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HomeMy WebLinkAbout2023 FedEx Annual Report0444.0074M005.109.LR 200 Summit Drive, Suite 500 ■ Burlington, Massachusetts 01803 ■ +1.781.569.4000 ■ www.rouxinc.com California ■ Illinois ■ Massachusetts ■ New Jersey ■ New York ■ Texas ■ Virginia May 31, 2024 Mr. Carl Lawson, Jr. Town of Yarmouth Health Office 1146 Route 28 South Yarmouth, Massachusetts 02664 Re: 2023 Handing and Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road, West Yarmouth, Massachusetts Dear Mr. Lawson: On behalf of FedEx Express (FedEx), Roux Associates, Inc. (Roux) is submitting this Annual Report for the FedEx facility located at 60 Ansel Hallet Road in West Yarmouth, Massachusetts (the Facility). The report provides a summary of activities associated with the Facility’s industrial wash water system and its disposal of toxic or hazardous materials during the reporting period. The report has been prepared in accordance with the reporting requirements set forth in the Facility’s Handling and Storage of Toxic or Hazardous Materials License and covers the period between January 1, 2023, and December 31, 2023. INDUSTRIAL WASH WATER HOLDING TANK AND PIPING SYSTEM On December 15, 2023, a registered Massachusetts Professional Engineer (PE) from Roux conducted the required annual visual inspection of the holding tank system. The following observations were made during the inspection: • Based on the visual inspection of the trenches, traps, tank sumps, and concrete pads associated with the system, all system appurtenances were in good and working condition (i.e., there was no evidence of cracks or other wear and tear that would suggest a potential risk for leaks or discharges to the subsurface). • There was minor debris (sediment and leaf matter) observed in the trench drains in the sorting area, but there were no indications that the trench drain system was not functioning as designed. • The system alarm panel was in good working condition, and both the visual and audio indicators were functioning properly for each of the three tank sensors. In addition to the above, several housekeeping items were in need of attention, including some areas with chemical drips and sorbent pads with oil that had not been cleaned up, and storage of vehicle parts outside of designated areas. Based on the December 15, 2023, visual inspection of the holding tank system, Roux recommended that: • The trench drains continue to be inspected and cleaned, as necessary. • Mesh guards be installed on the trench drain outlets to mitigate solids from entering the traps and the holding tank. • Housekeeping items be addressed, including the clean-up of chemical drips and sorbent materials and relocation of vehicle parts to designated areas (e.g., away from trench drains). It is Roux’s understanding, based on conversations with FedEx, that the recommendations have been implemented, with the exception of installing mesh guards on the trench drain outlets. Although Roux continues to recommend the installation of mesh guards as a preventative maintenance measure, the system functions properly without them. Mr. Carl Lawson, Jr. May 31, 2024 Page 2 ROUX │ ANNUAL REPORT 0444.0074M005.109.LR In addition to performing the visual inspection, Roux’s PE oversaw testing of the holding tank’s three alarm sensors (high-level, tank interstitial containment, and piping interstitial containment). The sensor testing was conducted by Mass Tank Inspection & Services, as indicated in the attached testing form (Attachment 1). All three sensors were determined to be fully operational. Additionally, FedEx manually tested the leak detection panel weekly during 2023 to ensure that the audible and visual alarms were functional. Panel testing logs for the 2023 reporting year are provided as Attachment 2. Based on both the visual inspections and the alarm sensor testing, Roux’s PE has determined that the wash water system is in good working condition and is not discharging to the environment. FedEx will continue to manually test the leak detection alarm panel in accordance with the Facility’s Handling and Storage of Toxic or Hazardous Materials License and will have the entire holding tank system inspected and the monitoring system tested under the oversight of a PE on an annual basis. The system will next be inspected and tested in 2024. TRAP MAINTENANCE Traps associated with the holding tank system were visually inspected by FedEx personnel on a routine basis (i.e., quarterly) during 2023. In addition, the traps were inspected by Roux’s PE during the December 15, 2023, annual inspection. The traps were in good working condition and did not require any additional maintenance in 2023. REPORTABLE SPILLS According to FedEx, there have been no reportable leaks or spills (i.e., greater than one gallon) of toxic or hazardous materials at the Facility during the reporting period. HAZARDOUS WASTE MANAGEMENT Used oil, antifreeze, aerosol cans, and absorbent pads from vehicle repair activities in the Facility’s maintenance garage were shipped off-site for disposal during the reporting period. No solvent waste was disposed of during the reporting period; solvent remains in use for vehicle parts cleaner. The following table provides a summary of the waste shipments. The associated Monthly Waste Management Operating Logs are provided as Attachment 3. Month Waste Description Quantity Receiving Facility March 2023 Used Oil 64 Gallons Heritage-Crystal Clean, LLC (Rockville, VA) March 2023 Antifreeze 121 Gallons Heritage-Crystal Clean, LLC (Rockville, VA) November 2023 Aerosol Cans 75 Pounds Heritage-Crystal Clean, LLC (Pennsauken, NJ) November 2023 Absorbent Pads 100 Pounds Heritage-Crystal Clean, LLC (Pennsauken, NJ) In addition to the above, based on information provided by FedEx and as summarized in the following table, vehicle wash water was pumped from the Facility’s holding tank system on five occasions in 2023. Up to approximately 1,000 gallons were pumped from the tank during each pumping event, amounting to approximately 4,050 gallons of vehicle wash water in total being pumped out of the holding tank during 2023. The wash water was disposed of as non-hazardous waste by Wind River Environmental LLC of Marlborough, Massachusetts, during 2023. Copies of invoices for the 2023 wash water pump outs are provided as Attachment 4. 2023 Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road West Yarmouth, MA 0444.0074M005.109.AT-CV ROUX ATTACHMENTS 1. Mass Tank Inspection & Services Annual Testing Report 2. 2023 Alarm Panel Testing Logs 3. Monthly Waste Management Operating Logs 4. Wash Water Pump Out Invoices 2023 Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road West Yarmouth, MA 0444.0074M005.109.AT-CV ROUX ATTACHMENT 1 Mass Tank Inspection & Services Annual Testing Report 2023 Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road West Yarmouth, MA 0444.0074M005.109.AT-CV ROUX ATTACHMENT 2 2023 Alarm Panel Testing Logs 2023 Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road West Yarmouth, MA 0444.0074M005.109.AT-CV ROUX ATTACHMENT 3 Monthly Waste Management Operating Logs 2023 Storage of Toxic or Hazardous Materials License Annual Report FedEx Express Facility HYAA 60 Ansel Hallet Road West Yarmouth, MA 0444.0074M005.109.AT-CV ROUX ATTACHMENT 4 Wash Water Pump Out Invoices