFR 264.53 as adopted in 10 N:AC lOF .0032.
Aaendme.nts to Plan. The Permittee shall revi.e~ and i.nmed:i.ately aman9, if necessazy, the contingency plan, in accordance with 40 CFR
264.'4 as acbpted in 10 OCAC lCF .0032. Singer 1IJJSt submit
notification and an amended cootingEllcy plan thirty (30) days prior
to Plant U33 closure.
fllersericy Coordinator. The Permittee shall o:>mply with the
re:iwreroents of 40 CFR 264.55 as adopted in 10 N:'AC lOF .0032,
c::mcern:ing tre eirergency coordinator.
N. Manifest System. 'The Permittee shall romply with the m!ll'lifest
requireannts 0£ 40 CFR 264. 71, 264. 72, and 264. 76 as adopted in 10 ~C
lOF .0032.
0. Remrdkeeping and Reporting.
1. 9?erating Rerord. 'Ihe Permittee shall maintain a written operating
'reooid a.t the hicility in accordance with 40 CFR 264.73(a), (b)(l),
(2), (3), (4), (5), (6), (7) (off-site only), (8), and (9) as
adopted in 10 N.:!AC lOF .0032, and as described oo pages C-11, F-4
through F-7 , F-15 through F-20, G-37 thro.igh G-39, H-21, Appendix B
of the attachment and Cooditioo I.D. 9. of this peraiit.
2 . Amual Report. The Peonittee shall comply with ere annual report
requirements of 40 CFR 264. 75 as adopted in 10 N:::AC lOF .0032 and
10 l'CAC lOF .0037.
P. Closure.
1. Performance Standard. The Perminee shall close the facility In accordance with the
closure plan as described on pages 1-1 through 1-24 of the attachment and as required in
4-0 CFR 264.111 as adopted In 15A NCAC 13A.
2. Amendment to Closure Plan. The Permlttee shall amend the closure plan In accordance
with 40 CFR 264.112(b) as adopted in 15A NCAC 13A .009 whenever necessary.
3. Notification of Closure. The Permittee shall notify the Secretary of the Department of
Human Resources or his deslgnee at least forty-flve (45) days prior to the date he
expects to begin closure.
13
A1-4
A2-4
4.
Revision O
February 26, 1993
Time Allowed For Closure. Within 90 days after receiving the final volume
of hazardous waste, the Permittee shall treat or remove from site all
hazardous waste in accordance with the schedule specified in the closure
plan. After receiving the final volume of hazardous waste, the Permittee
shall complete closure activities in accordance with the schedule specified
in the closure plan on page 1-23 and Figure 1·5.1 of the attachment.
5. . Disposal or Decontamination of Equipment The Permittee shall comply
with the requirements of 40 CFR 264.114 as adopted in 15A NCAC 13A
.0009. Singer must submit all analysis results.
6. Certification of Closure. The Permittee shall certify that the facility has
been cf osed in accordance with the specifications in the closure plan as
required by 40 CFR 264.115 as adopted in 15A NCAC 13A .0009. The
Permittee shall also submit a certification from an independent
professional engineer verifying that the facility was · closed per the
specifications of the closure plan as described on pages 1-1 through 1-14
of the attachment and Conditions Ill.I and V.D.
Q. Cost Estimate for Facility Closure. The Permittee shall comply with the
requirements of 40 CFR 264.142 as adopted in 1 SA NCAC 13A .0009, including
the requirements to adjust and revise the cost estimates, when necess~ry. The
Permittee's approximate closure cost estimate is described on page 1-26 of the
closure plan.
R.
s.
Financial Assurance for Facility Closure. The Pennittee shall demonstrate
continuous compliance with 40 CFR 264.143 as adopted in 15A NCAC 13A
.0009, or where applicable with 40 CFR 264.146, 264.149, 264.150, and 264.151
as adopted in 1 SA NCAC 13A .0009 by providing documentation of financial
assurance In at least the amount of the cost estimates required by permit
Condition 11.Q. and page 1-28 of the attachment.
The financial mechanism used shall be that instrument specified on page 1-28
and Appendix E of the attachment. The Permittee may propose using a different
mechanism by submitting a new financial instrument to the Secretary of the
Department of Human Resources or his designee for approval. The Permittee
must submit this documentation no later than sixty (60) days prior to the effective
date of the proposed change. The existing financial mechanism shall. remain in
force until the change is approved.
Liability Requirements. The Permittee shall comply with the requirements of 40
CFR 264.147 as adopted in 15A NCAC 13A .0009, including the requirements to
have and maintain liability coverage for sudden and accidental occurrences in
the amount of at least $1 million per occurrence with an annual aggregate of at
least $2 million, exclusive of legal defense costs.
The financial mechanism used shall be that instrument specified on page 1-28
and Appendix E of the attachment. The Permittee may propose
14
Al-5
A2-5
2.
3.
Revision 1
April 9, 1993
1he PE~ttee shall not place h.azardoos waste .in an unwashed
rontaine:r t~t previously he~d an incompatible waste or material.
'Ihe Pennittee shall not st.ore a container of hezardoos waste that is
incompatible with any waste or material stored nearby in o~r
ccntainers, piles, opea tanks or surface im~dnau:s unless tre
container is separated from the other matenals by a dike, benn,
wall, en: other device.
H. Rece5.pt of Containers. '!he Pennittee shall receive the shiprent of oi:"itillle:I waste materiBl as described 00 page .0.-3 of the attachment;
however, a mi.ni.zwm. of 10% of the drLJllS shall be fingerprinted as described
on page D-3 of the attachment. Any unacceptable WB$te.s discovered during
this inspection shall be i.nmad:i.etely returned to tre generator.
I. Clofillli!. The Permittee shall follow the closure plan as described in Section I of the attachment
and shall comply with 40 CFR 264.178 as adopted In 15A NCAC 13A .0009. At a minimum, soil
sampling at time of closure shall Include 5 surface samples taken In the container management
area and 5 background surlace samples. Singer must submit a certification from an
independent professional engineer verifying that closure was completed to the specifications of
this Condition of the permit
17
A1·6
A2-6
PART IV -TREATMENT IN TANKS
THIS SECTION HAS BEEN DELETED
18
A1-7
A2-7
Revision O
February 26, 1993