HomeMy WebLinkAbout952485.tiff Qcy.nc C
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CLERK
TO THE En'RD
November 6, 1995
Weld County Commissioners
915 10th Street
Greeley, CO 80631
Dear To Whom It May Concern:
RE: Notification of Class 1 Modification of the Kodak Colorado Division RCRA Part B
Permit
Attached please find a Notice to modify the Kodak Colorado Division(KCD)RCRA Part
B Permit to build a covered loading and unloading truck pit at our Permitted Drum
Storage Facility.
This notice is being mailed to you in accordance with 6CCR-1007-3, Part 100, Section
100.63(a)(1)(ii).
If you have any question regarding this matter, or you would like a copy of the drawing
referenced in the modification, please contact Mr. David C. Andre' (970) 686-4498.
Sincer y,
ezzieepe(4467 .,„
David C. Andre'
Senior Environmental Engineer
Kodak Colorado Division
9952 Eastman Park Drive
Windsor, CO 80551-1510
Attachment
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EASTMAN KODAK COMPANY • WINDSOR,COLORADO 80551
Y
CI
-777a4
September 29, 1995
zio 9 6737s6e
Mr. Gary W. Baughman,PE. /0/33/97
Chief-Facilities Section
Hazardous Materials and Waste Management Division
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80222-1530
Re: Class I Permit Modification General Permit Provisions
Attention: James Hindman
Dear James,
Following the direction given during our phone conversation on September 26, 1995,
Kodak Colorado Division(KCD) is submitting a Class I permit modification to our RCRA
Part B permit. The modification involves constructing a covered loading and unloading
truck pit equipped with secondary containment at our permitted drum storage facility.
This request is consistent with the regulations found in 6CCR 1007-3 Part 100 Section
100.63 Appendix I Classifications of Permit Modifications. Section A of Appendix I
states, Equipment replacement or upgrading with functionally equivalent components(e.a pipes, valves, pumps, conveyors, controls) is a Class I modification. KCD currently has a
truck loading and unloading area. Presently it has no containment or cover. Secondly,
the area does not allow for ground level loading or unloading of delivery trucks. We feel
the proposed modifications,one, constructing a concrete truck pit equipped with a
secondary liner and containment trench, and two, covering this facility fall under the
category of upgrading functionally equivalent components.
The plan for upgrade allows for the containment of 100 gallons of material. Should a spill
of less than 100 gallons that is contained in the truck pit occur, KCD personnel will
immediately contact Plant Protection to coordinate the clean-up. KCD's Plant Protection
Personnel have emergency response training. Should a spill in excess of 100 gallons
occur, KCD personnel will immediately call 911 and Plant Protection will employ the
KCD Contingency Plan.. Precipitation found in the trench will be removed following
steps described in KCD's Part B permit application Part 100.41(6)(1)Removal of Liquids
from Containment System[6CCR 1007-3 Part 100.41(b)(1)(i)(E)] dealing with
precipitation.
EASTMAN KODAK COMPANY • 9952 EASTMAN PARK DRIVE • WINDSOR• COLORADO 80551
OKodak
A copy of the engineering drawing for the modification is included. This drawing should
be attached to the drawing labeled Figure 1V located in KCD's Contingency Plan found in
our Part A application and again in Part 100.41(a)(7) of our Part B application. A copy
of the new drawing should also be attached to Figure IV located in Part 100.41(b)(1) of
the Part B application. The last section of the Part B application effected by this
modification is Part 100.41(a)(4)& (5) dealing with inspections. KCD procedure KCD-
6204 deals with how KCD inspects the drum storage facility. The procedure was
modified to included inspection of the trench in the truck pit. A copy of the modified
procedure is included and should replace the copy found in the previously mentioned
section.
KCD feels this modification is a significant improvement to they way we currently perform
loading and unloading operations at our drum storage facility. This modification reduces
risk to our employees along with reducing risk to the environment. KCD will begin
construction shortly after we have received confirmation the Colorado Department of
Public Health and Environment has received this letter. Also, in compliance with section
100.63(a)(1)(ii), KCD will send copies of this Class I permit modification to all persons
on the facility mailing list. Please contact me if you need additional information.
Sin ly,
c de..gs4
David C. Andre'
Senior Environmental Engineer
Kodak Colorado Division
9952 Eastman Park Drive
Windsor, CO 80551-1510 -
Attachments
Engineering Drawing
Procedure KCD-6204
EASTMAN KODAK COMPANY • 9952 EASTMAN PARK DRIVE • WINDSOR, COLORADO 80551
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