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Waste Programs Division: Veolia ES Technical Solutions, LLC (VES) Waste Storage Facility

Veolia ES Technical Solutions, LLC (VES) Waste Storage Facility
EPA ID No: AZ0 000 337 360

Facility History and Description

Veolia ES Technical Solutions, L.L.C. (VES) is located at 5736 W. Jefferson Street (St) in Phoenix, Arizona. Prior to 1984, the property was agricultural land. Between 1984 and 1986, the property was developed as the Westgate Industrial Center, and the four on-site buildings were constructed. LIC Partnership, an Arizona general partnership, owned the property until 1994, when the property was acquired by the Jewel Investment Company, an Arizona general partnership. The buildings were rented to various tenants between 1988 and 1991. Two paint booths and a drum storage area were associated with these tenants. In 1991, Salesco Systems USA Inc. - AZ (Salesco) began operations in one of the buildings. Beginning in 1991, Salesco processed polychlorinated biphenyl (PCB) and non-PCB wastes. By 1994, Salesco expanded its operations into all four buildings and expanded operations to include recycling of mercury-containing lamps. In 1997, Salesco expanded its operation to include retorting of mercury-contaminated wastes to recover elemental mercury for reuse. Since 2000, Onyx Environmental Services, L.L.C. (OES) operated the Facility. OES’s operations are similar to those conducted by Salesco. On July 1, 2006, OES changed its legal name to Veolia ES Technical Solutions, L.L.C. This was a name change only; the legal entity which leases and operates the facility did not change. The property owner is still Jewel Investment Company.

The global position of the facility is approximately 33 degrees, 26 minutes, 47 seconds north latitude and 112 degrees, 11 minutes, 05 seconds west longitude. The facility is located on the northeast corner of the intersection of West Jefferson St and North 59th Avenue (Ave) in Phoenix, Arizona. The site covers approximately 2.67 acres and sits approximately 250 feet (ft) west of the intersection. It is rectangular in shape with its longer boundary extending eastward from 59th Ave approximately 375 ft along West Jefferson St. The shorter, north-south boundary extends approximately 280 ft northward from West Jefferson St.

VES is currently operated as a hazardous waste storage facility under an Arizona Hazardous Waste Management Act (AHWMA) permit (Permit). VES stores and recycles spent fluorescent and high intensity discharge (HID) lamps, mercury containing manufactured articles (MCMA), batteries, inorganic mercury compounds, dental amalgams, clean up articles, personal protective equipment (PPE), gas regulators, and lab packs. They also store ignitable wastes that meet the definition of oxidizer and mercury cyanide wastes that are reactive. The mercury recycling processes are exempt from the permitting requirements pursuant to 40 Code of Federal Regulations (CFR) § 261.6(c)(1). VES also accepts PCB wastes, which are managed under an Environmental Protection Agency (EPA) Toxic Substance Control Act (TSCA) PCB Commercial Storage Permit. Wastes generated at the facility are segregated, consolidated, and shipped for recycling, treatment and/or disposal.

Waste Management

VES receives the materials in boxes, drums and pallets meeting United States Department of Transportation guidelines (US DOT) from off-site sources, including small quantity generators and Universal Waste handlers. The containers and pallets are stored in three designated storage areas in accordance with the Permit. Lamps are disassembled in a manual and/or automated disassembly process creating recyclable metal (end caps), cullet (glass), and mercury containing phosphor powder. Phosphor powder is currently shipped off-site as a hazardous waste to a VES sister facility for retort and recycling. The metal and glass from lamps are periodically sampled and analyzed for contamination before transporting them off-site for recycling, reuse, or disposal. MCMA are disassembled and liquid mercury is recovered directly from the devices or through the retort process. Remaining metal and parts that can be retorted are reclaimed. VES also has an M-4 process, which includes precipitation and a filter press to recover mercury from liquid compounds.

Waste management activities performed at VES under the Permit include:

  • Container storage areas - VES has three container storage areas: Storage Area 1, Storage Area 2, and Storage Area 3. Storage Area 1 is located within a detached shed along the back boundary of the property. Storage Areas 2 and 3 are located within main facility Building #1. These areas may store hazardous or non-hazardous wastes;
  • Loading Docks – There are four truck wells associated with loading docks capable of staging waste during the loading and unloading process during operating hours. One is primarily used for unloading mercury materials and waste and is located to the east of Building #2;
  • Staging area - The staging area receives and prepares materials for off-site shipment. Upon review and inspection of incoming mercury-related materials, they are moved to the processing area or one of the storage areas.

See Also:

Mercury Recycling Environmental Controls

Although the mercury recycling process itself does not require a permit, environmental controls are required because of the toxicity of mercury. Therefore, in addition to hazardous waste storage requirements, the Permit includes the following controls associated with handling the lamps during processing to protect human health and the environment pursuant to the Omnibus provision, Arizona Administrative Code (A.A.C.) R18-8-270.A (40 CFR § 270.32(b)(2)).

  • All mercury containing items are stored within a secure container and properly stored within a building. If lamps are broken in shipment, particulates which may work their way out of shipping containers are readily addressed by properly cleaning the areas with appropriate response equipment.
  • Shipping containers are opened in an exhausted (negative pressure) space to minimize release to the environment and worker exposure. All persons working within the exhausted enclosure wear PPE appropriate to the tasks being performed and the associated hazards present.
  • A portable mercury vapor analyzer is used to monitor mercury vapor concentrations in the air throughout the work place on a daily basis.
  • Air exhausted from the crusher, separator, and the dust collector is treated with carbon filters to remove any mercury in the vapor phase. A portable mercury vapor analyzer is used to monitor mercury vapor concentrations at the carbon filters to ensure mercury concentrations in the exhaust fall below required action levels set by Maricopa County and to determine when the carbon requires replacement.
Additionally, air exhausted from the disassembly, retort, and M-4 processes is treated with carbon filters prior to release to the environment.

