Hanford Federal Facility RCRA and TSCA Cleanup Activities
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Cleanup activities at the US Department of Energy (US DOE) Hanford Federal Facility (EPA RCRA Site ID Number WA7_89000_8967) are the joint responsibility of EPA Region 10 and the Washington State Department of Ecology, Nuclear Waste Program (Ecology) under the federal Superfund (CERCLA) program and the state Hazardous Waste Management Act, and respective implementing regulations. The specific division of labor between these agencies and authorities may be found in the Hanford Federal Facilities Agreement and Consent Order, more commonly known as the Tri-Party Agreement (TPA).
The TPA allocates oversight of Hanford cleanup activities between EPA and Ecology. As a means to streamline the work of each agency and to avoid the potential for imposition of conflicting requirements, EPA and Ecology have included a “One-regulator” agreement into the TPA and a separate Memorandum of Understanding (MOU). The MOU (PDF, 312Kb, 11pgs.) discusses specific procedural steps agreed to between the two agencies for implementing the ne-regulator agreement, and the respective roles and responsibilities of the two agencies. Waste management and corrective action requirements under the state Dangerous Waste program appear in the Hanford Federal Facility Dangerous Waste Permit which is issued by Ecology. EPA Region 10 is also responsible for establishing requirements for managing PCB-containing wastes under the Toxics Substance Control Act (TSCA).
As part of the U.S. Department of Energy, Office of River Protection (DOE-ORP) efforts to treat Hanford's 53 million gallons of high-level radioactive tank wastes, EPA Region 10, and the Washington State Department of Ecology has worked closely with the DOE-ORP and the waste treatment plant contractor, Bechtel National, Inc. (BNI) to develop key technical and regulatory elements of a RCRA delisting petition for vitrified high-level tank wastes. These efforts are intended to establish a regulatory pathway that will enable vitrified Hanford tank wastes to be placed in a geologic repository. The national repository is not anticipated to receive authorization to accept mixed high-level waste (wastes jointly regulated for their hazardous and radioactive components), such as Hanford tank wastes. The Tri-Parties have agreed to pursue a RCRA delisting petition through TPA milestone M-62-03. Should it be approved, the delisting action would remove treated high-level wastes from RCRA jurisdiction.
As part of discussions with DOE-RL and BNI, EPA and Ecology have evaluated the effectiveness of high-level waste vitrification with regard to destruction or removal of hazardous organic constituents found in tank wastes from the finished glass waste form. EPA has prepared a policy paper concerning destruction of hazardous organic constituents in Hanford tank wastes (PDF) (6 pp, 156K) as part the delisting petition development process. Briefly, this policy document establishes EPA's position that vitrification units, such as those being constructed as part of the Hanford Tank Waste Treatment Plant are expected to provide effective destruction or removal of organics from vitrified high-level wastes.
DOE-RL submitted the RCRA delisting petition discussed above in December, 2006, in satisfaction of TPA milestone M-62-03. Due to changes in the WTP construction schedule and uncertainties in licensing of a national geological repository, EPA Region 10 has postponed review of the delisting petition.
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Management of PCBs in Hanford Tank Wastes
During Hanford’s production era, polychlorinated biphenyls (PCBs) were used in various aspects of fuel fabrication, reactor operations, and plutonium production. As a result, at least some of the 53 million gallons of high-level radioactive wastes currently stored at Hanford are regulated by the Toxic Substance Control Act (TSCA) as PCB remediation waste. Although management and treatment of tank wastes is overseen principally by Ecology under the state dangerous waste program, the Department of Energy anticipated potential that might arise under a dual RCRA/TSCA regulatory approach. As a result, EPA, Energy and Ecology developed a Framework Agreement outlining key elements of how TSCA requirements would be applied to TSCA-regulated tank wastes. The basis of this framework agreement is use of risk-based disposal approval authority, made available through the TSCA disposal amendments of 1998.
