Consent Decree Appendices | Region 10 | US EPA

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Consent Decree Appendices


APPENDIX 2

Furnace Building and Phos Dock Upgrades


A. Furnace Building Upgrades

1. FMC shall upgrade the wastewater sumps, tanks and piping inside the furnace building to meet the applicable requirements of 40 C.F.R. Part 265, Subpart J by September 30, 1999. These sumps include V-1400, V-2400, V-3400, V-4400, and V-3607 and their associated piping.

2. FMC shall upgrade the V-3600 tank and the pipelines running from the V-3600 tank to any phossy waste disposal ponds by September 30, 1999, in accordance with the requirements of 40 C.F.R. 265, Subpart J.

3. FMC shall complete the following upgrades by September 30, 1999:


a. The emergency back-up line from the sump T-1415 to V-3600 will be upgraded to meet the requirements of 40 C.F.R. Part 265 Subpart J.

b. FMC shall cease use of the east launder.

c. To prevent any overflows of phossy water from the furnace phosphorus product sumps to the main wastewater collection sumps, FMC shall install a retaining wall of no less than six (6) inches around the product sump areas. Excess phossy water from the product sumps shall be routed back into the product sump or to the north launder for phos dock reprocessing and recycle.

d. FMC shall install kick plates around the precipitators, furnace, and condenser to direct floor washing into floor drains.

e. FMC shall re-route the secondary condenser T-4 sump blowdown line to deliver water to the furnace northeast sump for recycle at the phos dock.

4. FMC shall immediately commence upgrades of the furnace building waste handling systems, including wastewater sumps, tank and piping, to meet applicable RCRA requirements. FMC will complete these upgrades by September 30 , 1999. The furnace building upgrades shall include the following:

a. Furnace Building Wastewater Collection - Pan and Sump Upgrades (Sumps V-1400, V-2400, V-3400, V-4400, and V-3607). FMC shall install primary and secondary containment, consisting of a double-walled pan with leak detection, on the 0’ level of the furnace building below each of the slurry pots. Each pan will drain to one of the main wastewater collection sumps. Each main wastewater collection sump shall be upgraded by adding a double-walled stainless steel liner and leak detection. This pan and upgraded sump configuration shall be configured to allow for the collection of bottom drops, precipitator washes, slurry pot overflows, and pump packing leaks.

b. Medusa Upgrades. FMC will install welded piping to route all Medusa funnels directly to the upgraded main wastewater collection sumps (V-1400, V-2400, V-3400, and V-4400). FMC shall install drip pans around the Medusa fan bases, and these drip pans will drain directly to the funnels. This and all other piping that conveys hazardous waste into the funnels shall be welded or provided with secondary containment.

c. V-3700 Tank. The tank V-3700 system shall be upgraded to meet the requirements of 40 C.F.R. Part 265, Subpart J.

d. Piping Upgrades. FMC shall upgrade all hazardous wastewater piping entering the V-3600 and V-3700 tanks in accordance with 40 C.F.R. 265, Subpart J, from their origin to the V-3600 and V-3700 tanks as follows:

(i). FMC shall upgrade the Precipitator Slurry Line from the slurry pots to the V-3700 Tank.

(ii). FMC shall upgrade the Sump V-3607 by installing a stainless steel, double-walled sump with leak detection. The line from the sump pumps to V-3600 shall be upgraded by removing flanges and replacing them with welded connections. All backup lines presently routed to this sump shall be eliminated.

(iii). FMC shall upgrade all of the piping from the Wastewater Collection Sumps to the V-3600 tank.

(iv). FMC shall upgrade the Furnace Slurry Backup Line from the slurry pots to the V-3600 tank.

(v). FMC shall eliminate the two 3” emergency backup lines between the phos dock and the V-3600 tank.

(vi). The emergency backup line from the new V-3800 tank to the V-3600 tank shall conform to the requirements of 40 C.F.R. Part 265, Subpart J.

(vii). FMC shall eliminate the Medusa Scrubber liquor line to the V-3600 tank.
B. Phos Dock Upgrades

1. FMC shall upgrade the wastewater tanks and wastewater piping inside and outside of the phos dock area to meet the applicable requirements of 40 C.F.R. Part 265, Subpart J by September 30, 1999.

2. FMC shall complete the following upgrades by not later than September 30 , 1999:

a. FMC shall install a new clarifier feed surge tank to improve the ability of the phos dock to recycle water and recover P4. This tank shall be designed and constructed to provide surge capacity, prior to clarification, for increased recycle water flows from the furnace building and phos dock.

b. FMC shall direct the recycle water from the rail car collection system to the clarifier feed surge tank.

c. FMC shall install pumps in the phos dock tank containment areas to pump collected water to the clarifier feed surge tank.

d. The dock northeast sump shall be used exclusively for recycle of process water. This sump shall become an extension of the intercept sump, pumping heavy material to the multicone feed tank and light material to the clarifier surge tank. Pad water will continue to enter this sump and be recycled to the clarifier surge tank.
3. FMC shall initiate upgrades immediately to the wastewater tanks and wastewater piping in the phos dock area to meet RCRA requirements. FMC shall complete these upgrades by September 30, 1999. The upgrades will consist of the following:

a. New Wastewater Collection Tank. FMC shall cease using and close the existing north solids tank and install a new wastewater collection tank to be known as “the V-3800 tank.” FMC shall route all phos dock waste streams to the V-3800 tank. Wastewater from V-3800 shall be pumped directly to the ponds or to the V-3600 tank. FMC shall design and construct the V-3800 tank and the piping from V-3800 to the ponds or to V-3600 to meet the requirements of 40 C.F.R. 265, Subpart J.

b. Piping Upgrades. FMC shall upgrade wastewater lines entering the V-3800 tank in accordance with 40 C.F.R. 265, Subpart J, from their origin to the V-3800 tank as follows:


(i). FMC shall upgrade the line from the 3-way hydroclone strainer dump valve to the V-3800 tank.

(ii). FMC shall upgrade the line from the overflow discharge of the multicone unit to the V-3800 tank.

(iii). FMC shall upgrade the line from the 3-way Railcar Cleaning strainer dump valve to the V-3800 tank.

(iv). FMC shall upgrade the scrubber recirculation tank blowdown line from the scrubber recirculation tank to the V-3800 tank. FMC shall install a spare blowdown pump at this unit.

(v). FMC shall install a blowdown line to the recycle pump discharge. This line shall be designed and constructed to blow down excess clarified water to the V-3800 tank.

(vi). FMC shall direct the emergency overflow on the new clarifier feed surge tank to the V-3800 tank.
C. General Operating Requirements and Inspections

1. As FMC completes installation of each upgrade described in Paragraphs A.4 and B.3 above, FMC shall operate and inspect the wastewater tanks, sumps and piping in the inside and outside of the furnace building and phos dock areas in accordance with 40 C.F.R. 265.194 and 40 C.F.R. 265.195.

2. Any evidence of releases of elemental phosphorus observed during the upgrades shall be documented and reported to EPA within 5 working days.

D. Special Requirements of Ignitable or Reactive Wastes

1. Upon the startup of the LDR Treatment System, but not later than May 1, 2002, FMC shall directly convey phossy wastes from tanks to the LDR Treatment System for immediate treatment in accordance with paragraph 15 of the Compliance Schedule (Attachment A) to comply with 40 C.F.R. 265.198.


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URL: http://yosemite.epa.gov/R10/owcm.nsf/enforce/Appendix+2

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