Dry Wells at VES

A total of 11 active and inactive drywells are located on the facility property. Seven of the Class V drywells were sealed shut to prevent any hazardous wastes or hazardous waste constituents from entering the wells in accordance with the Arizona Department of Environmental Quality’s (ADEQ’s) Aquifer Protection Permit Program. Three of the drywells are currently active. They receive and drain storm water runoff from the south (non-industrial) side of the facility which is an employee parking area. Berms located to the east of Building 4, between Buildings 2 and 3, and to the west of Building 1 prevent process area storm water from entering these drywells. The drainage pattern on the north side directs storm water runoff to collect and evaporate on the asphalt-paved storage areas of the facility.

Hazardous Waste Permit

The AHWMA Permit was issued to VES on December 12, 2006 and is signed by the Director of ADEQ’s Waste Programs Division. It includes all permit conditions deemed necessary to protect human health and the environment. All permit conditions are based on the permit application, with supplements and updates submitted by the applicant on or before July 2, 2006.

The term for the Permit is ten years - it expires on December 12, 2016.

Contents of the Permit:

  • Part I - General permit conditions required by A.A.C. R18-8-270 A and L (40 CFR § 270.30).
  • Part II - General facility conditions required by A.A.C. R18-8-264.A and A.A.C. R18-8-270.A, M, N, and O (40 CFR § 270.32).
  • Part III - Specific conditions related to hazardous waste container storage and container management required by A.A.C. R18-8-264.A (40 CFR § 264 Subpart I).
  • Part IV - Specific conditions regarding corrective action for solid waste management units (SWMUs), also referred to as the Corrective Action Schedule of Compliance (CASOC). Corrective action is authorized by the Arizona Revised Statutes § 49-922.B and Section 3004(u) of the federal Resource Conservation and Recovery Act, as amended by the Hazardous and Solid Waste Amendments. The regulatory basis for the corrective action can be found in A.A.C. R18-8-264.A (40 CFR § 264.101) and A.A.C. R18-8-270.A (40 CFR § 270.33).

Permit Attachments:
  • Attachment A - Detailed description of the VES facility.
  • Attachment B - Description of procedures to prevent hazards.
  • Attachment C - Description of the waste characteristics and waste management.
  • Attachment D - Description of the inspection schedule.
  • Attachment E - Contingency Plan.
  • Attachment F - Description of the facility training plan.
  • Attachment G - Map of SWMUs and Dry Wells.
  • Attachment H - Closure Plan, Closure Cost Estimate, and Financial Assurance documentation.
  • Attachment I - Most recent Arizona administrative code for hazardous waste at the time the Permit was issued.
  • Attachment J – Most recent edition of 49 CFR § 173.152, rules for packaging and shipping oxidizers, at the time the Permit was issued.

Upon Permit final decision, ADEQ issued a Response to Comments Summary. The summary responded to all significant comments submitted by the applicant and the general public during the public comment period.

CASOC - Site Assessment

A Site Assessment was conducted pursuant to Conditions C and L in Part IV of the Permit. The Site Assessment addressed the potential historic release of hazardous materials to the soil and groundwater resulting from activities conducted within SWMU 8 and area of concern (AOC) 1 identified in Permit Part IV.B. According to the Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA):

  • SWMU 8 - Drums of waste oil and/or lubricant, broken lamps, retort residue, mercury debris, PPE and MCMA were stored.
  • AOC 1 - A former occupant of Building 1, Graphic Technical Services, applied for an installation permit for a paint booth to be located north of Building 1 in 1987. No information was available describing the actual paint booth activities or the types and amounts of paint used in the paint booth.
VES submitted the initial version of the Site Assessment Plan on January 27, 2007. A revised version of the Site Assessment Plan was approved by ADEQ on November 13, 2007 and soil sampling activities commenced at the facility on March 17, 2008. Soil samples were collected at SWMU 8 and AOC 1 in accordance with the plan down to 14 ft below ground surface (bgs). Based on historical activities, the samples were analyzed for eight RCRA metals (arsenic, barium, cadmium, chromium, lead, selenium, silver and mercury) by EPA Method 6010B/7471A and volatile organic compounds by EPA Method 8260B. Samples collected at SWMU 8 were also tested for polynuclear aromatic hydrocarbons and semi-volatile organic compounds by EPA Method 8270.

Arsenic was reported in four samples at AOC 1 at concentrations exceeding the corresponding Arizona residential and non-residential soil remediation level (R- and NR-SRL) of 10 milligrams per kilogram (mg/Kg). Chromium was reported in all samples at concentrations below the corresponding R-SRL for Chromium III and below the corresponding NR-SRL for Chromium VI. All other constituents, including mercury and tetrachloroethene, were below R-SRLs or not detected at all.

On July 27, 2012, ADEQ acknowledged VES’s February 2012 Site Assessment Report. Although arsenic and chromium concentrations exceeded the R-SRLs of 10 mg/kg and 30 mg/kg, respectively, ADEQ agreed to have the contamination addressed upon closure of the facility because:
  1. the area is covered with concrete and asphalt with no active dry wells, so contaminant mobility due to infiltration of precipitation would be minimal and humans are protected from the contaminated soil;
  2. arsenic and chromium concentrations are well below the groundwater protection levels (GPLs) of 290 mg/kg and 590 mg/kg, respectively, so there is no threat to ground water; and
  3. the contamination appears to be less than 9 ft bgs, which is well above the ground water level of approximately 120 ft bgs in the vicinity of the facility.
VES subsequently updated the Closure Plan in their Permit to address the historical arsenic and chromium contamination at AOC1 and SWMU 8 upon closure.

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