Under the framework agreement, EPA, Ecology and Energy anticipate a phased approach of approvals specific to the various components of the Hanford tank waste management system. The first of these components was approved on February 15, 2001 for the 242-A evaporator run (PDF) (2 pp, 436K). Results of the pilot campaign were transmitted to EPA in the form of a post-campaign report dated May 7, 2001.
In addition to management of tank PCB remediation waste in the 200 Area LWPF, the February 2002 RBDA application also requested approval to manage aqueous PCB remediation waste from the 100 Area K-basins. Although management of these non-tank wastes is not within the scope of the Framework Agreement, they are proposed to be managed in the same physical waste management facilities. Therefore, EPA has granted a risk based disposal approval (RBDA) for disposal of K-basin PCB remediation waste (October 22, 2003) (PDF) (16 pp, 159K) based on the 200 Area LWPF RBDA application.
Consistent with the phased approach to implementing the Framework Agreement, the Department of Energy has submitted an application for RBDA for the 200 Area Liquid Waste Processing Facilities (LWPF) (PDF) (59 pp, 607K) and an RBDA application for the double-shell tanks (PDF) (78 pp, 440K). EPA solicited public comment on a draft approval for the Liquid Waste Processing Facilities (PDF) (24 pp, 333K) from December 8, 2003 through January 9, 2004. No comments were received, and EPA issued a final approval for the Liquid Waste Processing Facilities on June 8, 2004. This action represents the first implementation phase of the Framework Agreement risk-based disposal approval. (Please see Related Documents below for a full listing of documents.)
EPA expects a similar draft approval to be available in the second half of 2004 that will address PCB remediation waste management in the double-shell tank system. When proposed, this will represent the second implementation phase of the Framework Agreement RBDA.
Questions and comments should be directed to Dave Bartus, at (206) 553-2804 or email@example.com.
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Hanford PCB Management Related Documents:
Waste Retrieval from Single-Shell Tanks
- Application for Risk-Based Disposal Approval (RBDA) for PCBs, Hanford 200 Area Liquid Waste Processing Facilities, DOE/RL-2002-02, Revision 0 (February 22, 2002) (PDF) (59 pp, 607K)
- Double-Shell Tank System PCB Risk Assessment Risk-Based Disposal Approval (RBDA) Application (RPP-8393 August 2002; DOE Letter #R01-EMD-034, January 15, 2002) (PDF) (78 pp, 440K)
- RBDA Approval of K-Basin PCB Remediation Waste (October 22, 2003) (PDF) (16 pp, 159K)
- Draft approval for the Liquid Waste Processing Facilities (December 8, 2003) (PDF) (24 pp, 333K)
- Final approval for the Liquid Waste Processing Facilities (June 8, 2004) (PDF) (27 pp, 317K)
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The Department of Energy – Office of River Protection (DOE-ORP) has proposed to the Department of Ecology (Ecology) use of supernatant from double-shell tanks (DST) for purposes of retrieval of sludge wastes from selected single-shell tanks (SST). Pursuant to the Framework Agreement, DST supernatant is regulated as PCB remediation waste, and EPA has determined that the proposed use of supernatant requires TSCA approval. As a result, Energy submitted an application for a risk-based disposal approval (PDF) (84 pp, 476K). In response to this application, EPA has issued a Phase I RBDA approval common to all twelve SSTs (PDF) (35 pp, 2.5MB) selected for retrieval using supernatant, combined with a tank-specific Phase II RBDA approval for tank 241-S-102.
Subsequently, based on Tank Waste Retrieval Work Plans (TWRWPs) approved by Ecology, EPA has issued several additional Phase II RBDA approvals for retrieval of wastes from additional SSTs using DST supernatant.
