Consent Decree Appendices | Region 10 | US EPA

Jump to main content.


Consent Decree Appendices


APPENDIX 1


INFORMATION TO BE SUBMITTED ON THE LDR TREATMENT
AND OFF-GAS SYSTEM

For the LDR Treatment and Off-gas Treatment System
(Unit and Overall System Basis)

A. Design Information (for the documents due to be submitted to EPA on or before March 31, 2000, EPA will accept information based on at least 20% complete engineering design, however, FMC shall provide updated engineering design information to EPA upon request).

Engineering drawings and specifications
Piping and Instrumentation Diagrams

B. Operating Plan

Standard Operating Procedures (for the documents due to be submitted to EPA on or before March 31, 2000, EPA will accept information based on at least 20% complete engineering design, however, FMC shall provide updated engineering design information to EPA upon request).

Critical Operating Parameters (i.e., temperature, pressure, flow rates, emission monitoring, etc.)

Automatic Waste Feed Cutoff Limits For Each Parameter including basis for limit set points

(Above supported using engineering calculations, manufacturer specifications and/or operating data.).


C. Documentation of meeting 40 C.F.R. Part 264 Subpart J Standards for New Tanks

D. Documentation of capability of system to meet the more stringent elements of: (1) 40 C.F.R. 264.343 performance standards; or (2) more recent of (a) proposed April 19, 1996 Standards for Hazardous Waste Incinerators, Section 63.1203(b), or (b) final promulgated regulations under that section. Supported using engineering calculations, manufacturer specifications and/or operating data.

E. Documentation of capability to satisfy land disposal restriction treatment requirements, and reduce levels of elemental phosphorus and cyanide in the waste such that phosphine and hydrogen cyanide concentrations do not exceed 0.3 ppm phosphine and 10.0 ppm hydrogen cyanide, that the solids “pass” method 1030, and that treatment is permanent.

F. Consistent with most current EPA risk assessment guidance for hazardous waste combustion facilities, documentation of direct inhalation risks posed by stack emissions either at the stack or at the location of maximum annual and one hour average ground level concentration and at the location of maximum annual and one hour average ground level concentration at the FMC property boundary.

Documentation must include:

Identification of all compounds (including radionuclides) which have potential to be in the stack emissions and projected concentrations of:

Compounds in the wastes
Compounds formed in the treatment process
Compounds formed due to incomplete treatment
Compounds introduced in the treatment process

Risks evaluated must include carcinogenic, noncarcinogenic, and acute risk.

All of the above must be supported using waste analysis, engineering calculations, dispersion modeling, manufacturer specifications and/or operating data.

G. Update and Submittal of interim status plans/procedures/equipment to include:

Waste Analysis Plan

Contingency Plan

Preparedness and Prevention Procedures (for the documents due to be submitted to EPA on or before March 31,2000, EPA will accept information based on at least 20% complete engineering design, however, FMC shall provide updated engineering design information to EPA upon request).

Training Plan

Closure Plan and Cost estimate

Financial Documentation

Inspection Requirements


Local Navigation


URL: http://yosemite.epa.gov/R10/owcm.nsf/enforce/Appendix+1

Jump to main content.