Avogadro

Case Study: Scrap Metal Recycling Industry—PPC Plans

The Consulting Engineering Division of Avogadro Environmental has been selected by a globally known scrap metal recycling plant to prepare facility Pollution Prevention and Control (PPC) plans. This industry leader is a globally known  in the scrap metal recycling industry and processes materials ranging from car and nonferrous scrap metal to plastic and glass recyclables.

As part of this scope of work, the Consulting Engineering Division has visited 16  of their northeastern facilities. Site visits allow professional engineers, project managers and environmental scientists to evaluate the facility location, onsite sources of pollution and environmental setting, along with gaining an understanding of facility operations.

During a site visit oil storage areas, hazardous materials and all corresponding storage containers (tanks and drums) are evaluated for secondary containment, signs of leakage and evidence of recent spills.  Because this facility recycles scrap metal,  management of this process also needs to be taken into consideration during a site visit. Scrap metal piles need to be well managed in order to prevent sediment erosion into storm water. It is important that storm water drainage paths and outfalls are evaluated to ensure that sediment, oils and hazardous materials are not being discharged with the storm water.

In order to gain an understanding of facility operations, onsite equipment is also evaluated. This is especially important for clients who operate heavy, fuel-burning machinery. For all fuel-burning equipment, secondary containment must be identified for equipment fuel leaks.

A meeting with the facility contact is another way to gain a better understanding of facility operations. This gives the Consulting Engineering Division a chance to review onsite procedures, such as fueling, storm water monitoring and spill clean up procedures. It also allows for discussion of BMP implementation, as mandated by the facility’s storm water permit, and the possibility of pollution prevention upgrades.

PPC plans need to be written according to federal and state guidelines with cross references to the federal SPCC regulations. Some clients have acceptable company-developed templates for PPC plans. However, the Consulting Engineering Division is also experienced with developing unique templates for those clients who are new to the PPC program.

Case Study: Audit Checklist

The Consulting Engineering Division of Avogadro Environmental has been working with the same scrap metal recycling organization in developing an internal environmental health and safety audit checklist for their east coast facilities. Because of their global involvement  in scrap metal and recyclable processing, many areas of environmental health and safety regulations needed to be analyzed.

In order to develop such a comprehensive checklist, federal and state environmental health and safety regulations needed to be reviewed, along with their internal facility policies. In order to gain all applicable information, the Consulting Engineering Division obtained all facility permits and engaged in lengthy conversations with various facility contacts to better understand the operations and potential hazards involved with the scrap metal industry. Once the facility’s potential hazards were identified, the Consulting Engineering Division was able to select which federal and state regulations would be incorporated into the checklist.

Within the checklist, all regulations are categorized as either environmental or health and safety. The environmental and health and safety regulations are further broken down to reflect more specific subsets of regulations. For example, some environmental regulation subsets include Fluids Management, Air Quality and Storm Water. Some health and safety subsets include Worker Protection Safety, Fall Protection Safety and Marine Operation Safety.

The audit checklist is organized into an excel spreadsheet. The spreadsheet has different tabs, each of which focuses on one subset of regulations. For example, one tab solely focuses on Fluids Management regulations while another tab focuses on Worker Protection Safety. Within the spreadsheet, each regulation is reformatted as a question and assigned a subject and number ID. These IDs help to further organize each subset of regulations. Each regulatory question is accompanied by a citation and a list of records to review when answering the question. The spreadsheet also allows room for a listing of findings, a description of findings, a listing of corrective actions/action owners and a completion date.

This audit checklist is an organized, user friendly product that allows the employees of SMM to complete a comprehensive internal facility audit of all hazards that could occur while working in the scrap metal industry.

Case Histories for Engine Permitting Projects:

GlaxoSmithKline

Collegeville, PA

In order to complete registration of new emergency generators in association with the existing Title V Operating Permit, Avogadro Environmental completed and submitted an Administrative Amendment Request to PADEP Southeast Office New Source Review Section.

Sims Hugo Neu

Queens, NYC

Avogadro Environmental prepared a NOx RACT Compliance Plan and Operating Plan for internal combustion sources in accordance with NYSDEC Air Regulations Subpart 227-2.3 (b) and (c) accordingly. The main generator at Hugo Neu Queens Yard is rated at 9,630 HP (6.5 MW). As well, (2) 300 KW Cummins engines, fired on low-sulfur diesel fuel are operated on site. Avogadro Environmental obtained a Variance from the RACT NOx limit for lean burn engines (2.3 grams/BHP-hr) by demonstrating that it is not economically feasible using the methods described in Air Guide 20 (published January 24, 1996). A case specific RACT determination including use of low-sulfur fuel and other strategies implemented to date was utilized.

Avogadro Environmental also prepared a renewal application for Generators at the Queens Yard facility. The application included revising operating hours of the main generator and two backup generators, and inclusion of emission reductions from NOx RACT controls as offsets for the addition of a new 1000 KW Peak Load Cummins Diesel Generator for a new Plastics Recycling Operation on site.

Cummins Power Generation

Warren Hospital
Phillipsburg, NJ

Avogadro Environmental provided assistance to submit an application and obtain an air permit through the Preconstruction Permit Program at NJDEP. Warren Hospital is an existing site in the NJDEP Air Pollution Control Permit Program site. Cummins Power Generation is planning to construct and operate a new 1250 KW natural gas-fired engine as referenced above for Warren Hospital.