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Other Hanford PCB Approvals
K-Basins North Load-out Pit (NLOP)
As part of an amended CERCLA Record of Decision (ROD) for the Hanford K-basins, EPA required that treatment of sludges from the North Load-out Pit (NLOP) be subject to treatment necessary to meet waste acceptance criteria for disposal as transuranic waste in lieu of long-term storage at the T-plant facility. The ROD amendment also specified that the T-plant facility is considered “off-site” with respect to the CERCLA remedy, so that the permit exclusion of CERCLA does not apply. As a result, Energy submitted an application for a risk-based disposal approval on May 19, 2005 (PDF) (16 pp, 541K) for the sludge treatment process that will manage K-basin NLOP sludge. Based on this application, EPA issued the requested approval on July 1, 2005 (PDF) (17 pp, 219K). Energy requested a minor modification (PDF) (3 pp, 264K) to this approval on November 6, 2006. On February 12, 2007, EPA approved the requested modification (PDF) (19 pp, 466K) to the approval allowing additional schedule flexibility for treatment campaigns relating to inspections during periods of inactivity.
200-Area Water Tanks
The United States Department of Energy (DOE-RL) is attempting to secure recycling and/or disposal capacity for two water tanks formerly used at the Hanford site. Unlike most wastes associated with site cleanup, these tanks are not radioactively contaminated – on-site disposal is not possible, since existing on-site disposal capacity is limited to radioactively-contaminated wastes. DOE-RL therefore sought to recycle the tanks as scrap metal, but has been unable to do so after becoming aware that paint in the interior of the tanks contains polychlorinated biphenyls (PCBs) at levels such that the tanks are regulated as PCB bulk product waste under the Toxic Substances Control Act (TSCA). With this finding, DOE-RL has found that identifying a final disposition pathway is both more complicated and more time consuming than initially expected. Since continued storage is regulated under TSCA, and on-siteTSCA-compliant storage that could accept the tanks is not available, DOE-RL is seeking a risk-based approval for compliant storage of the two tanks at their current field location while it continues final disposition efforts. DOE-RL submitted an application (PDF) (7 pp, 624K) for a risk-based disposal approval supporting DOE-RL's efforts to secure recycling and/or disposal capacity on date. After review of DOE-RL's application, EPA issued a risk-based disposal approval (PDF) (6 pp, 288K).
On December 20, 2007, DOE-RL provided a request for a one-year extension (PDF) (2 pp, 23K) to the RBDA approval, based on provisions of the original approval. DOE-RL determined that recycling of the PCB-contaminated water tank was not feasible, and elected to perform size-reduction of the water tanks followed by disposal in the Hanford Environmental Restoration Disposal Facility, or ERDF. EPA concurs with this approach, and has modified the RBDA approval (PDF) (8 pp, 242K) to include requirements pertaining to size reduction activities, and to allow additional time to complete size reduction and disposal.
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Effluent Treatment Facility (ETF) Delisting
On November 29, 2001, the Department of Energy-Richland Operations Office (DOE-RL) petitioned EPA Region 10 to modify the RCRA delisting rule (See 60 Federal Register [FR] 31115, June 13, 1995) currently applicable to treated effluents generated by treatment of radioactive wastewaters at ETF. The new delisting petition requests an increase in the wastes that can be managed under the delisting to 210 million liters/year, and requests addition of a number of waste numbers for which treated effluents are delisted. In addition, this petition requested a new delisting for certain secondary wastes generated from ETF treatment operations. An electronic copy of this document may be found at ETF Delisting Rule Proposal.
ETF Delisting Petition Documents
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Final ETF Delisting Rule
EPA finalized a Response to Comments document on July 25, 2005 (PDF) (29 pp, 108K), after receiving comments from two parties, and promulgated the Final ETF Delisting Rule on August 3, 2005 (PDF) (10 pp, 215K).
The Washington State Department of Ecology has completed approval of a parallel state action complimenting EPA’s approval. For information on this state action, please see the section “Other Permitting Documents” appearing on Ecology’s Nuclear Waste Program’s Key Documents page.
Subsequent to publication of the final ETF Delisting Rule, the Department of Energy submitted a request for alternate reuse practices (PDF) (6 pp, 308K) for treated effluent in lieu of disposal at the State Authorized Land Disposal Site (SALDS), pursuant to Condition 7 of the new rule. Based on the information provided in the request letter, EPA has issued an approval letter for the proposed reuse practices (PDF) (2 pp, 70K).
Questions and comments should be directed to Dave Bartus, at (206) 553-2804, or firstname.lastname@example.org.
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