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Region 10: The Pacific Northwest |  |
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Serving the people of Alaska, Idaho, Oregon, Washington and 270 Native Tribes
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Hanford Federal Facility RCRA and TSCA Cleanup Activities
Cleanup activities at the US Department of Energy (US DOE) Hanford Federal Facility 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, the federal Resource Conservation and Recovery Act (RCRA), 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 of the RCRA program appear both in the Tri-Party Agreement, and in the Hanford Federal Facility Site-Wide Permit which is issued in two components separately by Ecology and EPA (PDF file, 146 Kb). EPA Region 10's Office of Waste and Chemicals Management 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, the Washington State Department of Ecology has been working 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 the proposed national geologic repository at the Yucca Mountain, Nevada facility. The national repository is not anticipated to receive authorization from the state of Nevada to receive mixed high-level waste (wastes jointly regulated for their hazardous and radioactive components). Hanford tank wastes are regulated as mixed wastes and carry RCRA hazardous waste codes, so treated wastes would not meet Yucca Mountain waste acceptance requirement when it is licensed to accept high-level 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 file, 156 Kb, 6 pages) 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. go to top Hanford Site Solid Waste Environmental Impact Statement (EIS) The U.S. Department of Energy, Richland Operations Office (DOE-RL) has completed and released for public review and comment a revised draft Hanford Site Solid (Radioactive and Hazardous) Waste Program Environmental Impact Statement (HSW EIS). Information about this document and opportunities for public involvement may be found at the HSW EIS website .Modification to the Corrective Action Section of the Hanford Federal Facility RCRA Permit In October 1999, EPA and Ecology jointly proposed modifications to the Hanford site-wide permit that were intended to transfer authority for RCRA corrective action requirements from EPA to Ecology as outlined in EPA’s October 1999 Fact Sheet and October 1999 Statement of Basis. Ecology finalized modifications to the Ecology portion of the Hanford site-wide permit on March 28, 2000. The Department of Energy appealed these conditions, but reached a settlement with Ecology before the state Pollution Control Hearings Board. EPA did not finalize its changes to the EPA portion of the Hanford site-wide permit pending the outcome of the appeals process. As a result of this settlement, EPA and Ecology sought additional public comment on the proposed transfer of corrective action authority from EPA to Ecology as outlined in the EPA's February 2001 Fact Sheet. Ecology also requested additional public comment with respect to the settlement, as described in the Ecology Focus Sheet.go to top 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. 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 for disposal of K-basin PCB remediation waste (October 22, 2003) (PDF, 159Kb, 16 pages) 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 risk-based disposal approval (RBDA) for the 200 Area Liquid Waste Processing Facilities (LWPF) (DOE/RL-2002-02, Revision 0, February 22, 2002) (PDF, 607Kb, 59 pages) and an RBDA application for the double-shell tanks (RPP-8393 August 2002;DOE letter #R01-EMD-034, January 15, 2002) (PDF, 440Kb, 78 pages). EPA solicited public comment on a draft approval for the Liquid Waste Processing Facilities 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. 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 (509) 372-7938 or bartus.dave@epa.gov.
Effluent Treatment Plant (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: Questions and comments should be directed to Dave Bartus, at (509) 372-7938, or bartus.dave@epa.gov. go to top Hanford Compliance Documents Ecology's Hanford Focus Sheet (February 22, 2001) - Settlement of the Appeal of Modification to the Corrective Action Section of the Hanford Facility RCRA Permit (PDF file, 28 Kb) US DOE Hanford Federal Facility Consent Decree and Final Order (October 12, 2000) (PDF file, 42 Kb) US DOE Hanford Operation Fined $55K - Press Release (March 6, 2000) Related Links EPA Region 10 Office of Environmental Cleanup (Superfund) Hanford Web pages US DOE Hanford Website go to top Unit: Office of Waste and Chemicals Management Dave Bartus E-Mail: bartus.dave@epa.gov (509) 372-7938 Phone Number: (509) 372-7938 Last Updated (mm/dd/yy): 08/04/2004 Permits http://yosemite.epa.gov/R10/OWCM.NSF/permits/hanfordhome |
